Flock Safety sends agencies a playbook for narrowing public records requests about its cameras

When Capitola PD received a records request about its Flock cameras, Flock sent the department a guide on exemptions, redactions, and fees, then put its legal and external affairs staff on a call with the city the next day.

The document, titled "Guide to Flock Safety Data for Open Records Laws" and last updated September 3, 2025, walks agencies through arguments for withholding or narrowing requests for Flock records. Flock's customer success manager sent it to Capitola Sgt. Jackie Yeung on November 5, 2025. On November 6, Flock staff from its legal and external affairs teams (Hector Soliman-Valdez, Trevor Chandler, and Amy Palumbo) joined a Zoom with the city about the pending request.

The guide catalogs exemption theories by record category. On audit logs: "Agencies should consider whether to redact license plates, search reasons, and case numbers from these logs." On scope and cost: "Agencies should also consider negotiating a narrowed timeframe and whether they are entitled to payment of an upfront fee for the effort involved." It asserts broad state-law protection for the camera data itself: "The following states have specifically exempted license plate reader records from their public records laws: Georgia, Illinois, Kansas, Maryland, Minnesota, Montana, Nebraska, New Jersey, North Carolina, Oklahoma, Tennessee, Utah (not fully restricted; LPR data considered a 'protected record'), and Virginia." An internal note shows the company's own staff in the workflow: "It is recommended that CSMs assist the customers with the downloads when feasible for timeframes larger than six months and major accounts."

The guide itself has circulated before. The records-request site Footnote4a published the full document in March 2026 and challenged its legal claims. What the Capitola production adds is timing and delivery: the vendor's playbook reaching a ten-camera department at the moment a request was pending, with the company's legal staff joining the small agency's records response the following day.

The guide is written by the vendor whose records are being requested. The company that generates the records supplies the theory for why the public cannot see them, and the staffing to argue it.

Source: Capitola Police Department, California PRA request 124, Bates CAP_PRA_124_000010 (transmittal email), 000011 to 000017 (the guide), 000028 and 000032 (call participants). The guide as previously published: footnote4a.org/news/flock-vs-foia.