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POAC recommends City implement revised VPD records policy to avoid watermarks that hinder data use
Summary
The Police Oversight and Accountability Commission unanimously recommended adoption of a revised Vallejo Police Department records-management policy (803.7) after staff and counsel said adding watermarks to electronic public records could conflict with the California Public Records Act and impede requesters’ ability to analyze data.
The Police Oversight and Accountability Commission unanimously recommended that the Vallejo Police Department implement proposed revisions to records-management policy 803.7, after staff explained the change was intended to avoid adding watermarks that can interfere with how requesters use electronic records.
Deputy Chief Bob Knight, the department’s liaison, told the commission the revision was made quickly under a special order (No. 26-01, issued 03/05/2026) and that the packet includes a track-changes version of the policy. "If that watermark... could affect the requester's ability to put it into software or to do any type of other data analysis to it," Knight said, the city risks impairing a requester’s use of public records.
A staff member and counsel explained that the California Public Records Act entitles requesters to receive documents "in the exact same format in which the city stores it" and that adding a watermark to an electronic document stored without one can therefore raise legal issues. Commissioners also asked that related language elsewhere in the records chapter be reviewed separately (for example, the vice chair requested that language in policy 803.5 about "frivolous" requests be reworked in a different resolution addressing that specific section).
After questions and brief discussion, Commissioner Yen moved to adopt the resolution recommending implementation of the revised 803.7 as presented; the motion was seconded and passed by all members present.
Why it matters: the commission is required by ordinance to review proposed VPD policy changes within a specified period. The change responds to a practical concern — that adding a stamp or watermark to an electronic release could degrade downstream use of records for research or civic oversight — and the commission’s recommendation will go to the chief of police for final action.
