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

The Public Safety section of the City of Chicago Office of Inspector General (OIG) has completed a follow-up to its Evaluation of the Chicago Police Department’s Random Reviews of Body-Worn Camera Recordings published in July 2019. Based on responses from the Chicago Police Department (CPD or the Department), OIG concludes that CPD has partially implemented corrective actions related to the evaluation findings.

The purpose of the 2019 evaluation was to determine whether CPD was in compliance with Special Order S03-14, the Department directive outlining policy and procedures for body-worn cameras (BWC). S03-14 requires watch operations lieutenants (WOL), across all watches, to review one randomly selected BWC recording “on their respective watch per tour of duty.” OIG found that CPD did not comply with this requirement; the Department failed to complete all required reviews in the time period OIG reviewed, failed to implement a standardized process to randomly select BWC recordings for review, and failed to monitor compliance with the random review requirement. Further, OIG found that the committee charged with overseeing implementation of CPD’s BWC program did not initially hold meetings as required by S03-14.

Based on the results of the 2019 evaluation, OIG recommended that CPD monitor the impact of its BWC Committee and determine any additional corrective measures to remedy continued noncompliance with BWC policies. OIG further recommended that CPD develop and implement a standardized process to randomly select recordings for review and consider revising the selection process to enable WOLs to identify incidents that should have been recorded but for which no video was recorded or uploaded. OIG also recommended that CPD take steps to ensure WOLs adhere to any implemented standardized selection process when conducting their reviews and that CPD develop an effective method for monitoring compliance with the requirements for random reviews. Lastly, OIG recommended that CPD’s BWC Committee maintain a regular meeting schedule, ensure that its meetings include a presentation of the latest available Quarterly Report on BWC program compliance, and ensure appropriate content in the Quarterly Reports. In its response to the evaluation, CPD committed to taking “structural internal steps,” such as updating the BWC policy and the training curriculum, and automating “functions to streamline the review process” to improve compliance with the random review requirement.

In December 2020, OIG inquired about corrective actions taken by CPD in response to the 2019 evaluation. CPD responded in February 2021 and in June 2021, just prior to the publication of this report, OIG asked CPD to provide further any updates. CPD provided some additional information in response to that request, including that it is preparing a revised Special Order to govern its BWC program. When it is drafted, CPD plans to submit that new directive for review to Independent Monitoring Team (IMT) monitoring compliance with the consent decree entered in Illinois v. Chicago in order to comply with certain provisions of that decree. CPD did not indicate what changes to its directive are planned.

Based on CPD’s response, OIG concludes that CPD has partially implemented corrective actions. CPD’s Audit Division has made some efforts toward improving its random review process; however, a new BWC review process and new randomization procedures have not yet been implemented. CPD reported that it piloted an application to facilitate a standard review process; only after doing so, however, did it assess and determine the application to be to be cost-prohibitive. As a result, CPD is currently working to develop an alternative. CPD has not developed policies or procedures for WOLs to identify incidents that should have been recorded but for which no video was recorded or uploaded. Finally, CPD reports that it is monitoring WOL review compliance through a monthly evaluation report, and that preservice training for new Lieutenants and District Executive Officers includes a section on the obligation to review randomly selected recordings. CPD’s BWC Committee has not maintained a regular or quarterly meeting schedule, but at the meetings that have taken place, Committee members have reviewed the most recent Quarterly Report and the Quarterly Report consistently covers the appropriate time periods.