Documents — FOIA Correspondence Record

1. ALPR/Flock Safety Usage Policy — All policies, procedures, and guidelines governing the use of the Flock Safety system by Bourbonnais Police Department personnel.
2. Flock Safety Contract and Agreements — The complete service agreement, contract, and any amendments or renewals between the Village of Bourbonnais and Flock Safety.
3. Data-Sharing Agreements and Network Participation — All agreements pertaining to data sharing with other agencies, network participation documents, and any memoranda of understanding (MOUs).
4. Data Retention Period — All documents confirming the data retention period configured within the Flock Safety system for Bourbonnais.
5. Cost and Payment Records — All invoices, payment records, and cost documentation related to the Flock Safety system.
6. Secretary of State ALPR Audit Records — Any records related to the Illinois Secretary of State's 2025 ALPR compliance audit of Bourbonnais Police Department.
7. Flock Safety Audit Logs (Metadata Only) — Audit logs showing who accessed the Flock Safety system, when, and for what purpose (officer names, search reasons, timestamps). Personal vehicle ALPR capture images and license plate data redacted as appropriate.
8. Village Board and Committee Records — All board meeting minutes, resolutions, committee records, and votes related to the adoption and authorization of the Flock Safety program.

A Bourbonnais resident was required to appear in person with photo ID to access their own personal vehicle data. Yet the same data flows freely to 1,761 agencies across the country with zero identity verification. In February 2026 alone, 3,212 unique agencies queried the Flock network for Bourbonnais data. The irony of requiring an individual to verify their identity to see their own data while thousands of unvetted agencies access it without any friction is difficult to explain to constituents.

The Village Board was presented with a limited picture of data sharing — likely framed around regional cooperation with neighboring agencies. The audit logs reveal over 5.6 million network searches in just 9 months, with partner agencies spanning 41 states. This includes federal agencies, state corrections departments, and agencies in states like Florida, Texas, Georgia, and California. The Board never authorized a national surveillance network. The data sharing scope far exceeds what was disclosed during board deliberations.

625 ILCS 5/2-130 requires a signed written affirmation from every out-of-state agency before ALPR data can be shared. The Village claims 1,276 out-of-state agencies have access to Bourbonnais data. It is highly unlikely — and should be documented — that the Village has collected signed written affirmations from all 1,276 of these agencies. The FOIA response should have addressed this statutory requirement directly.

Bourbonnais Police Department Policy 430 explicitly states that data sharing requests must be submitted in writing to the department. Yet Flock's network architecture operates on automatic, real-time sharing with all partner agencies — Bourbonnais PD plays no gatekeeping role. The department's own policy anticipated this distinction and built in safeguards. Those safeguards are being entirely bypassed by the way Flock's network sharing actually works.

The requester's vehicle was captured 78 times across 8 of 12 cameras over 28 days — averaging 2.8 photographs per day. The requester has no criminal history, no outstanding warrants, and no basis for suspicion. Yet their complete movement profile for an entire month is accessible to 1,761 agencies, searchable by individuals in different states who have no legitimate local law enforcement need. This is mass surveillance of innocent people, not targeted investigation.

The provided Policy 430 still contains placeholder language ("[department/office]") in critical sections. This is Lexipol's standard template, never customized. A policy document governing 5.6 million surveillance records per month was adopted and executed without being fully read or edited. This is a significant governance failure and raises questions about whether the Board understood what it was authorizing.

"I want to be clear: I'm not opposed to the police department using technology to solve crimes and keep the community safe. But there is a meaningful difference between a tool that helps Bourbonnais PD investigate local incidents and a system that feeds every resident's daily movements into a nationwide surveillance network searchable by thousands of agencies with zero oversight from your department. The department's own policy anticipated this distinction and built in safeguards. Those safeguards are being entirely bypassed by the way Flock's network sharing actually works. And the irony of requiring me to show up in person to see my own data — while that same data flows freely to agencies in 30+ states — is not lost on me."