Contract · Duluth, Minnesota · Signed May 2020; renewed January 12, 2026
Duluth’s no-contribution addendum
LexisNexis has a version of the form with the license grant removed. Duluth signed that one. The question is whether it still governs the subscription the council renewed in 2026.
3
Meets
4
Partial
0
Fails
11
Missing
of 18 practices this document could address
Duluth’s 2020 AVCC addendum is titled, in capitals, “NO DATA CONTRIBUTIONS TO PSDEX.” Compared with the standard form it is missing Section I.2, the contribution obligation, and Section II.1, the irrevocable license. What remains is LexisNexis’s promise to provide PSDEX information to the city and the city’s promise to access other agencies’ data only through LexisNexis. The council approved it unanimously at $17,800 a year.
In January 2026 the council renewed for 40 months at roughly $32,000 a year, 7 to 2, after residents raised ICE. The chief told reporters “we do not upload our data to LexisNexis, our data is not shared, we do not have an interface,” and a LexisNexis list of the 72 Minnesota agencies contributing to AVCC does not include Duluth. The 2026 Schedule A the council approved, however, pays for “five (5) Database Interfaces” with capacity for a 300-megabyte daily import, and a 2022 renewal package in the city’s files carried the standard contributor form, unsigned. No signed contributor addendum has surfaced. The no-contribution addendum appears to be the operative document, and the interface capacity appears to be unused. Both are worth a records request.
Primary source
AVCC XML Addendum, “NO DATA CONTRIBUTIONS TO PSDEX” (ADDM_ AVCC/ACA/CCM Q1.20.v1), City of Duluth document 23908, with Resolution 20-0345RRead 2026-09-28
Document
Practice by practice
What the document says, or does not say, on each practice in the Standard. Practices this kind of document has no business addressing are marked n/a. These marks are evidence for a jurisdiction’s grade; the document itself gets no score.
Stage 1
Decide
- Missing
The 2026 memo describes the product. It does not say what problem it solves or what was tried first.
- Missing
- Meets
1.3Public notice and a recorded vote
Resolution 20-0345R adopted in open session; 2026 renewal debated and voted 7 to 2 with the Schedule A attached.
Stage 2
Acquire
- Partial
2.1Direct contract, no marketplace add-ons
Direct contract for a platform, with TraX added on. The addendum names “the ACA product” and PSDEX; features enabled later would not appear here.
- Missing
2.2Published use policy before deployment
No use policy for how officers query other agencies’ records.
- Partial
Three-year initial term, then a 40-month term that “will not renew.” Each renewal is a council vote. Neither required a review of results.
- Meets
2.4No irrevocable license to the vendor
No license grant, because no data is contributed. The 2022 package and the 2026 interface capacity are the loose ends.
Stage 3
Deploy
- Missing
3.1Purpose limitation in writing
Nothing limits what Duluth officers may query PSDEX for.
Stage 4
Use
- Missing
4.1Logged justification for every query
Query justification is not addressed. The master terms let LexisNexis audit the city’s use, not the reverse.
- Partial
4.2Access control and separation of duties
CJI-authorized users only, per the incorporated FBI security addendum.
- Missing
Stage 5
Share
- Meets
5.1No sharing without a published policy
Nothing is contributed, so nothing can be shared. The chief’s public statement and LexisNexis’s own contributor list agree.
Stage 6
Retain
- n/a
6.1Shortest retention that serves the stated purpose
No Duluth data at LexisNexis to retain.
Stage 7
Audit
Stage 8
Retire
- Missing
- Partial
8.2Exit terms and certified destruction
The FBI security addendum requires deletion or return of criminal history information at termination. Nothing broader.
What to take from it
The best way to control what LexisNexis does with your records is to not send them. Duluth is the proof the form is negotiable down to zero. What the contract does not govern is what Duluth officers do with everyone else’s records, and it does not explain why a city that contributes nothing is paying for five import interfaces.