Flock Now Requires Self-Audits, Recommends Deleting Footage Sooner.

What Can a City Actually Demand of the System It Bought?

A contract binds the parties who sign it. A default binds everyone who does not act, which is the larger set, because consent to a default cannot be told apart from inattention. Where the party supplying the rule is also the party the rule governs, the question is not whether the rule is reasonable but whether anyone else was positioned to write one.

Public Administration. Canceling is the lever cities are told they hold, and the counts of how often it has been pulled do not agree. The advocacy tracker DeFlock reports 56 canceled contracts this year. FindingFlock, the only tracker that publishes a verification rule, documents 14. Flock's chief executive says 60 or 70. They are not counting the same act. Across seven Virginia localities the decisions took five legally different forms, and only three were terminations: Charlottesville and Floyd declined to renew, and Warrenton rejected a proposal it had never adopted. Charlottesville had taken its cameras free, on a 3-2 vote, and had already set seven days locally.

Strategy & Operations. The phrase termination for convenience does not appear in Flock's terms. Section 7.2 provides for exit on an uncured material default or a violation of law, and section 11.12 conditions the customer's obligations on appropriated funds. Purchasing moves through cooperative vehicles including OMNIA Partners, which lets a city buy without running its own procurement. Reading the same document, the ACLU found expanded protections against liability for willful misconduct or gross negligence, harder termination, and mandatory private arbitration under Georgia law, so a Virginia city's dispute with its surveillance vendor is resolved privately under the law of the vendor's home state.

Councils are often not voting on the cameras at all. Fairfax County's board approved a $136,270 federal grant in 2023. Alexandria's disclosure followed a request from the mayor to the police chief and the city manager rather than a vote. The lever is also shorter than the numbers suggest: the company's client base runs past 12,000, of which roughly 5,000 are law enforcement agencies, the rest businesses and homeowners' associations. A council vote reaches its own contract, not the network.

Who Audits a System Whose Auditor Ships With It?

An oversight mechanism reports what it was built to look for. Where a control keys on variation in a required field, uniform entries pass by construction rather than by accident, and the clean record that results is evidence about the instrument rather than about the conduct. Silence from a monitor is informative only where the thing monitored would have registered.

Cybersecurity & Privacy. Alexandria publishes what its cameras share, and as of August 28 the page lists 157 organizations with access, 61 cameras, 21-day retention and 409 search sessions in the preceding 30 days. Every organization on it is a Virginia entity, with no federal agency among them, and the listed prohibited uses begin with immigration enforcement. Two things complicate the disclosure. It is served from transparency.flocksafety.com and footed "Provided by Flock Safety," so the transparency instrument is a product supplied by the party being disclosed. Its counters also roll: the same page read 161 organizations and 479 searches 10 days earlier, which means the past cannot be audited from it.

The city also has a policy of its own, on its own domain. Directive 10.40, effective October 2025, requires an internal audit of the database every 30 days, a rule Alexandria imposed roughly ten months before the vendor made auditing compulsory. It also settles what the portal cannot. The directive provides that LPR system and audit trail data "shall not be subject to disclosure under the Freedom of Information Act." The record of who searched is kept, and it is exempt. The same directive turns the retention exception into a duty rather than a possibility, requiring operators to move files into the evidence system "before the automatic purge of the database." The city's own instrument never names the vendor whose system it governs.

Risk & Compliance. What the vendor made compulsory on August 13 is the machinery that watches its customers' officers: Audit Assistance for every law enforcement customer by year end, a case code on every search, a proactive lockout that suspends access when activity looks anomalous, and multi-factor authentication, which had not been required before this month. The control has already been tested and did not hold. A Milwaukee officer is charged with running one plate 124 times and another 55 times over three months, entering "investigation" as his reason each time. The published rule looks for a plate searched under varying case codes, so a repeated identical entry does not trip it. He was identified by haveibeenflocked.com, a hobbyist site built from public records, when someone searched their own plate.

The distribution of authority is worth stating precisely: the vendor detects and the agency's own administrator decides. Savannah is the counter-case, having fired six employees in August with the tooling helping to detect the misuse. Fairfax County shows what the alternative looks like. On the county's own domain rather than the vendor's, it reports 21-day retention "in accordance with Virginia law and department policy," 100% of searches reviewed by a human audit team, and the commander of its Real Time Crime Center barred from searching the system he runs. The vendor's default governs where administrative capacity is absent. Where a county has an audit team, the default is a floor it cleared long ago.