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TLO gives Lansing police access to a lot of information

November 13, 2019

 

An alert reader - who wishes to remain anonymous - noticed something in my October 11 story Two civic organizations lose City of Lansing recognition. There was a police report at the end of that story, and the last sentence in that report says

 

 

He noticed that the report

 
  mentioned that they used "TLO" to find other people living at Michelle's address. This appears to be a subscription service from TransUnion, at https://www.tlo.com/law-enforcement. According to the website, among the many features of this service, it grants Law Enforcement access to query our credit histories through Transunion, access employment information, and also lets them "Locate vehicles nationwide using license plate recognition data".   

 

(Transunion is one of the big three credit reporting services: Transunion, Equifax and Experian.}

 

The reader wonders

 
 

Did the City Council authorize LPD to purchase and use such an invasive service? Does LPD have any policies protecting citizen privacy rights related to this private system?  How long has LPD had access to this system?  How has LPD used this system in the past? What does it cost the city? How much data is in the system related to citizens who are not subject to active investigations? How long does this company retain data on Lansing residents? Does a citizen have the option to opt-out of having their data collected by the vendor, or from being accessed by LPD?

 

 

He also wonders

 
 

how use of this TLO system to query the respondent's address for other citizens at that address was relevant to the complaint; since the officer already had the name address of the person accused of harassing the victim, and stated that person could not be located at that address.  Why did they need to know who else lived at the house?  Seems like an invasion of the privacy of the other residents at that address.  (A better use of such a tool might be to find out who the 800 number belonged to that was harassing the victim, to confirm the validity of the complaint.)

 

 

This same reader is familiar with a technology called Automated License Plate Recognition (ALPR) defined at this site as
 

[A] technology that uses optical character recognition (OCR) to automatically read license plate characters. . . Mobile ALPR software suites use multiple cameras mounted on a vehicle. As the vehicle moves, it photographs license plates and transmits plate data to a database. The database may be a national database or it may be created at the local level and downloaded into the vehicle's onboard computer at the beginning of each shift. If the system detects a match, the officer receives an alert on his computer. A mobile ALPR can read up to 1,000 plates per hour and cover two or more lanes of traffic at once.

 

 

Several years ago, the Lansing police department purchased ALPR equipment and software and gave the system a try. In December 2014, our reader submitted a FOIA request to the Lansing police department for an electronic extract of all license plate data collected through the use of ALPR. The city attorney denied the request "pursuant to the personal privacy exemption found at MCL 15.243 (1)(a) of FOIA . . Disclosure of the information would not advance the core purpose of FOIA, which is to significantly contribute to the public understanding of government." But the reader also sent a list of questions to the police department and got an answer from then-Police Chief Mike Yankowski. Yankowski's answers are in bold:

 

 

Our reader says now that

 
  LPD has previously said that they have stopped using in-car ALPR technology, and no longer has ALPR devices or data from those devices.  Even though LPD might not have cameras capturing plate information directly anymore (and they are no longer storing the information themselves), this website suggests LPD now, thru the TLO service, may have access to a network of private license plate location databases (often obtained by using privately owned cameras and GPS equipment installed on taxi cabs, toll roads, and tow trucks, capturing and storing the location of every license plate they pass) to search for all the places that a given vehicle had been seen on public streets or private parking lots, anywhere in the country. This could provide the City with a significant amount of personal information about the activities of the person who uses a given vehicle, as well as locations that they go to regularly -- locations which the person may believe and/or assume to have been private, confidential, and unknown by others 

By using a private nationwide service to perform the function that was previously performed by several local governments in our region (the collection of license plate location information within the City of Lansing limits by LPD), the City has expanded their ability to invade our privacy, and also removed the potential for transparency because these records are no longer created by the government entity (and no longer subject to FOIA).  

 

 

Send comments, questions, and tips to stevenrharry@gmail.com. If you'd like to be notified by email when I post a new story, let me know.

 

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