Evaluation of the Chicago Police Department’s Random Reviews of Body-Worn Camera Recordings

Executive Summary

OIG’s evaluation determined that CPD has not complied with its requirement for random WOL reviews based on the following findings:

1. CPD reported not completing all required random WOL reviews. From November 2017 through March 2018, none of the three districts reporting specific numbers of random WOL reviews reported completing a random review for every tour of duty in a month, as required.
2. CPD has not implemented a standardized process for randomly selecting BWC recordings for review. CPD has also not provided WOLs with specific guidance or training on how they should select recordings to review.
3. CPD has not effectively monitored compliance with its random WOL review requirements. The Department has used definitions of compliance that are inconsistent and that do not allow CPD to determine whether WOLs are conducting randomized reviews in accordance with the Special Order.
4. CPD’s BWC Program Evaluation Committee (the Committee), which is tasked with ensuring compliance with the Department’s BWC policies and evaluating the effectiveness of the BWC program, did not initially hold quarterly meetings as required by the Special Order. Furthermore, a quarterly meeting observed by OIG did not include a presentation of the latest available BWC Program Evaluation Committee Report (Quarterly Report) prepared by the commander of the Inspections Division.

As a result, during the period assessed in this evaluation, CPD did not fully and accurately assess officer compliance with aspects of Department policy, including whether members are properly recording law-enforcement-related activities. In addition, the Committee did not ensure officer and supervisor compliance within the BWC program and thus was not able to make appropriately informed recommendations to the superintendent regarding the program.

Collectively, the issues identified by OIG have potentially limited the overall effectiveness of CPD’s BWC program, which is an important innovation in the service of performance, accountability, and transparency needed to foster trust and legitimacy with the public.

To achieve full compliance, OIG recommends that CPD,

1. assess the impact of the steps the Committee has taken to date, and plans to take, to improve compliance with requirements for completing and reporting on random WOL reviews of BWC recordings;
2. develop a standardized process for randomly selecting recordings for review;
3. take steps to ensure that WOLs adhere to this standardized process across districts and shifts; and
4. develop an effective method for monitoring compliance that accounts for all aspects of the Special Order’s requirements.

To strengthen the Committee’s oversight of the BWC program, OIG recommends that CPD,

5. maintain a regular meeting schedule for the Committee;
6. ensure that Committee meetings include a presentation of the latest available Quarterly Report prepared by the commander of the Inspections Division;
7. define which three-month period should be reviewed in Quarterly Reports; and
8. ensure that all months in the year are reviewed in Quarterly Reports.

In response to our findings and recommendations, CPD acknowledged the need to improve compliance with its random WOL review requirement. CPD identified the following steps it has taken or is planning to take to address all of OIG’s recommendations:

• Have the Office of Reform Management and Auditing Unit review the Department’s implementation of its random review policy, as required to fulfill CPD’s obligations under the Consent Decree (Recommendation 1).
• Work with its BWC service provider Axon to use the Axon Performance platform to automate several components of the random WOL review process, including the random selection of recordings, the logging of review results, the sending of notifications to WOLs to remind them to conduct reviews and to alert them to potential indicators of noncompliance, and the creation of an audit trail of reviews (Recommendations 2, 3, 4, 7, 8).
• Continue holding quarterly meetings of the Committee (Recommendation 5).
• Continue presentations of Quarterly Reports by the commander of the Inspections Division to the Committee (Recommendation 6).
• Have the commander of the Inspections Division ensure that Quarterly Reports reflect the proper three-month period (Recommendation 7).
• Have the commander of the Inspections Division work with the Committee to ensure Quarterly Reports review all months of the year (Recommendation 8).

CPD also identified the following additional measures it can take to improve compliance, which, depending on how they are implemented, may also address OIG’s recommendations:

• Incorporate the random review process into the training curriculum for new lieutenant classes (Recommendations 1, 3).
• Issue a Department-wide notice to clarify that the random review requirement applies to all assigned WOLs, including those visiting from other districts or units (Recommendation 1).
• Incorporate compliance updates on random WOL reviews into CPD’s weekly CompStat accountability model (Recommendations 1, 4).
• Impose progressive discipline, training, or other remedial action in response to noncompliance with its BWC policy (Recommendation 1).

OIG is encouraged by CPD’s expressed commitment to improve its compliance with its random WOL review requirement. However, CPD did not specify a timeline for implementing the most substantial remedial action it intends to take: the use of the Axon Performance platform to automate key aspects of the random review process. CPD identified the Axon Performance platform as providing the capacity to address five of OIG’s eight recommendations. CPD should implement this automated solution as quickly as possible and, in the interim, adopt additional measures as necessary to improve compliance.