FinePrint

Contract · National (Portland, Oregon copy) · Form Q3.21.v1; Portland executed August 2024

LexisNexis’s PSDEX contributor addendum

The three-page form more than 2,400 agencies have signed. It grants LexisNexis an irrevocable worldwide license, lets any subscriber use the records for any mission, and keeps the data forever unless someone writes to ask.

0

Meets

1

Partial

7

Fails

12

Missing

of 20 practices this document could address

This is the addendum a police department signs to join the Public Safety Data Exchange. In exchange for access to everyone else’s records, the department “agrees to contribute public safety information” that other PSDEX customers “may use for analysis, investigations and reporting or other applications to accomplish their mission.” It then grants LexisNexis “a paid up, irrevocable, worldwide, non-exclusive license to use, adapt, compile, aggregate, create derivative works, transfer, transmit, publish and distribute” the contributions. The department keeps ownership of a copy it can no longer control.

Retention is one sentence: “Unless otherwise indicated by written request from Customer, all data will be retained by LN and remain accessible by others.” There is no term, no termination section, no data return, no audit right for the department, and no restriction on which subscribers may search. LexisNexis disclaims responsibility for use of the data “by any third party, including the public or any law enforcement or governmental agencies.” The only named sub-processor is Google, for geocoding.

Portland negotiated two words into its copy, “limited” and “selected by Customer,” and a start date of 2025. The license grant is otherwise untouched. Federal Way, Washington receives an automated receipt from this system every morning.

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

n/a

1.3Public notice and a recorded vote

Whether a council sees this form depends on the city. Portland’s did.

Stage 2

Acquire

Missing

2.1Direct contract, no marketplace add-ons

A direct contract for a platform that is “enhanced by LN data and technology such as LexID.” Marketplace add-ons are enabled elsewhere.

Missing

2.3Sunset clause

Term lives in Schedule A. The license does not end with it.

Fails

2.4No irrevocable license to the vendor

“Paid up, irrevocable, worldwide.” Ownership is retained in name; control is not.

Stage 3

Deploy

Fails

3.1Purpose limitation in writing

Other customers may use the contributions for “analysis, investigations and reporting or other applications to accomplish their mission.” Any purpose, any mission.

Stage 4

Use

Missing

4.1Logged justification for every query

Nothing on query justification. The contributor never sees who searched its records or why.

Partial

4.2Access control and separation of duties

Users must be CJI-authorized personnel under the incorporated FBI security addendum. That governs who can log in, not what they may do.

Stage 5

Share

Fails

5.1No sharing without a published policy

Access is granted to “PSDEX customers” with no geographic, agency-type or federal exclusion. ICE is a PSDEX customer.

Fails

5.2Chain of custody

LexisNexis may “transfer, transmit, publish and distribute.” An optional line shares a de-identified subset with unnamed third parties. Google is the only processor named.

Fails

5.3Downstream deletion

A written request can stop LexisNexis retaining the data. Nothing reaches the subscribers who already searched, viewed or exported it, and nothing says how long a request takes.

Stage 6

Retain

Fails

6.1Shortest retention that serves the stated purpose

“All data will be retained by LN” by default, with no clock.

Missing

6.3Sealed and expunged records are removed

Sealed and expunged records are addressed nowhere in the addendum. Downers Grove confirmed in writing it has no way to monitor what happens after upload.

Stage 7

Audit

Missing

7.2Logs available to the oversight body

The master terms give LexisNexis the right to audit the customer. The customer gets no audit of LexisNexis.

Stage 8

Retire

Missing

8.1An off switch

No termination section in the addendum.

Fails

8.2Exit terms and certified destruction

No data return or destruction. The license is irrevocable by design, so the data outlives the contract. The incorporated FBI addendum requires deletion of criminal history information only.

What to take from it

The baseline that every other LexisNexis exhibit is measured against. Seven Fails, one Partial, no Meets. Oklahoma City’s amendment and Portland’s two words are what negotiation looks like against this form. Most contributors signed it as written.