Lynn Lembcke Consulting
22 ALPR audits across 20 agencies. Of the 22 we have read in full, 19 recorded zero findings (86%). Individual findings break down as 2 material, 1 superficial. Depth: checklist, substantive.
20
Agencies audited
22
Audits filed
86%
Zero findings
2
Real findings
Flags
One flag on who this auditor is, without a mill pattern in the output yet.
Law enforcement background
The firm’s principal or governing board includes current or former police personnel.
Audits by this auditor
No discrepancies noted.
Read the audit (LRL 260881) →Zero findings. Lembcke returned no discrepancies against all seven statutory requirements: data collection and classification, destruction of data, sharing among law enforcement agencies, log of use, biennial audit records, authorization to access data, and BCA notification. The audit covered a dual deployment of six permanent Flock cameras and fifteen Axon squad units over a two-year period, both on 30-day retention, and queries run in Flock Analytics and Evidence.com confirmed no ALPR data older than thirty days was held. The report records three warrants obtained during the period to track individuals under active criminal investigation, no exigent-circumstances uses, no written sharing requests from other agencies, no preservation or chapter 5B destruction requests, and no security breaches. The public log of use consists of system-generated reports plus the agency's Flock transparency portal, covering only data inside the 30-day retention window. No ghost-finding language: the narrative admits no gap that it then failed to record.
Read the audit (LRL 261789) →One discrepancy recorded, under Log of Use Required: the public transparency portal omits the specific time of day ALPRs actively collected data. The office says it will use system-generated reports (which include time of day) going forward. A second 'Discrepancy noted' annotation appears next to the statement that the office has no stationary/fixed ALPRs, with no explanation; treated as a template artifact, not a second finding. All other sections (data collection/classification/use restrictions, destruction/60-day retention, sharing, biennial audit, access authorization, BCA notification) marked 'No discrepancies noted.' One ALPR photo was shared with another agency during a homicide investigation; no other sharing reported.
Read the audit (LRL 261569) →Lembcke audited Belle Plaine PD's Flock system (5 stationary cameras, no mobile units). Went section by section through the statute's seven requirements, querying live data in Flock Analytics for retention (30-day default, confirmed no data older than 30 days), sharing, log of use (verified against the statutory checklist), access authorization, and BCA notification (confirmed on the BCA site, including the five fixed locations). A BCA CJIS security audit was also conducted in July 2024. Every section closed 'no discrepancies noted.'
Read the audit (LRL 261027) →Zero findings recorded. The auditor walked each statutory requirement under Minn. Stat. 13.824 and closed every section with "No discrepancies noted." Shakopee ran three ALPR systems during the period: Elsag Plate Hunter (discontinued January 8, 2025), Flock cameras in six permanent locations on a 30-day retention, and Axon squad-mounted ALPRs on 60 days. No recommendations, no exceptions, and no ghost-finding language in the narrative.
Read the audit (LRL 261013) →No discrepancies noted.
Read the audit (LRL 260654) →Discrepancy noted: the department submitted its LPR Agency Data Collection Forms to the BCA but not within ten days of installation as required by subd. 8. All other items: no discrepancies. The lone finding across all Lembcke ALPR audits reviewed.
Read the audit (LRL 251759) →No findings recorded. The report recites "No discrepancies noted" against each of the seven § 13.824 requirements. Data limited to "license plate numbers; date, time, location" and vehicle images, all classified as private; 30-day retention with systematic deletion, and "A query of data stored in Flock Analytics confirmed" nothing exceeded that window; no data-sharing requests received during the period; public log of use maintained; "Access is managed by the assignment of roles and permissions in Flock"; BCA notification timely and camera locations published. No recommendations, no "as a result of this audit" language, no ghost findings.
Read the audit (LRL 260188) →No discrepancies noted across all seven statute subdivisions. 10 Flock stationary readers; 30-day retention confirmed by query of Flock Analytics; BCA notification and fixed-location listing confirmed on the state website.
Read the audit (LRL 260490) →No discrepancies noted.
Read the audit (LRL 260211) →No discrepancies noted. Axon squad-mounted ALPRs only; no stationary units.
Read the audit (LRL 251919) →No discrepancies noted. Axon squad ALPR data integrated into Flock Analytics.
Read the audit (LRL 251717) →No discrepancies noted across all seven statute subdivisions. 3 Flock stationary readers serving Maple Plain and Independence; 30-day retention confirmed by query of Flock Analytics. BCA CJIS Security Audit noted as underway at the time of this audit.
Read the audit (LRL 251300) →No discrepancies noted on any statutory requirement reviewed (data collection/classification/use restrictions, destruction, sharing, log of use, biennial audit, access authorization, BCA notification).
Read the audit (LRL 251687) →No discrepancies noted across all seven statute subdivisions. Uses Axon squad ALPRs (no stationary or fixed-location units); data managed in Evidence.com with a 30-day retention period confirmed by query.
Read the audit (LRL 260527) →No findings. Lembcke checked seven statutory requirements — data collection/classification/use restrictions, destruction of data, sharing among agencies, log of use, biennial audit, authorization to access data, and BCA notification — and recorded "No discrepancies noted" on every one. Report confirms 30-day retention ("thirty (30) days from the date of collection"), matching with the Minnesota License Plate Data File only, warrants required to track criminal investigation subjects, no sharing requests received, no security breaches, and fixed ALPR locations registered with the BCA. No ghost-finding language in the narrative: nothing described as fixed during or as a result of the audit.
Read the audit (LRL 251490) →No discrepancies noted.
Read the audit (LRL 251402) →No discrepancies noted.
Read the audit (LRL 251350) →BCA notification of fixed camera locations was not submitted within the statutory 10-day window after the ALPR system went live (May 2024); the city produced evidence of the original notification and the lapse was since resolved. The audit enumerates seven statutory requirements -- Data Collection; Classification; Use Restrictions / Destruction of Data Required / Sharing Among Law Enforcement Agencies / Log of Use Required / Biennial Audit / Authorization to Access Data / Notification to Bureau of Criminal Apprehension -- and records no discrepancy against the other six.
Read the audit →All seven statutory requirements under Minn. Stat. 13.824 marked 'No discrepancies noted.' Report states the department 'is in compliance with statutes governing access to ALPR data.' Additional observations (not findings): a BCA CJIS Security Audit was conducted in April 2022, and the department reported no security breaches during the period.
Read the audit (LRL 240981) →All seven statutory requirements under Minn. Stat. 13.824 (data collection/classification/use restrictions, destruction, sharing, log of use, biennial audit, access authorization, BCA notification) marked 'No discrepancies noted.' Report states the department 'is in compliance with statutes governing access to ALPR data.' No exceptions or recommendations recorded.
Read the audit (LRL 220708) →Zero findings recorded. The entire report is one page, and it clears the department on all seven statutory requirements with the identical phrase "No discrepancies noted" repeated seven times — no narrative analysis, no recommendations, no exceptions. Affirmative statements include that ALPR data "is only accessible to persons who have completed department approved training and whose work assignment reasonably requires access," that the department "does not monitor or track individuals...using ALPR, nor have they applied for a warrant to do so," and that it "has had no breaches of security." Program at the time: 2 mobile units in patrol vehicles, no fixed cameras, PIPS Technology with BOSS4 software, 30-day retention.
Read the audit (LRL 210879) →These figures describe what the filed reports contain. They are not an allegation that any audit was improper or that any agency is out of compliance with Minn. Stat. § 13.824. If you believe a record here is wrong, tell us and we will correct it.
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