Police Department LEP Assessment and Plan

Most individuals in the United States read, write, speak and understand English. However, there are many individuals whose primary language is not English. Individuals who do not speak English as their primary language and who have a limited ability to read, write, speak or understand English can be Limited English Proficient (LEP). This language barrier may prevent individuals from accessing services and benefits.

There are two pieces of legislation that provide the foundation for the development of an LEP plan: Title VI of the Civil Rights Act of 1964, and Executive Order 13166. In some circumstances, failure to ensure that LEP persons can effectively participate in federally assisted programs may constitute discrimination based on national origin under Title VI. Additionally, agencies receiving funding under the Omnibus Crime Control/ Safe Streets Act are also required to take reasonable steps to ensure services are accessible to LEP individuals. In order to comply with Title VI, the Boise Police Department takes reasonable actions for competent language assistance. Executive Order 13166 clarifies requirements for LEP persons under Title VI. The Executive Order requires our agency to examine the services it provides, and develop and implement a system by which LEP persons can meaningfully access those services.

Four Factor Analysis

  1. The number, or proportion, of LEP persons eligible to be served, or likely to be encountered by a program, activity or service. The first step in determining the proper components of a Language Assistance Plan is understanding the number of LEP persons who may encounter services or programs provided by the Boise Police Department. In Boise, Spanish speakers are the primary LEP persons likely to be encountered by Boise Police Department employees. As of the 2010 Census, the total population within the City of Boise is 205,671. Per the 2007-2011 American Community Survey (ACS), the estimated population of persons age five years and older is 194,012. In Boise, Spanish is the language spoken at home by 9,035 people, or 4.7% of the population five years and older. Of the 9,035 persons who speak Spanish at home, 2,840 (or 1.5% of the population five years and older) report speaking English less than very well. In addition, 5,783 citizens (or 3% of the population five years and older) of Boise Police Department LEP Plan 4 the population report speaking other Indo-European languages, with 2,029 of them (or 1% of the population five years and older) speaking English less than very well. There is also a small percentage of the Boise population that speaks Asian and Pacific Islander languages (2.1% of the population five years and older) and American Indian and Alaskan native languages (.3% of the population five years and older). In all, it is estimated that 3.9% of the population of Boise speaks English less than very well.
    The U.S. Census Bureau and American Community Survey reports may be found in Appendix 1.
  2. The frequency with which LEP individuals come in contact with the program. The Boise Police Department assesses the frequency at which staff has, or could possibly have, contact with LEP persons. This includes examining Census data, telephone inquiries, requests for translated documents, and staff feedback. As discussed above, Census data indicate that approximately 1.5% of the citizens of Boise are Spanish-speaking LEP persons. As a law enforcement agency, it is necessary to recognize this segment of the general population. Telephone inquiries and staff feedback also indicate that Spanish-speaking LEP persons have regular contact with police services. Over the past year, 360 employees of the Boise Police Department who were surveyed have reported 87 inquiries by phone or in person to have an interpreter assist an LEP person. The Boise Police Department employs 9 Spanish-speaking employees who interact with Spanish-speaking LEP callers and contacts and 4 officers speaking one or more of the following languages: French, Chinese, Portuguese, Bosnian, Serbian, and Croatian. The Department also contracts services with citizens in the community, who speak a variety of languages.
  3. The nature and importance of the program, activity or service provided by the recipient to people’s lives. The City of Boise is home to the Idaho Migrant Council, Idaho Legal Aid Services, the Community Council of Idaho, the English Language Center, the Idaho Office on Refugees, three refugee resettlement agencies (International Rescue Committee, World Relief, and Agency for New Americans) and the College of Western Idaho-ESL training courses. Therefore, there is not a lack of social service, professional and leadership organizations within the City of Boise that focus on outreach or membership of LEP individuals.

    Boise Police Department personnel are most likely to encounter LEP individuals through police contacts in the community and at the front desk of City Hall West. The Boise Police Department has formed a partnership with the community and other public safety agencies in the area to provide quality services to protect life and resolve problems. Clear communication, no matter what language, with our citizens is critical in order for this partnership to occur. Ada County Sheriff’s dispatchers (providing dispatch services to Boise Police) and Boise Police telephone report unit staff serve as the cornerstone in this partnership. Ada County Sheriff’s Dispatch answers emergency and non-emergency calls from the public. Dispatchers send police officers on calls for service, and relay their requests to the appropriate sources. This Boise Police Department LEP Plan 5 communication interchange occurs 24 hours a day, 365 days a year. The Boise Police Department has bilingual staff throughout the agency available to provide interpretation, and also has contracts for oral and written language assistance services. Employees will only use family members, friends or bystanders to interpret in unforeseen, emergency circumstances while awaiting a qualified interpreter. If field and investigative personnel require an interpreter, the CAD system has information on available interpretation services. For Boise’s future, we are addressing three key areas: growth, accountability, and improvement of basic service delivery, with the goal of providing better service to our community in whatever language they communicate.

    In order to ensure our continuing transparency and accountability to the LEP community, the Boise Police Department provides several methods for citizens to report misconduct. The BPD’s Office of Internal Affairs (OIA) is responsible for investigating complaints alleging police misconduct. The procedures for receiving and investigating such complaints are set forth in the Boise Police Department Policy Manual, Section 12.02.00. Members of the public can file a complaint of alleged police misconduct in writing, over the telephone, over the Internet, in person at the OIA, or in person to a supervisor at City Hall West, 333 N. Mark Stall Place, Boise, Idaho 83704-0644. Complaints are acknowledged at the time they are received, either orally or in writing, depending upon how the complaint was filed. No False Information Warning is given. Upon completion of the investigation, complainants are notified either by telephone or in writing, depending upon the nature and severity of the complaint.

    In lieu of filing a complaint directly with the BPD, citizens may file a complaint with the Office of Community Ombudsman, a city office, independent from the Boise Police Department, providing civilian police oversight and complaint investigation. A complainant who is not satisfied with an OIA investigation may also contact the Officer of Community Ombudsman, headed by a civilian oversight professional appointed by the Mayor and the City Council. The Office of Community Ombudsman reviews completed OIA investigations and provides nonbinding recommendations to the OIA. The City's Human Resources Department is responsible for tracking City department EEOP and LEP programs, ensuring that LEP individuals are afforded meaningful access to all federally-assisted City programs and services in accordance with Title VI.
  4. The resources available to the recipient and costs. The Boise Police Department assessed its available resources used to provide language assistance. This included identifying bilingual staff, reviewing the existing Boise Police Department services for interpretation and translation-service providers, determining which documents should be translated, and deciding what level of staff training is needed.

    The Boise Police Department will provide specific outreach on programs to organizations supporting persons with Limited English Proficiency. The Boise Police Department will ensure that information regarding public meetings is disseminated to organizations supporting persons with Limited English Proficiency and disseminate public notices that have language assistance instructions. The Boise Police Department will meet periodically with refugee resettlement agencies and other advocacy groups for Limited English speakers to assess any changes to language needs. The Boise Police Department will provide Census Bureau “I Speak Cards” at Boise Police Department LEP Plan 6 public meetings, and utilize the telephone interpreter service Language Line Services when interpreter services are required. The Boise Police Department will also use ERS Language Services, Inc., when the services for an interpreter are needed for a meeting or hearing.

    The Boise Police Department currently subscribes to Language Line Services, a service that provides interpretation of 9-1-1 calls in 140 different languages to assist in determining a caller’s language, name, address, telephone number, and a short narrative of the situation and the help needed, as well as with suspect information, if available, to ensure an appropriate dispatch of services.

    Language Line Services is also used by the Ada County Sheriff’s Office to assist in determining a caller’s language, name, address, telephone number, and a short narrative of the situation and the help needed, as well as with suspect information, if available, to ensure an appropriate dispatch of services. The Boise Police Department, though its Community Outreach Refugee Liaison, has developed a list of contract interpreters who are available for in-person interpretation in more than thirty (30) languages. Each contract interpreter has been vetted and screened by the Refugee Liaison.

    The Boise Police Department will determine what documents to translate into languages other than English by conducting an assessment consistent with the four-factor analysis contained in the Department of Justice (DOJ) Guidance. Specifically, the Boise Police Department will analyze the number of LEP persons that would utilize the material, the frequency with which LEP individuals would come into contact with the material, the nature and importance of the material, and the resources available to translate the materials. When staff prepares a document or schedules a meeting for which the target audience is expected to include LEP individuals, documents, meeting notices, flyers and agendas will be printed in an alternative language based on the known LEP population.

    Based on the Hispanic and Latino population in the City of Boise, many of the written materials, including vital documents, are being translated into Spanish.

    In accordance with the four-factor analysis described above, the Boise Police Department developed the following plan for providing language assistance to LEP persons through: (1) interpreters contracting with BPD under the Community Outreach Division’s Refugee Liaison Officer program; (2) Language Line Services; (3) bilingual BPD employees; and (4) friends or family members of LEP individuals or third-party bystanders. BPD does not currently conduct any assessment of bilingual officers and there is no incentive for maintaining bilingual skills.

    The Boise Police Department determines what documents to translate into languages other than English by conducting an assessment consistent with the four-factor analysis contained in the Department of Justice (DOJ) Guidance. Specifically, BPD analyzes the number of LEP persons that would utilize the material, the frequency with which LEP individuals would come into contact with the material, the nature and importance of the material, and the resources available to translate the materials.

    In accordance with the four-factor analysis described above, the Boise Police Department developed the following plan for providing language assistance to LEP persons.

Department Plan

Identifying Individuals Who Need Assistance

The Boise Police Department will use the following measures to identify individual persons who may need language assistance:
• Document requests for language assistance from past field contacts, telephone calls, in person requests at the Boise Police Department officers, Language Line Service usage/billings, and usage of Boise Police contract interpreters to anticipate the possible need for assistance at upcoming meetings;
• Have the Census Bureau’s “I Speak Cards” (appended to this Plan as Appendix 2) available for officers and civilian staff to identify language needs.
• Frequently survey officers and first line civilian staff regarding any direct or indirect contact with LEP individuals.

Language Assistance Measures

There are several language assistance measures available to LEP persons, including both oral and written language services. There are also various ways in which Boise Police Department employees respond to LEP persons, whether in person, by telephone, or in writing.

Since there are so many languages spoken by such a limited population in the City of Boise, the implementation of the following assistance steps is based on the low percentage of persons speaking a language other than English and considering the available resources available to the City of Boise service area:
• Ensure that police department outreach brochures are provided in languages likely to reach LEP persons;
• Continue to meet regularly with refugee resettlement agencies to provide outreach, assess any changes or inputs;
• Survey BPD officers and civilian employees to complete/update a list of bilingual employees and contract interpreters;
• Locate Census Bureau’s “I Speak” Cards at the Boise Police Department;
• Provide the “I Speak” Cards at outreach meetings;
• When an interpreter is needed, in person or on the telephone, and the Boise Police Department staff has exhausted the above options, staff will first attempt to determine Boise Police Department LEP Plan 8 what language is required. Staff shall use the telephone interpreter service – Language Line Services – by dialing 1-888-808-9008. If an in-person interpreter is needed, the Boise Police Department shall call ERS Language Services, Inc. by dialing 208-465-4542. BPD personnel may also access the Refugee Liaison’s contract interpreter list for in-person interpretation services.

Training Staff

It is important that staff members, especially those having contact with the public, know their obligation to provide meaningful access to information and services for LEP persons. Even staff members who do not interact regularly with LEP persons should be aware of and understand the LEP plan. Training staff is a key element in the effective plan implementation.
The primary Boise Police Department groups critical to the LEP plan are front window Records Division staff, Community Service Specialists and Telephone Report Unit staff, and sworn officers of the Boise Police. These groups are most likely to encounter LEP persons, either inperson or by telephone, and thus to provide language assistance. Training topics for these groups include:
• Understanding the Title VI LEP responsibilities
• What language assistance services the Boise Police Department offers
• Specific procedures to be followed when encountering an LEP person
• How to use the “I Speak…” multi-language identification flashcards
• How to contact translation services if needed
• How to access Google Translate on public access computers
• Ensuring that Department personnel understand they can only use family members, friends, or bystanders to interpret in unforeseen, emergency circumstances while awaiting a qualified interpreter.

Providing Notice to LEP Persons

The Boise Police Department plans to utilize qualified service providers to translate official documents to ensure accuracy of those materials for identified LEP populations. For less formal documents such as flyers or other document releases to the community the Boise Police Department has implemented the recommended quality control measure of having these documents coordinated through the Title VI Coordinator’s office which will take the necessary steps to ensure that Department personnel, or a non-departmental individual that is recognized for their competency in translation services, also reviews the document prior to release.

There are several ways that Boise Police Department employees provide notice to LEP persons that language assistance measures are available, through both oral and written communications:
• The Boise Police Department provides vital documents that are in both Spanish and English, indicating that the publication is accessible to Spanish speakers (i.e. Complaint Procedures and Complaint form). Boise Police Department LEP Plan 9
• A statement on the City of Boise’s website indicating that language assistance is available.
• Notice at all public counters in English and Spanish that language assistance is available.
• The Boise Police Department also provides employees with Language Identification Flashcards which allow an LEP individual to point to the language that the individual speaks.
• The City of Boise website will provide a Spanish version of online forms.

Monitoring and Updating the LEP Plan

This plan is designed to be flexible, and should be viewed as a work in progress. As such, it is important to consider whether new documents and services need to be made accessible for LEP persons, to monitor changes in demographics and types of services, and to update the LEP plan when appropriate by the designated Title VI Coordinator. At a minimum, the Boise Police Department will review the LEP plan on an annual basis and update as needed. Additionally, the LEP plan will be updated to incorporate any recommendations provided by the Office of Civil Rights Compliance Review as needed. At a minimum, each update will examine all plan components, such as
• How many LEP persons were encountered?
• Were their needs met?
• What is the current LEP population in the City of Boise?
• Has there been a change in the types of languages where translation services are needed?
• Is there still a need for continued language assistance for previously identified Boise Police Department programs?
• Are there other programs that should be included?
• Have the Boise Police Department’s available resources, such as technology, staff, and financial costs changed?
• Has the Boise Police Department fulfilled the goals of the LEP plan?
• Were any complaints received?

The Boise Police Department project will continue past the implementation of steps necessary to bring them into compliance or the training of the personnel on the updates to the LEP plan. The Boise Police Department is incorporating long-term goals of establishing stronger ties to refugee and LEP segments of the community as well as instilling routine periodic measures for monitoring contacts with LEP individuals and for recognizing any shifts in the population of the community. In addition to maintaining the positive relationships that the Boise Police Department has with the Spanish language community and continuing to work with the various ethnic media outlets, the Boise Police Department has department personnel that reach out to local refugee communities and organizations in order to build trust with those groups.

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