Two weeks ago Flock Safety's CEO said the quiet part in public: some of our contractual language has confused the public on this crucial point. He promised a fix. A plain English explanation of the contract, section by section, on the website, next week.
It went up on August 21st, 2026. I read it this morning.
It is a real document and it answers real questions. It also never once uses the phrase "machine learning," and it never once uses the word "anonymized." Those are the two words that carry the paragraph I have been holding a printed copy of since the 19th.
Here is the video, then the paragraph.
The figures in this issue, as of August 27, 2026
Michigan's Flock Safety contract, number MA250000000832, runs 172 pages. |
Its estimated aggregate value is $2,626,000.00, stated on Change Notice 1, page 1. |
The phrase "machine learning" appears exactly 1 time in those 172 pages, on page 32. |
Flock Safety's legal hub at flocksafety.com/legal listed 15 documents on August 19, 2026 and lists 17 documents on August 27, 2026. |
The document added is "Data Ownership - A Plain-English Guide to Data Ownership Under the Flock Customer Terms and Conditions," last updated August 21, 2026. |
The phrase "machine learning" appears 0 times in that plain English guide. |
The word "anonymized" appears 0 times in that plain English guide. |
Superseded, do not cite: nothing in this issue supersedes a figure published in an earlier issue of this newsletter. |
What he promised
Garrett Langley, CEO of Flock Safety, on the Flock Safety blog, August 13, 2026, under the heading Data Ownership:
"From the beginning, we have been clear that our customers own the data captured by their ALPR cameras. This has always been the case, but some of our contractual language has confused the public on this crucial point. To make that commitment easier to understand, next week we will publish an easy to read / plain English explanation of our contract on our website, organized section by section. The principle is simple: customers own the data, decide who can access it, and choose who they share it with."
I want to be fair about this, because it is more than most vendors do. A company saying its paperwork confused people, and then saying it will go fix the paperwork, is a company doing something. When I built the video on the 19th, the guide was not up and the promise was four days past due. It is up now, last updated August 21, 2026. He shipped it.
So let's do what he suggested and read a section.
What the guide says
The document is called Data Ownership and it explains Section 4.1 of Flock Safety's customer Terms and Conditions. Six numbered sections. It quotes the contract directly, which I appreciate, and this is the part that matters. Flock Safety's plain English guide to data ownership, published August 21, 2026, quotes Section 4.1 of its customer Terms and Conditions as follows:
"Customer hereby grants to Flock a limited, non-exclusive, royalty-free, irrevocable, perpetual, worldwide license to (a) use and disclose Customer Data to provide the Flock Services; and (b) use Customer Data to support and improve Flock's products and services."
The guide then explains purpose (b) like this: Flock may use data in aggregate or technical ways to make the platform work better for all customers, and it gives an example. Improving read accuracy. Training the system to recognize new and special occasion license plate designs.
New license plate designs. That is the example the guide gives.
What Michigan signed is a different piece of paper
The guide explains Flock Safety's standard customer terms. The State of Michigan did not sign Flock Safety's standard customer terms. The state wrote a different contract, MA250000000832, 172 pages, and I have it because DTMB Central Procurement Services handed it over at no charge under Michigan FOIA.
Page 32 of that contract, section 21.3, tells the contractor what it may not do with state data. Michigan contract MA250000000832, section 21.3(d), page 32, reads:
"not use, sell, rent, transfer, mine, distribute, commercially exploit, or otherwise disclose or make available State Data for Contractor's own purposes"
Read that list again. Mine. Distribute. For the contractor's own purposes. Flatly prohibited.
The next paragraph on the same page is titled Anonymized Data. The Anonymized Data paragraph on page 32 of Michigan contract MA250000000832 reads:
"Contractor shall have the right to collect, analyze, and anonymize State Data to the extent such anonymization renders the data non-identifiable to create Anonymized Data to use and perform the Services and related systems and technologies, including the training of machine learning algorithms. State hereby grants Contractor a non-exclusive, worldwide, perpetual, royalty-free right to use and distribute such Anonymized Data to improve and enhance the Services and for other development, diagnostic and corrective purposes, and other Contractor offerings."
One paragraph says do not mine or distribute state data for the contractor's purposes. The paragraph immediately after it grants a perpetual, worldwide right to distribute the anonymized version, and names machine learning training as one of the uses. Both paragraphs sit on page 32 of the same contract. They print on one sheet, which is the page I am holding in the video.
That same paragraph also says "Contractor does not own and shall not sell Anonymized Data." That is true and it stays true. Nobody is selling anything here. A perpetual license to use and distribute is not a sale, and Flock Safety has never said it was.
The part I think people get wrong
I do not think anybody got tricked.
Turn to page 66. The state's requirements worksheet, where Michigan lists what the vendor must do and the vendor checks a box. Requirement 24 on page 66 of Michigan contract MA250000000832 reads:
"The prospective LPR vendor must ensure that the department owns the LPR data; therefore, the selected LPR vendor does not own and must not sell the department's LPR data."
Requirement 25, on the same page:
"The prospective LPR vendor does not own and will not sell Anonymized Data."
Flock Safety marked both requirements X under Current Capability. Its written answers in the vendor column are "Contractually, the customer owns the data" for requirement 24 and "Contractually, Flock Safety does not own, nor sell any data" for requirement 25.
Both of those answers are true. Neither requirement 24 nor requirement 25 asks whether the vendor may train machine learning models on the data. The state asked who owns it and who sells it, Flock Safety answered who owns it and who sells it, and the training language sits 34 pages earlier in the contract body, on page 32, without anybody having had to lie about anything.
That is the whole thing. The state asked the wrong question.
What I would ask Flock Safety
The plain English guide covers ownership, the license-back, sale, sharing, confidentiality and access. Six sections. It does not mention anonymized data and it does not mention machine learning, and those two words are the entire subject of the paragraph sitting under section 21.3 on page 32 of Michigan's contract.
So: is the Anonymized Data paragraph getting a plain English section too?
That is not a gotcha. He said section by section. This is a section.
What you can do with this
Your town's contract is probably not Michigan's contract and it is probably not the standard customer terms either. It is whatever your city attorney negotiated, and the only way to know what it says is to go get it.
Ask for the executed contract and every change notice or amendment. It is one email. Michigan's cost me nothing and came back in a day.
When you get yours, go to the ownership section and then read the next paragraph.
And if the work is worth something to you, there is a donate page at donate.magneticnorse.com. The records fees come out of my pocket first and get paid back second, or not at all.
Mags
The record behind this issue
State of Michigan contract MA250000000832, Flock Group Inc. d/b/a Flock Safety, License Plate Reader Solution, Change Notice 1, 172 pages. Obtained from Michigan DTMB Central Procurement Services under the Michigan Freedom of Information Act, MCL 15.231, at no charge. Clauses quoted above are at page 32 and page 66; every figure in this issue was recounted from that PDF on August 27, 2026.
Flock Safety, "Data Ownership - A Plain-English Guide to Data Ownership Under the Flock Customer Terms and Conditions," flocksafety.com/legal/data-ownership, last updated August 21, 2026, read August 27, 2026.
Garrett Langley, Flock Safety blog, August 13, 2026, flocksafety.com/blog/flock-guardrails-address-lpr-privacy-concerns-and-police-transparency, read August 19 and August 27, 2026.