To the Santa Clara Police Department, Discovery Section/ California Public Records Act Unit:
This is a request for information pursuant to California’s Public Records Act, California Government Code §§ 6250-6276.48, on behalf of the University of California, Irvine, School of Law Immigrant Rights Clinic, for records relating to the Santa Clara Police Department’s relationship with Clearview AI. We ask that you please direct this request to all appropriate offices and units with the Santa Clara Police Department that may be in possession of any of the information sought through this request.
SPECIFIC RECORDS REQUESTED
- ALL CONTRACTS, LICENSING AGREEMENTS, AND NONDISCLOSURE AGREEMENTS BETWEEN SANTA CLARA POLICE DEPARTMENT (“THE DEPARTMENT”) AND CLEARVIEW AI.
- COMMUNICATIONS: RECORDS RELATED TO MEETINGS OR FOLLOW-UP ACTIONS BETWEEN THE DEPARTMENT AND CLEARVIEW AI REGARDING LAW ENFORCEMENT, INTELLIGENCE, IMMIGRATION, OR OTHER USE OF CLEARVIEW AI PRODUCTS.
- SALES RECORDS: CLEARVIEW AI PURCHASE ORDERS, INVOICES, AND OTHER MEMORANDA AND DOCUMENTATION.
- MARKETING RECORDS: ALL MARKETING MATERIALS – UNSOLICITED, REQUESTED, OR OTHERWISE – ACQUIRED FROM CLEARVIEW AI.
- POLICY RECORDS: ANY POLICY DIRECTIVES, GUIDANCE DOCUMENTS, MEMORANDA, TRAINING MATERIALS, OR SIMILAR RECORDS GOVERNING THE DEPARTMENT’S USE OF CLEARVIEW AI TECHNOLOGY FOR LAW ENFORCEMENT, INTELLIGENCE, IMMIGRATION, OR OTHER PURPOSES, INCLUDING ANY MEMORANDA OF UNDERSTANDING BETWEEN THE DEPARTMENT AND CLEARVIEW AI TO SHARE DATA, ACCESS REMOTE SYSTEMS OR OTHER FORMS OF INFORMATION SHARING WITH EXTERNAL AGENCIES.
- TRAINING RECORDS: TRAINING MATERIAL GOVERNING THE USE, SHARING, OR ACCESS TO ANY DATA RELATED TO OR COLLECTED BY CLEARVIEW AI, INCLUDING THE LEGAL STANDARD THAT IS REQUIRED BEFORE USING THE TECHNOLOGY, INCLUDING DOCUMENTS, SHOULD THEY EXIST, ABOUT TRAINING FOR BIAS IN THE USE OF FACIAL RECOGNITION TECHNOLOGY.
- USE AND FUNCTION RECORDS: MATERIALS THAT DESCRIBE THE FUNCTION OF THE CLEARVIEW AI FACIAL RECOGNITION TECHNOLOGY IN USE OR UNDER CONSIDERATION BY THE DEPARTMENT, INCLUDING EMAILS, HANDOUTS, POWERPOINT PRESENTATIONS, ADVERTISEMENTS, OR SPECIFICATION DOCUMENTS.
- VALIDATION AND ACCURACY: RECORDS, REPORTS, AUDITS, AND OTHER DOCUMENTS SUFFICIENT TO DESCRIBE VALIDATION, ACCURACY, RELIABILITY, AND POLICY COMPLIANCE OF THE CLEARVIEW AI FACIAL RECOGNITION TECHNOLOGY.
- THE NUMBER OF SEARCHES RUN TO DATE BY THE DEPARTMENT ON THE CLEARVIEW FACIAL RECOGNITION TECHNOLOGY.
FEE WAIVER AND PROCESSING OF THE REQUEST
We request a waiver of all fees because disclosure of this information will likely contribute significantly to public understanding of Santa Clara Police Department’s relationship with Clearview AI and our Clinic will use this information to inform our public education and advocacy efforts. Furthermore, the Clinic has no commercial interest in this matter, and plans to make any information received as a result of this request available to the public, at no cost. Disclosure in this case therefore meets the statutory criteria, and a fee waiver would fulfill legislative intent. If you are not able to waive the applicable fees, please inform us immediately of any payment required prior to copying.
If this request is denied in whole or in part, we ask that you explain why it was denied and describe the searches that were undertaken to locate records responsive to this request. If you determine that any information in a requested record or document is exempt from disclosure, please state which exemption applies, including a citation to the section of the Government Code that provides the exemption, and please provide an explanation for why the information or document falls under that exemption. Further, if a record or document that contains the requested information also contains information that is exempt from disclosure, please provide a redacted version of the record that still shows the non-exempt information. See Cal. Gov’t Code § 6253(a) (“A reasonably severable portion of record shall be available for inspections by any person requesting the record after deletion of the portions that are exempted by law”).
We have tried to be as specific as possible in designating public records without having access to the records themselves. If you find any of these requests to be insufficiently focused, we request that you provide the assistance required by California Government Code § 6253.1.
We request that you provide your response within 10 working days, or sooner as required by statutes see Cal. Gov’t Code § 6253(c), preferably in electronic form, to firstname.lastname@example.org or:
UCI Law Immigrant Rights Clinic
Attn: Caitlin Bellis
PO Box 5479
Irvine, CA 92616-5479
Please don’t hesitate to contact us by email or phone at (949) 824-8337 with any questions. We thank you in advance for your attention.
Caitlin Bellis, Supervising Attorney
Robyn Lin, Law Student
Immigrant Rights Clinic
 The term “records” as used herein means “public records as broadly defined by Cal. Gov. Code § 6252(e), and includes, but is not limited to, correspondence, documents, data, videotapes, audio tapes, DVDs, CDs, emails, faxes, telephone messages, text messages, logs, files, guidance, guidelines, evaluations, instructions, analyses, memoranda, agreements, notes, orders, policies, procedures, protocols, reports, rules, training manuals, other manuals, or studies.
 In enacting the Public Records Act, the California legislature declared “access to information concerning the conduct of the people’s business is a fundamental and necessary right to every person in the state.” Cal. Gov. § 6250.