LEADS Consulting

Audit of Moorhead PD's ALPR practices (one mobile squad-car-mounted 3M BOSS unit, operational since Nov. 2014) found full compliance with Minn. Stat. 13.824. Auditor's conclusion: "LEADS Consulting finds the Moorhead Police Department ALPR Practices to be in compliance with Minnesota Statute 13.824." Auditor sampled 130 of 6,357 recent (60-day) reads plus all 53 recent hotlist hits, against total system history of 603,205 reads / 5,652 hits since 2014; confirmed no data retained beyond the 60-day non-investigative limit. Narrative also notes data-quality noise unrelated to compliance (12 false reads from bumper stickers/signs, 15 misreads from a 'Harvest Church' sign, 2 duplicate hits) but records no formal exceptions or recommendations.

No discrepancies recorded, and the testing was genuinely substantive: LEADS examined a random sample of 160 of 3,726 reads from the prior 48 hours, ran electronic searches of the live BOSS database confirming no data older than 48 hours, examined the audit trail directly (16 trooper users, 4 administrators), and reviewed public logs of use. Observations noted without findings: 2 of 16 ALPR units had malfunctioning GPS recording (3M delaying repair amid its sale of the ALPR business to Neology), two false reads, and duplicate reads among hits. Notable: the State Patrol deletes ALPR data within 48 hours, far stricter than the 60-day statutory maximum — the shortest retention in this table.

No discrepancies recorded, with genuinely substantive testing: LEADS examined 610 of 131,791 reads from the prior 60 days, ran electronic searches of the live ELSAG database confirming no data older than 60 days, and examined the audit trail directly. Observations noted without findings: 18 reads missing GPS location data, one photo captured a person near a plate (not discernible), 24 false reads from street signs/mailboxes/bumper stickers, and duplicate hits including one impounded vehicle that alarmed 58 times.

GHOST FINDING — the audit closes with a recommendation and records no exception. LEADS writes that "LEADS Auditors recommend that the department produce and save monthly or bi-monthly reports containing summary data," while the report's own conclusion is unqualified: "LEADS Consulting finds the Brooklyn Park Police Department to be in compliance with Minnesota Statute 13.824." The recommendation names a real transparency gap — the department was found capable of producing the required usage reports but was not producing and retaining them as a matter of practice, which is the mechanism by which the public and the agency's own supervisors can see how ALPR is used. Under FinePrint's scoring that maps to the Material precedent for an absent public log of use. Because the auditor recorded it as advice rather than an exception, it does not change the official findings count; it is logged as one ghost finding against LEADS. See the Feed article "The ghost findings of Minnesota's ALPR audits." Otherwise the audit is methodologically real. LEADS reviewed all 534 reads in the sample window against the statute's collection limits, examined the 3M BOSS audit trail directly, ran electronic database searches, and confirmed no data retained past the 60-day destruction deadline. Access was limited to six authorized users, all logged. System totals reported: 88,692 reads and 193 hits in the 60 days preceding fieldwork; 8,391 hits since the system went live in May 2015. The narrative also records data-quality noise that carries no compliance weight and is not scored as findings — five reads missing GPS data, four with indiscernible persons, six false reads off fencing and weeds, several off street signs, 35 of 193 hits sequential duplicates, and several false hits where the plate's state could not be identified.