Follow-Up on the Chicago Police Department’s “Gang Database”

In April 2019, the City of Chicago Office of Inspector General (OIG) published a report on the Chicago Police Department’s (CPD) so-called “gang database.” OIG reported that CPD captured, reported, and visualized gang data and gang affiliation designations in at least 18 different forms, records, and systems of records. OIG found that CPD’s Gang Arrest Cards, one of the Department’s largest repositories of gang information, evidenced wide-reaching data quality concerns. OIG also found in 2019 that CPD:

• had no mechanism for informing individuals that they had been designated as a gang member;
• did not have processes for individuals to contest or appeal gang designations;
• did not have processes to regularly review or purge outdated or faulty designations; and
• had no internal mechanism to amend inaccurate gang information.

OIG’s analysis of Gang Arrest Card data found that Black or African American and Latinx persons comprised 95% of the 134,242 individuals designated as gang members during arrest, were designated at both younger and older ages, and were issued more Gang Arrest Cards per person than White gang designees.

OIG issued 27 recommendations to CPD in its original report; CPD agreed to fully implement most, partially implement some, and declined to implement one. At the center of CPD’s response was the proposal for a new system for storing gang information and gang affiliation designations; CPD published a new draft General Order to govern the administration of that system.

This follow-up report provides an update on the status of CPD’s collection and maintenance of gang data, as well as CPD’s progress on the commitments formally made in response to OIG’s April 2019 recommendations. Specifically, the objectives of this report were:

• To determine the current status of CPD’s planned gang intelligence database, now known in CPD’s draft General Order G10-01-03 as the “Criminal Enterprise Information System” (CEIS).
• To assess CPD’s progress toward fully articulating the strategic purpose and value of collecting and storing information on individuals presumed to be involved in gangs.
• To evaluate the extent of CPD’s community engagement in planning the launch of the CEIS and the extent of CPD’s responsiveness to community concerns.

OIG reached three new findings herein:

• CPD has made minimal progress toward an operational CEIS.
• CPD has not clearly and specifically articulated the strategic value of its proposed system for collecting gang affiliation information.
• CPD has taken some measures to adopt community feedback on its gang data collection, but its current public-facing description of the CEIS may be misleading with respect to a key policy concern.
CPD’s lack of progress toward an operational CEIS may be measured on five separate metrics: the lack of a clear timeline for completion; the absence of clear managerial responsibility for its development; confusion within CPD over the drafting status of G10-01-03; critical policy decisions remaining unresolved or underdeveloped; and CPD continuing to rely on old systems and sources for gang data.

On the issue of the strategic value of CPD’s gang information, in April 2019, OIG cited interviews in which CPD members observed that CPD’s gang designation information often becomes inaccurate as soon as it is documented. At that time, OIG made recommendations that would have clarified the strategic purpose and value of CPD’s gang data collection efforts. Specifically, OIG recommended that CPD should add a clearly defined “purpose” section to its CEIS directive and “provide regular, formal refresher training updates to officers on the evolving nature of gangs in Chicago.” CPD agreed with both of these recommendations at the time. This follow-up report finds that, nearly two years later, CPD has not implemented these recommendations. Nor has CPD in any other way provided a clear statement of how its proposed system for collecting gang data will remain more up-to-date and accurate––and therefore, more useful for crime fighting purposes––than the prior version.

Finally, this report speaks to CPD’s community engagement efforts from April 2019 to the present and how they have influenced the development of the CEIS. OIG finds that CPD’s most significant community engagement effort took place immediately after the release of OIG’s April 2019 report, when CPD held a public comment period on draft General Order G10-01-03 and received 421 public comments. CPD incorporated some of these comments into the two subsequent versions of the draft directive and conducted some in-person community meetings, although further scheduled meetings were derailed by the onset of the COVID-19 pandemic. The most significant failing of CPD’s public engagement on the topic of the CEIS is that CPD has left an outdated version of draft General Order G10-01-03 (from February 2020) publicly posted on its website and has failed to provide the successor draft (updated July 2020) to the public. The more recent draft significantly broadens the circumstances under which district law enforcement officers may enter an individual’s information into the CEIS by eliminating the restriction that district law enforcement may only make an entry during the completion of an Automated Arrest Report. The prospect of individuals being identified as gang members without having committed any criminal offense was a concern for multiple community members who provided public comments. Therefore, the retention of the February 2020 version of draft General Order G10-01-03 on CPD’s website, and the failure to post the July 2020 version, may mislead the public with respect to a key policy concern.

In sum, OIG concludes that CPD has fallen critically short of meeting the commitments it made in response to OIG’s April 2019 findings and recommendations.