Audit · Beltrami County, Minnesota · November 28, 2025
Paul Bunyan Drug Task Force audit
The one Minnesota audit that tested the live system. It found that Flock lets any user export plate data with no audit-trail entry, a flaw that applies to every agency on the platform.
6
Meets
9
Partial
0
Fails
3
Missing
of 18 practices this document could address
Rampart Audit LLC spent a day on site with the task force commander in October 2025, sampled ten hits out of 4,941, pulled the audit trail for the two-year period, ran a report for any data older than 30 days, checked the fixed-camera list against the BCA’s, and read the policy against both statutes. The task force runs 13 leased Flock cameras and held 1,225,448 reads at the time of the audit.
The finding that matters: “the Flock system currently allows any authorized user to export ALPR data and does not document such activity in its audit trail.” Rampart judged that a download is a dissemination the statute requires to be logged, could not complete its planned review of exports because no record of them exists, and recorded the gap as a finding. The commander had already opened a support ticket with Flock.
The audit also documented, in passing, that Flock makes agencies discoverable and opts them into sharing by default, that a single search can reach every sharing agency at once, and that one sampled query had no case number. It recommended keeping audit logs for 30 months so the next audit has something to read.
Primary source
Independent Auditor’s Report, Paul Bunyan Drug Taskforce, Rampart Audit LLC, filed with the Legislative Reference Library (251961)Read 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
Stage 2
Acquire
- Meets
2.2Published use policy before deployment
Policy reviewed against 13.824 and 626.8472 and appended to the public audit as Appendix A. “In our opinion, PBDTF’s ALPR policy addresses all of the mandatory elements identified in the statute.”
Stage 3
Deploy
- Partial
3.1Purpose limitation in writing
Collection sampled against the statutory list with no exceptions. The audit notes Flock’s “Vehicle Fingerprint” AI attributes are “not ‘collected’ but rather are the product of AI analysis,” which is a purpose question the statute does not answer.
- Partial
Thirteen fixed cameras; locations verified identical to the BCA list. No scope rationale for the count or placement.
- Meets
Fixed locations on the BCA list, verified. Monthly public logs retained a minimum of two years.
Stage 4
Use
- Partial
4.1Logged justification for every query
Audit trail reviewed for the period. “One of the searches we reviewed lacked a case or call for service number,” later traced to a protection-order case.
- Partial
4.2Access control and separation of duties
The auditor recommended designating two administrators to perform periodic reviews, which means one person currently holds the keys.
- Partial
The audit flags that network search lets one query reach every sharing agency and says whether that complies with the ban on a central repository “is beyond the scope of this audit.” Named, not resolved.
- Meets
4.4Misuse is reported like a near miss
A control failure was found, recorded as a finding, escalated to the vendor by support ticket, and published. This is what a near-miss report looks like.
Stage 5
Share
- Meets
5.1No sharing without a published policy
“ALPR data is shared only with agencies in Minnesota.” Requesting agencies sign an access form with case number and reason. The auditor observed the master sharing option deactivated.
- Partial
Sharing is limited and documented by form. Exports are not logged, so copies that left by download cannot be traced.
- Missing
Nothing on whether recipients delete.
Stage 6
Retain
- Meets
6.1Shortest retention that serves the stated purpose
“The report showed no retained data beyond the 30-day retention period.” The system is set to 30 days; the policy allows 60.
- Partial
Deletion verified inside the platform. Exported copies are untracked, so their deletion cannot be verified.
Stage 7
Audit
- Meets
7.1Independent audit on a schedule
On site, sampled, tested the live system, recorded a finding, filed on time. “No direct system access was granted to the auditors,” which is the one limit.
- Partial
7.2Logs available to the oversight body
The commander ran the reports at the auditor’s direction. The auditor never touched the system.
- Partial
7.3Annual public report with counts
Monthly public logs with read and hit counts, kept two years. No counts of sharing requests or misuse.
Stage 8
Retire
- Missing
What to take from it
Grade the audit, not the task force. Rampart did what the statute imagines an audit is: it looked, and it found something nobody else in Minnesota had reported. The finding is a platform defect, so every clean Flock audit filed before November 2025 was clean because nobody checked exports.