Official Documents

Summary

Response from Grafton Police Department to Wisconsin Open Records request dated October 28, 2025, received November 11, 2025. This document provides critical transparency about Flock camera usage, agency access lists, search practices, and oversight compliance.

What This Document Contains

• Network Access List: Documentation of 591 agencies with access to Grafton's camera data
• Usage Statistics: Information about how Grafton officers use the ALPR system
• Transparency Portal Status: Confirmation that Grafton has NOT enabled public transparency portal
• Audit Compliance: Information about whether Policy 427's required audits are conducted
• External Agency Tracking: Details on whether Grafton tracks how other agencies use its data

Why This Matters

This Open Records Response revealed several concerning gaps in Grafton's ALPR oversight:

• 591 agencies across 32+ states have access to Grafton's camera data
• Grafton does not track how external agencies use its data
• The public transparency portal (included in Flock contract) remains disabled
• Limited information available about audit compliance and search justification practices

This response demonstrates why resident oversight and transparency are critical. Without public records requests, residents would have no way to know how their location data is being used, who has access, or whether required safeguards are being followed.

Summary

The actual binding contract between the Village of Grafton and Flock Safety, signed October 20, 2023. This 5-year agreement costs $88,150 total ($17,500/year) for seven Falcon cameras with 30-day data retention and nationwide network access.

Key Details

• Cost: $17,500 per year (7 cameras × $2,500 each)
• Contract Term: 60 months (December 2023 - December 2028)
• Total Value: $88,150
• Data Retention: 30 days
• Hardware Ownership: Flock retains ownership; Village leases equipment

Critical Excerpts

On Network Access:

"Nationwide Network (LP Lookup Only) - Allows agencies to look up license plates on all cameras opted in to the nationwide Flock network."

On Flock's Perpetual Data Rights:

"Customer hereby grants Flock a non-exclusive, worldwide, perpetual, royalty-free right to use and distribute such Anonymized Data to improve and enhance the Services and for other development, diagnostic and corrective purposes, and other Flock offerings."

On Third-Party Data Sharing:

"Flock may access, use, preserve and/or disclose the Footage to law enforcement authorities, government officials, and/or third parties, if legally required to do so or if Flock has a good faith belief that such access, use, preservation or disclosure is reasonably necessary to comply with a legal process, enforce this Agreement, or detect, prevent or otherwise address security, privacy, fraud or technical issues, or emergency situations."

On NCIC Integration:

"Real-Time NCIC Alerts on Flock ALPR Cameras - Alert sent when a vehicle entered into the NCIC crime database passes by a Flock camera."

Why This Matters

This contract reveals that Flock Safety, not the Village of Grafton, retains ultimate control over the data infrastructure. The company holds perpetual rights to anonymized data patterns and can share footage with third parties under certain circumstances. Grafton residents' location data feeds a nationwide commercial surveillance network that extends far beyond local law enforcement.

Summary

Official Grafton Police Department policy governing how officers use ALPR cameras. Updated September 17, 2025. This policy explicitly states that officers do not need warrants, probable cause, or even reasonable suspicion to search license plate data.

Critical Excerpts

No Warrant Required:

"An ALPR may be used in conjunction with any patrol operation or official department investigation. Reasonable suspicion or probable cause is not necessary before using an ALPR."

On Nationwide Network:

"Because Flock Safety is part of a nationwide network, the Chief of Police may grant other law enforcement agencies access to the Grafton ALPR data."

On Search Requirements:

"Under all circumstances, the person searching for information through the Flock Safety camera system shall include a reason for the search under the 'Search Reason' block. There should be a corresponding case or call for service number associated with each search. Blanket searches absent a bona fide reason, are strictly prohibited. The only exception is for training and or demonstration purposes."

Data Not Public:

"All data and images gathered by an ALPR are for the official use of the Grafton Police Department and because such data may contain confidential TIME information, it is not open to public review."

Authorized Uses:

"ALPRs are used by the Grafton Police Department to convert data associated with vehicle license plates for official law enforcement purposes, including identifying stolen or wanted vehicles, stolen license plates and missing persons. ALPRs may also be used to gather information related to active warrants, homeland security, electronic surveillance, suspect interdiction and stolen property recovery."

Why This Matters

This policy contradicts the Fourth Amendment principle established in Carpenter v. United States (2018), which held that comprehensive location tracking requires a warrant. By explicitly stating that "reasonable suspicion or probable cause is not necessary," Grafton Police claim authority to conduct warrantless mass surveillance of all drivers.

The policy's prohibition on "blanket searches" is not enforceable without audit transparency. Policy 427 requires regular audits of search activity, but no audit reports have been made public.

Summary

The original ALPR policy adopted September 2021 when Flock cameras were first deployed. Comparing this to the 2025 version reveals how the policy evolved as the system expanded.

Why This Matters

Preserving the original policy allows researchers to track how search authorities, data sharing provisions, and oversight requirements have changed over time. Any weakening of restrictions or expansion of search powers becomes visible through comparison.

Summary

Formal recommendation from the Public Safety Committee to the Village Board to approve the 5-year Flock contract. This is the document that authorized the current deployment.

Complete Text

"VILLAGE OF GRAFTON
REPORT OF THE PUBLIC SAFETY COMMITTEE
December 12, 2023

1. Motion, to recommend that the Police Chief's request to enter into a five-year contract with Flock Safety for License Plate Reading (LPR) technology be approved.

Amy Luft, Chair

Committee members present: Trustee Amy Luft, Trustee Mary Pat Fenton, Trustee Dave Armstrong, Jeff Thoma, Barry Jondahl and Guy Paider.

Staff present: Fire Chief William Rice, Police Chief Jeff Caponera, and Administrative Assistant Diana Degnitz."

Why This Matters

This is the pivotal authorization document. The committee's recommendation led to Village Board approval on December 18, 2023, committing Grafton to five years of surveillance at a cost of $88,150. No public opposition is documented in the minutes, suggesting either lack of public awareness or no public comment period.

Summary

Internal Grafton Police Department form requesting renewal of the Flock contract. Shows the administrative process and justification used to secure the 5-year agreement.

Why This Matters

This document reveals the internal decision-making process. It likely contains Chief Caponera's justification for the renewal, cost-benefit analysis, and effectiveness claims that persuaded the Public Safety Committee to recommend approval.

Summary

Memo from Chief Caponera explaining why Grafton Police chose Axon body-worn cameras over competitors. Reveals that Flock camera integration was a deciding factor in selecting Axon, which cost $177,881 for body cameras and in-car video systems.

Critical Excerpt

"There are a host of other reasons we chose Axon over other vendors such as Watch Guard and our current vendor Arbitrator by Panasonic, including reliability and the ability to sync our in-car video with our Flock Safety cameras."

Why This Matters

This document proves that Flock cameras were already integrated into Grafton's broader technology ecosystem by June 2022, influencing major equipment purchases. The surveillance infrastructure is not isolated - it's part of a unified platform that combines license plate tracking, body cameras, and in-car video into a comprehensive surveillance system.

The Flock system drove $177,881 in additional spending, demonstrating how initial ALPR deployment creates vendor lock-in and escalating costs.

Summary

Five-year capital improvement budget approved June 2025, allocating $120,830 for surveillance and security including ongoing Flock ALPR costs through 2030.

Key Excerpt

Surveillance & Security ($120,830 - 9% of budget)

"Flock Safety ALPR ($17,500): Continuation of license plate reader network (years 1-5 of 5-year agreement signed in 2024)"

Why This Matters

This document proves Grafton is committed to Flock cameras through at least 2030, with $17,500 budgeted annually. The 5-year contract locks in this spending with no opportunity for community input or annual reconsideration.

Summary

Detailed police department capital budget spreadsheet showing year-by-year allocation for Flock cameras alongside other equipment purchases like Tasers, body armor, and squad cars.

Why This Matters

This spreadsheet shows Flock ALPR funding in the context of the entire police budget. The $17,500 annual cost is presented as a routine "lease program" alongside Taser leases, making the surveillance cameras appear as ordinary equipment rather than a constitutional issue.

Summary

Public Safety Committee's explanation of capital improvement priorities for 2025-2029 fiscal years, listing ALPR lease program among ongoing technology expenditures.

Key Excerpt

"These programs/items include the fleet lease program, Taser lease program, ALPR lease program (Flock), body-worn camera and squad in-car video system replacement, personal protective gear (body armor, gas masks, ballistic helmets, etc.), rifle shields, replacement duty weapons, drone, squad laptop replacement, cruiser radar replacement, and other police department furniture/fixtures/equipment as needed."

Why This Matters

Flock cameras are presented as routine "lease program" equipment alongside Tasers and police cars, buried in a list with body armor and laptop replacements. This framing avoids any discussion of constitutional implications or community surveillance concerns.

Summary

THE most important meeting minutes. This is the Public Safety Committee meeting where Chief Caponera presented the 5-year Flock renewal request and the committee voted to recommend approval to the Village Board.

What to Look For

• Chief Caponera's presentation on Flock effectiveness
• Discussion of 5-year contract vs. annual renewal
• Cost analysis showing price lock-in at $2,500/camera (vs. new $3,000 rate)
• Committee questions about data sharing and network access
• Public comment (if any occurred)
• Final vote count

Why This Matters

This meeting set in motion the 5-year, $88,150 commitment to Flock cameras. The discussion and vote happened at the committee level with minimal public visibility. Understanding the justifications presented and questions asked (or not asked) reveals how surveillance expansion occurs without robust community debate.

Summary

Village Board meeting where trustees voted to approve the 5-year Flock contract based on the Public Safety Committee's recommendation.

What to Look For

• Presentation of PSC recommendation
• Village Board discussion and questions
• Individual trustee votes (if roll call recorded)
• Public comment period (if any)
• Authorization language granting signature authority

Why This Matters

This is the final authorization point. The Village Board's vote committed Grafton to five years of ALPR surveillance. These minutes show whether trustees engaged substantively with constitutional concerns or approved the contract as routine business.

Summary

Public Safety Committee meeting from the initial Flock deployment period in 2021. This meeting likely contains early discussion of ALPR technology and the decision to adopt Flock cameras.

What to Look For

• Initial Flock presentation or proposal
• Discussion of camera placement strategy
• Cost estimates and funding sources
• Comparison with other ALPR vendors (if any)
• Policy 427 adoption or discussion
• Community concerns raised (if any)

Why This Matters

Understanding the original justifications and promises made in 2021 allows comparison with the current reality. Has crime decreased? Are cameras used as initially described? Did cost and scope remain as projected? This historical record provides accountability.