OIG Finds That CPD Has Made Minimal Progress in Developing a New Gang Intelligence System, and Has Not Clearly Articulated its Value or Been Adequately Transparent in its Development

The Office of Inspector General’s (OIG) Public Safety section has completed a follow-up to its 2019 review of the Chicago Police Department’s (CPD or the Department) “gang database.” OIG found that, while CPD’s response to the recommendations contained in the original 2019 report were centered on the creation of a new gang intelligence system, CPD has made minimal progress toward developing and operationalizing that system. CPD has not clearly articulated, as a matter of policy, the strategic value of its proposed system. While the Department has taken some measures to adopt community feedback on its collection of gang affiliation information, its public-facing information was outdated and potentially misleading on a key issue of community concern.

In 2019, OIG found that CPD captured, reported, and visualized gang data in at least 18 different forms, records, and systems. CPD’s Gang Arrest Cards––considered by the Department to be the source of its best-verified gang data––evidenced widespread data quality issues. CPD had no mechanism for informing individuals that they had been designated as gang members, did not have processes for individuals to contest or appeal a gang designation, did not have processes to regularly review or purge outdated or faulty designations, and had no internal mechanism to amend inaccurate gang information.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 2019 analysis of Gang Arrest Card data found that 95% of the 135,242 individuals designated as gang members were Black and Latinx. Individuals as young as nine and as old as seventy-five were designated as gang members. OIG’s 2019 report also highlighted the potential consequences of a gang designation in relation to an individual’s criminal justice involvement, immigration status, and employment prospects.

OIG previously made a total of 30 recommendations related to the utility, collection, maintenance, sharing, impact, and quality of CPD’s collection and use of gang information. In its 2019 response, CPD concurred with many of OIG’s recommendations and committed to the creation of a new gang intelligence system which would “address many of [OIG’s] findings and recommendations.” OIG’s follow-up, however, finds that two years later, CPD has made minimal progress toward the development of any such new system. The Department has not publicly articulated a timeline for completing its Criminal Enterprise Information System (CEIS), has not clearly assigned managerial responsibility for it, and there has been confusion among CPD’s senior ranks about the status of the policy governing the creation and use of the CEIS. Critical policy decisions about the function of the CEIS remain unresolved or underdeveloped, and CPD has continued to rely on its old gang data systems, despite having publicly acknowledged their flaws. Despite continuing to maintain that the collection of gang affiliation information is critical to its operations, CPD has not articulated how the new CEIS and the data it is structured to house might serve a specific strategic purpose.

In the aggregate, there is little evidence that the Department’s flawed generation, use of gang affiliation designations and data, and inequitable impact on segments of the community, have changed since OIG’s original report. Despite having taken measures to adopt community feedback on its collection and use of gang information, CPD failed to share that the publicly available draft of its CEIS policy had been superseded, and that it had changed its position on a key matter of public concern—specifically, the circumstances under which an individual could be designated as gang-affiliated in CPD’s records.

“OIG’s landmark 2019 report—now published two years ago—found CPD’s collection and use of gang information to be deeply flawed and poorly controlled, and to raise tremendous equity and fairness concerns. Though CPD agreed with many of our original recommendations, the Department has fallen critically short of the commitments it made in 2019 to render its policies on and systems for gang information more transparent and just,” said Deputy Inspector General for Public Safety Deborah Witzburg. “We welcome indications of recent progress, but for Chicagoans impacted by an opaque and procedurally flawed system, time is short—and two years is a very long time.”

The full report can be found online: bit.ly/GangDatabaseFollowUp

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The mission of the independent and non-partisan City of Chicago Office of Inspector General (OIG) is to promote economy, effectiveness, efficiency, and integrity by identifying corruption, waste, and mismanagement in City government. OIG is a watchdog for the taxpayers of the City and has jurisdiction to conduct investigations and audits into most aspects of City government. If you see corruption, fraud, or waste of any kind, we need to hear from you. For more information, visit our website at: igchicago.org.