Executive Summary

Automated License Plate Reader (ALPR) technology has expanded rapidly across Washington State with minimal public oversight. These camera systems — mounted on police vehicles, fixed infrastructure, and increasingly on private property — capture, store, and share the license plate, location, date, and time of every vehicle that passes within range, regardless of whether the vehicle or driver is connected to any crime.

The result is a growing network of mass vehicle surveillance that tracks the movements of millions of Washingtonians with no warrant, no reasonable suspicion, and, in many cases, no meaningful data retention limits.

For transgender people, domestic violence survivors, immigrants, reproductive healthcare patients, and anyone whose safety depends on being able to move through public space without being tracked, unregulated ALPR systems represent a serious and growing threat.

How ALPRs Work

ALPR systems use high-speed cameras and optical character recognition software to capture images of license plates. Each scan generates a record that typically includes:

These records are stored in databases — operated by law enforcement agencies, private vendors like Vigilant Solutions (now Motorola Solutions) and Flock Safety, or shared through regional networks — and can be searched retroactively to reconstruct a vehicle's movements over days, weeks, months, or even years.

A single ALPR camera can capture thousands of plates per day. Many police vehicles are equipped with multiple cameras that scan continuously while on patrol. Fixed ALPR installations at intersections, highway on-ramps, and parking structures capture plates around the clock.

The Scale of the Problem in Washington

Washington State has seen significant ALPR expansion in recent years. Law enforcement agencies across the state — from the Washington State Patrol to municipal police departments in Seattle, Tacoma, Spokane, and dozens of smaller cities — operate ALPR systems with widely varying policies on data retention, access, and sharing.

SB 6002, introduced in the 2024 legislative session, sought to establish baseline standards for ALPR use by law enforcement and private entities in Washington. The bill would have required data retention limits, prohibited the sale of ALPR data to federal immigration agencies, and established transparency requirements for agencies operating ALPR systems. The bill did not pass, leaving Washington without statewide ALPR regulation.

In the absence of state law, ALPR policies vary wildly by jurisdiction. Some agencies retain data for 30 days; others retain it for years. Some share data freely with federal agencies including Immigration and Customs Enforcement (ICE); others have adopted sanctuary policies that limit such sharing. There is no uniform standard, and no meaningful mechanism for residents to know where ALPR cameras are deployed, how long their data is retained, or who has access to it.

Why This Matters for Transgender Communities

The risks of unregulated ALPR surveillance fall disproportionately on communities that are already marginalized — including transgender people, for whom location tracking can be especially dangerous.

Healthcare access. Transgender people regularly travel to specific clinics and healthcare providers for gender-affirming care. ALPR data can reveal patterns of visits to these providers, creating a record that could be subpoenaed, hacked, or shared with hostile state or federal agencies. In a political environment where multiple states have criminalized gender-affirming care and some have attempted to pursue cross-border enforcement, the ability to track a vehicle's visits to a known transgender healthcare provider is not a hypothetical risk.

Domestic violence and stalking. Transgender people experience intimate partner violence at rates significantly higher than the general population. ALPR data — especially when accessible through private vendor systems or law enforcement officers acting outside their official capacity — can be exploited by abusers to track survivors' movements, identify shelter locations, and locate safe houses. Gender Justice League's Community Security Program has worked with hundreds of survivors who depend on the ability to move safely without being tracked.

Immigration enforcement. Many transgender asylum seekers and immigrants in Washington rely on the state's sanctuary protections. ALPR data shared with federal immigration agencies undermines those protections and puts people at risk of detention and deportation — consequences that are especially dangerous for transgender people, who face well-documented abuse in immigration detention.

Chilling effect on civic participation. When people know their movements are being recorded, they are less likely to attend protests, visit advocacy organizations, or engage in political organizing. For transgender communities already facing political targeting, mass surveillance has a measurable chilling effect on the civic participation that is essential to defending civil rights.

The Federal Dimension

The risks of unregulated ALPR use are compounded by the current federal landscape. Federal agencies — including ICE, the Department of Homeland Security, and the FBI — have contracted with private ALPR vendors to access billions of license plate records from across the country, bypassing the need for warrants or even formal requests to local law enforcement.

For Washington residents who depend on the state's privacy and sanctuary protections, the lack of state-level ALPR regulation creates a backdoor through which federal agencies can access location data that state law would otherwise protect.

What Other States Have Done

Several states and municipalities have enacted ALPR regulations that provide a model for Washington:

GJLA Policy Recommendations

Gender Justice League Action calls on the Washington State Legislature to pass comprehensive ALPR regulation that includes:

  1. Data retention limits. ALPR data should be automatically deleted after no more than 30 days unless it is associated with an active, specific criminal investigation. Bulk retention of location data on millions of people who are not suspected of any crime is incompatible with Washington's constitutional privacy protections.
  2. Prohibition on sale or sharing with federal immigration agencies. ALPR data collected in Washington should not be sold, shared, or made accessible to ICE or other federal agencies for immigration enforcement purposes. Washington's sanctuary protections are meaningless if location surveillance provides a backdoor around them.
  3. Warrant requirement for historical data access. Law enforcement should be required to obtain a warrant, based on probable cause, before accessing historical ALPR data to reconstruct the movements of any individual.
  4. Transparency and public reporting. Agencies and private entities operating ALPR systems should be required to publish annual reports detailing the number of cameras deployed, the number of plates scanned, data retention periods, data sharing agreements, and the number of times ALPR data was accessed for investigations.
  5. Restrictions on private ALPR systems. Private entities operating ALPR systems — including homeowner associations, parking operators, and private security firms — should be subject to the same data retention and sharing restrictions as public agencies.
  6. Ban on ALPR data use for tracking healthcare access. ALPR data should not be used, directly or indirectly, to identify, track, or investigate individuals based on their visits to healthcare providers — including providers of gender-affirming care, reproductive healthcare, or HIV/STI treatment.

Conclusion

Automated License Plate Readers are a powerful tool that can serve legitimate law enforcement purposes. But without strong regulation, they become a tool of mass surveillance that disproportionately harms the communities that can least afford to have their movements tracked, stored, and shared without their knowledge or consent.

Washington State has a long history of enacting strong privacy protections — from its constitutional right to privacy (Article I, Section 7) to its landmark data breach notification laws. Extending those protections to ALPR technology is both consistent with Washington's values and urgently necessary to protect the people most at risk.

Gender Justice League Action is a 501(c)(4) social welfare organization. This policy brief is provided for educational and advocacy purposes. For press inquiries: [email protected]