The ghost findings of Minnesota's ALPR audits

Minnesota law requires an independent audit of every police license plate reader program every two years. The audit exists to create a public record: results go to the Commissioner of Administration and the Legislative Commission on Data Practices, and if an audit finds substantial noncompliance, the commissioner can order the cameras shut off. Of the 47 Minnesota ALPR audits FinePrint has read in full, 37 recorded zero findings.

Two of those zero-finding audits describe problems in their own text.

The 2025 audit of the Olmsted County Sheriff's Office, conducted by the Minnesota Security Consortium, notes that the office had not been maintaining a standard set of Log of Use reports for its now-retired BOSS camera system. The public log of use is a requirement under Minn. Stat. 13.824, subd. 5. It is the mechanism that lets a resident see how often the cameras ran and how many plates they read. The report records no discrepancy. The office passed every item, and the auditor offered to assist with reports on future systems.

The 2025 audit of the Oakdale Police Department, by the same auditor, states that Oakdale "now compiles monthly reports" meeting the log of use requirement, and that "as a result of this audit" the department "is now in compliance with this part of the statute." Read that again: as a result of the audit. Before the auditor showed up, the department was out of compliance with the same subdivision Olmsted was missing. The final report: compliant, no findings.

We are calling these ghost findings. A ghost finding appears in the narrative of an audit but never in its record. The auditor saw the gap, wrote it down in passing, and then recorded a clean sheet.

To be clear, fixing a problem is the point. An agency that starts compiling its public log because an auditor asked for it is better off than one that never does. But the statute did not create these audits to deliver quiet consulting. It created them to tell the public and the legislature what the auditor found. There is an honest way to do both, and some auditors use it: the 2025 Columbia Heights audit recorded a late BCA notification as a formal exception and noted it was resolved. The 2025 Deephaven audit recorded the agency's absence from the state's public ALPR list as a finding and got the list corrected. Finding, fix, record. Everyone comes out fine, and the record stays true.

A ghost finding does something different. It converts a statutory gap into a favor between the auditor and the agency, and it hands the legislature a report that says nothing happened. Both ghost findings we have identified so far involve the same statutory requirement, the public log of use, and the same auditor. FinePrint now tracks ghost findings as their own category in ALPR Audit Watch, alongside every audit's recorded findings.

If you have an ALPR audit whose text says more than its record does, send it to tips@fineprint.report.

Source: Olmsted County Sheriff's Office 2025 ALPR audit (LRL 250871) and Oakdale Police Department 2025 ALPR audit (LRL 251753), Minnesota Legislative Reference Library.