I wrote to Flock's privacy contact to opt out of their domestic spying program

Legal status of Flock’s role and data “ownership”

  • Many commenters say Flock is positioning itself as a CCPA “service provider” (similar to a GDPR processor): its customers (cities, HOAs, etc.) are the “owners/controllers” of ALPR data, so deletion/opt‑out requests must go to them, not Flock.
  • Others argue this is a legal fiction: Flock owns and leases the hardware, operates the cloud platform, indexes and analyzes license plates, and facilitates cross‑agency search, so it is exercising real control and should bear privacy obligations.
  • California has a specific ALPR statute and separate data broker rules; some argue Flock qualifies as a data broker because it enables paid access to pooled PII, others say contracts and statutory definitions likely shield it.
  • Government entities often have exemptions or different regimes under CCPA‑like laws, further complicating deletion rights.

Comparisons to other services

  • Defenders analogize Flock to AWS, Google Cloud, or Sendgrid: infrastructure providers can’t practically or legally delete customer data just because a data subject asks.
  • Critics respond that Flock is unlike generic storage: it deliberately parses, indexes, and links PII (plates, time, location) and markets “nationwide search” as a feature, more like an adtech or surveillance network than S3.

Is license plate/location data “personal information”?

  • Some claim photos of a car in public aren’t clearly “personal information” or are “publicly available.”
  • Others point to CCPA language covering information that can reasonably be linked to a person/household, arguing plate+time+location clearly qualifies, similar to IP addresses, especially when aggregated into movement profiles.

Privacy, surveillance, and civil liberties concerns

  • Strong concern that Flock enables de‑facto mass location tracking and cross‑jurisdictional searches (e.g., abortion enforcement, protest tracking), approaching the effect of GPS tracking.
  • Several see Flock’s “customers own the data” framing as a way to duck both privacy laws and constitutional constraints on government surveillance.
  • Some argue current laws are toothless in practice: data subjects can’t even discover which entity to contact, AGs rarely act, and exemptions for law enforcement swallow rights.

What to do about it

  • Suggestions include: complaints to state AGs, EFF and similar groups, targeted litigation, new legislation (state ALPR bills, stronger data broker rules), and pressure on municipalities to cancel contracts.
  • A few comments advocate vandalizing cameras; others implicitly treat that as illegal and focus on legal, political, and community organizing routes instead.