HomeMy WebLinkAboutItem 5City of Lakeville
Police Department
Memorandum
To: Mayor
City Council
City Administrator
From: Chief Jeff Long
Copy: Body Worn Camera File
Date: February 21, 2019
Subject: Body Worn Camera Project
In the 2018, the City applied for and was awarded a grant to defray costs of implementing a
body worn camera (BWC) project. Sworn and non-sworn uniformed staff will be equipped
with body worn cameras. As a part of the grant, the police department needs to include
stakeholders in the creation of policy.
Staff created a draft policy as a starting point. To create the policy, numerous sources were
used including existing policies from the City of Burnsville, City of Apple Valley, City of Chaska,
City of Minneapolis, and model policies from the International Association of Chiefs of Police,
League of Minnesota Cities and numerous others. The goal was to create a draft policy that fit
the needs of the City of Lakeville, its residents, visitors and those having contact with the
Lakeville Police Department.
To gain the most useful input from residents, the police department is utilizing relationships
with stakeholders to reach small groups and ask them to provide insight about the draft
policy. Small focus groups will aid in the communication process as the exchange of
information will occur in a safe, nonconfrontational environment. A list of stakeholders
currently sought out is attached to this memo. This list will continue to grow as we learn of
more groups and network with stakeholders.
To reach persons of color, the police department has enlisted the aid of the diversity
coordinator with ISD 194. We hope to realize the benefits of this relationship by having small
group meetings with families and individuals.
At the conclusion of the focus group sessions, the city will host an informational meeting
regarding BWCs. The purpose of this meeting is to demonstrate equipment and answer any
new questions and inform those that we have not reached.
A public hearing is required at a regularly scheduled City Council meeting. At the conclusion
of this hearing, the draft policy will be adopted.
The entire schedule is attached to this memo.
Body Worn Camera Timeline
January 2019 - July 2019 Body Worn Camera Policy Development
January 2019 - July 2019 Continued Equipment Examination
February 2019 - Adoption Identify Community Stakeholders and Seek Input
June 2019 Public Info Meeting - Educate and Share Stakeholder Findings
July 2019 Prepare Final Version Policy and Present to City Council for Approval
July 2019 Public Hearing as Required by Statute
August 2019 Contract Approved by Council with Selected Vendor
September 2019 Product Delivery and Installation
October 2019 Training
November 2019 Full Deployment
January 2020 Begin Measuring Achievement of Grant Goals
Focus Groups and Public Outreach
TBD Hosanna!
TBD Kingdom Hall
TBD Church of Jesus Christ Latter Day Saints
TBD School Board Work Session
Pending Chamber Newsletter
TBD Public Hearing
June Public Information Meeting
February 28 Council Work Session
February 12 Chamber of Commerce Ambassador Group
February 15 ISD 194 Diversity Groups Leader
February 15 City Website
February 15 Police Department Website
February 17 Bereann Baptist
February 17 All Saints
February 19 ISD 194 Superintendent
February 19 Public Safety Committee
February 22 ISD 194 ALL Diversity Groups
February 24 St. Johns
February 24 Crossroads
March 7 Rotary
March 9 City Wide Expo
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314 MOBILE VIDEO AND PORTABLE AUDIO/VIDEO RECORDING
Lakeville Police Department Order #314
General Order- Mobile Video and PORTABLE AUDIO/VIDEO Recording
Date: ??/2019 Personnel: All Issued by: Chief of Police
314.1 PURPOSE AND SCOPE
This policy provides guidelines for the use of Mobile Video Recorders and
portable audio/video recording devices by law enforcement operators of this
department while in the performance of their duties. Mobile Video Recorders
include all recording systems affixed to department vehicles. Portable
audio/video recording devices include all recording systems whether body-worn,
handheld or integrated into portable equipment including telephones.
This policy does not apply to audio/video recordings, interviews or interrogations
conducted at any Lakeville Police Department facility, undercover operations,
crime scene documentation video, wiretaps or eavesdropping (concealed
listening devices) unless captured by a portable recording system.
314.1.1 DEFINITIONS
Definitions related to this policy include:
Mobile Video Recorder (MVR) - An in-car device that is capable of both audio
and video recording of law enforcement operator activities, but camera
equipment is affixed to the vehicle.
Portable Recording System - A device worn by a law enforcement operator of
this department that is capable of both video and audio recording of the law
enforcement operator’s activities and interactions with others or collecting digital
multimedia evidence as part of an investigation and as provided in Minn. Stat. §
13.825.
Law Enforcement Operator (LEO) – Primarily a licensed peace officer but may
also be a non-licensed representative such as a Community Service Officer
(CSO) or others who are trained, authorized and assigned to operate Mobile
Video Recorders (MVRs) and/or Portable recording system equipment.
314.2 POLICY
The Lakeville Police Department may provide LEOs with access to portable
recorders for use during the performance of their duties. Vehicles may be
equipped with MVR. The use of recorders is intended to enhance the mission
of the Department by accurately capturing contacts between LEOs of the
Department and the public.
314.2.1 MOBILE VIDEO RECORDER OBJECTIVES
The Lakeville Police Department has adopted the use of in-car MVR and
portable audio/video recorders to accomplish the following objectives:
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A) To enhance LEO safety.
B) To document statements and events during the course of an incident.
C) To enhance the LEO's ability to document and review statements and
actions for both internal reporting requirements and for courtroom
preparation/presentation.
D) To preserve audio and visual information for use in current and future
investigations.
E) To provide a tool for self-critique and field evaluation during LEO training.
F) To enhance the public trust by preserving factual representations of LEO-
citizen interactions in the form of audio-video recordings.
G) To assist with the defense of civil actions against law enforcement LEOs and
the City of Lakeville.
H) To assist with the training and evaluation of LEOs.
I) To promote and enhance safe vehicle operation
314.3 LEO RESPONSIBILITIES
Prior to going into service, each LEO will be responsible for making sure that
he/she is equipped with a portable recorder issued by the Department, and that
the recorder is in good working order. If the recorder is not in working order or
the LEO becomes aware of a malfunction at any time, the LEO shall promptly
report the failure to his/her supervisor and obtain a functioning device as soon as
reasonably practicable. LEOs shall document the malfunction report in writing by
emailing the IT HelpDesk and copying their supervisor.
Uniformed LEOs should wear the portable recorder in a conspicuous manner.
Officers have no affirmative duty to inform people that a portable recording
system is being operated or that they are being recorded. (Minn. Stat. §
626.8473). Officers may elect to notify people they encounter that a portable
recording system is being operated if it is felt that doing so may de-escalate an
encounter.
Any LEO assigned to a non-uniformed position may carry an approved portable
recorder at any time the LEO believes that such a device may be useful. Unless
conducting a lawful recording in an authorized undercover capacity, non-
uniformed LEOs should wear the recorder in a conspicuous manner.
When using a MVR and/or portable recorder, the assigned LEO shall record
his/her name, employee number and the current date and time at the beginning
and the end of the shift or other period of use, regardless of whether any activity
was recorded. This procedure is not required when the recording device and
related software captures the user’s unique identification and the date and time
of each recording.
LEOs should document the existence of a recording in any report or other official
record of the contact, including any instance where the recorder malfunctioned or
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the LEO deactivated the recording (Minn. Stat. § 626.8473). LEOs should
include the reason for deactivation.
MVR
LEOs should test MVR systems at shift start. A test recording should be created.
LEOs may operate squads with non-functioning MVR systems if no other squad
is reasonably available. If a MVR fails during the course of a shift, the LEO may
continue to use that vehicle until the end of the shift.
If the recorder is not in working order or the LEO becomes aware of a
malfunction at any time, the LEO shall promptly report the failure to his/her
supervisor. LEOs shall document the malfunction report in writing by emailing
the IT HelpDesk and copying their supervisor.
314.3.1 PORTABLE AUDIO RECORDING SPARE DEVICES
When using a spare device, or one that is not assigned to the LEO, it is the
LEO's responsibility to notify the watch commander of the reason they are
unable to use their issued equipment. In addition, it is the LEO's responsibility to
notify Administrative Services to ensure the evidence that was recorded on that
device can be reassigned to the recording LEO in video storage system.
314.4 SUPERVISOR RESPONSIBILITIES
Supervisors shall ensure LEOs are using their MVR and portable audio/video
recorders per policy. Supervisors should determine corrective action for non-
functioning portable audio/video recorders.
When an incident arises that requires the immediate retrieval of the recorded
media (e.g., serious crime scenes, peace officer-involved shootings, department-
involved collisions), a supervisor shall ensure that the portable audio/video
recorders are properly uploaded.
314.6 USE AND DOCUMENTATION
The Chief of Police or the authorized designee should designate related
responsibilities (Minn. Stat. § 626.8473; Minn. Stat. § 13.825):
A) The Police Records Analyst should coordinate the use and access.
1) Establishing procedures for the security, storage and maintenance of data
and recordings.
2) Establishing procedures for accessing data and recordings.
3) Establishing procedures for logging or auditing access.
4) Establishing procedures for transferring, downloading, tagging or marking
events.
B) The Police Records Analyst will ensure the department maintains the
following records and documents relating to portable recording systems,
which are classified as public data:
1) Total number of devices owned or maintained by the Lakeville Police
Department.
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2) Daily record of the total number deployed and used by LEOs and, if
applicable, the precinct or district in which the devices were used.
3) Total amount of recorded audio and video data collected by the devices
and maintained by the Lakeville Police Department.
4) This policy, together with the Records Retention Schedule.
C) The Police Records Analyst is responsible for obtaining and preparing for
independent biennial audits required by Minn. Stat. § 13.825, Subd. 9.
D) The Police Records Analyst will notify the Bureau of Criminal Apprehension
(BCA) within ten days when new equipment is obtained by the Lakeville
Police Department that expands the type or scope of surveillance
capabilities of the department’s portable recorders beyond video or audio
recording.
E) Administrative Services, typically the Police Records Technicians, should
coordinate the release of protected information to ensure that procedures
comply with requirements of the Minnesota Government Data Practices Act
(MGDPA) and other applicable laws (Minn. Stat. § 13.01 et seq.) It is
important to recognize data practices are very different for mobile video
recordings versus portable audio/video recordings. Portable audio/video
recordings are presumptively private.
314.7 ACTIVATION OF THE AUDIO/VIDEO RECORDER
This policy is not intended to describe every possible situation in which the
recorder should be used, although there are many situations where its use is
appropriate. LEOs should activate the recorder any time the LEO believes it
would be appropriate or valuable to record an incident.
The recorder should be activated in any of the following situations:
A) All enforcement and investigative contacts including stops and field interview
(FI) situations
B) Traffic stops including, but not limited to, traffic violations, stranded motorist
assistance and all crime interdiction stops
C) Self-initiated activity in which a LEO would normally notify Dakota
Communications Center
D) Any other contact that becomes adversarial after the initial contact in a
situation that would not otherwise require recording
LEOs should remain sensitive to the dignity of all individuals being recorded and
exercise sound discretion to respect privacy by discontinuing recording whenever
it reasonably appears to the LEO that such privacy may outweigh any legitimate
law enforcement interest in recording.
Requests by members of the public to stop recording should be considered using
this same criterion. Recording should resume when privacy is no longer at issue
unless the circumstances no longer fit the criteria for recording.
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At no time is a LEO expected to jeopardize his/her safety in order to activate a
portable recorder or change the recording media. However, the recorder should
be activated in situations described above as soon as reasonably practicable.
314.7.1 CESSATION OF RECORDING
Once activated, the portable recorder should usually remain on continuously until
the LEO reasonably believes that his/her direct participation in the incident is
complete or the situation no longer fits the criteria for activation.
Recording may be temporarily ceased or the audio muted to exchange
information with other officers, legal counsel, or the lens obstructed in order to
avoid capturing images of undercover officers, informants, or citizens where
based on training and experience, in the judgement of the officer a recording
would not be appropriate or consistent with this policy. The reason to cease and
resume recording (or to mute audio or obstruct the lens) will be noted by the
officer either verbally on the portable audio/video recorder or in a written report.
Recording may be stopped during significant periods of inactivity such as report
writing or other breaks from direct participation in the incident.
Formal statements recorded on portable audio/video recorders shall be recorded
as separate recordings.
Recordings shall be categorized, titled and identified in accordance with
established policies and procedures.
SEE CRITICAL INCIDENT POLICY FOR CESSATION OF RECORDINGS
POST INCIDENT
314.7.2 WHEN ACTIVATION IS NOT REQUIRED
Activation of the portable audio/video recorder system is not required:
A) During encounters with undercover officers or informants.
B) When a LEO is on break or is otherwise engaged in personal activities.
C) In any location where individuals have a reasonable expectation of privacy,
such as a restroom, locker room or break room.
D) When not in service or actively on patrol.
314.7.3 SURREPTITIOUS RECORDINGS
Minnesota law permits an individual to surreptitiously record any conversation in
which one party to the conversation has given his/her permission (Minn. Stat. §
626A.02).
LEOs of the Department may surreptitiously record any conversation during the
course of a criminal investigation in which the LEO reasonably believes that such
a recording will be lawful and beneficial to the investigation.
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LEOs shall not surreptitiously record another department member using any
device without a court order unless lawfully authorized by the Chief of Police or
the authorized designee.
314.8 REVIEW OF RECORDED MEDIA FILES
When preparing written reports, LEOs are permitted to review their recordings as
a resource (See the Critical Incident policy for Officer-Involved Vehicle Crashes,
Shootings and Deaths Policy for guidance in those cases). However, LEOs shall
not retain personal copies of recordings, in any format. LEOs should not use the
fact that a recording was made as a reason to write a less detailed report.
Supervisors are authorized to review relevant recordings any time they are
investigating alleged misconduct or reports of meritorious conduct or whenever
such recordings would be beneficial in reviewing the LEO’s performance.
Recorded files may also be reviewed:
A) Upon approval by a supervisor, by any LEO of the Department who is
participating in an official investigation, such as a personnel complaint,
administrative investigation or criminal investigation.
B) Pursuant to lawful process or by court personnel who are otherwise
authorized to review evidence in a related case.
C) In compliance with the Minnesota Data Practices Act request, if permitted or
required by the Act, including pursuant to Minn. Stat. § 13.82, Subd. 15,
officers may display portions of recordings to witnesses or others as
necessary for purposes of investigation, to aid in the law enforcement
process, promote public safety, or dispel widespread rumor or unrest.
Officers should generally limit, when possible, these displays in order to
protect against the incidental disclosure of individuals whose identities are
not public. Protecting against incidental disclosure could involve, for
instance, showing only a portion of the video, showing only screen shots,
muting the audio, or playing the audio but not displaying video.
D) All recordings should be reviewed by Administrative Services prior to public
or private release, typically by the Police Records Technicians. It is important
to recognize data practices are very different for mobile video recordings
versus portable audio/video recordings. Portable audio/video recordings are
presumptively private. Additionally, recordings that are clearly offensive to
common sensibilities should not be publicly released unless disclosure is
required by law or order of the court (Minn. Stat. § 13.82, Subd. 7).
314.9 RECORDING MEDIA STORAGE AND INTEGRITY
At the end of their shift, LEOs are responsible for transferring or assuring the
proper transfer of their data from their personal audio/video recording devices.
The portable audio/video recorder battery should also be fully recharged. Refer
to the SUPERVISOR RESPONSIBILITIES portion of this policy when an incident
arises that requires the immediate retrieval of the recorded media.
314.9.1 COPIES OF RECORDING MEDIA
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Evidentiary copies of digital recordings will be accessed and copied from the
video storage system for official law enforcement purposes only. Access rights
may be given to the Dakota County Attorney, the Lakeville City Attorney, or other
prosecutorial agencies associated with any future prosecution arising from an
incident in which digital recordings exist. LEOs shall ensure relevant recordings
are preserved. LEOs or Administrative Services may prevent automatic deletion
by changing the category of the media at any time prior to deletion.
314.10 SYSTEM OPERATIONAL STANDARDS
A) Portable audio/video recorder and MVR systems use should be based on
LEO safety requirements and device manufacturer recommendations.
B) The portable audio/video/MVR recorder systems should be configured to
minimally buffer for 30 seconds prior to activation. The audio may or may
not be buffered depending on manufacturer specifications.
C) For each digital recording, LEOs shall select the proper category. LEOs shall
enter the 8-digit case file number, if there is not a case file number, the LEO
shall enter the full CAD record or full citation number, and descriptive title.
The title should clearly describe the nature of the recording. For example:
1) Use of Force
2) DWI
3) Pursuit
4) Booking
5) Transport
6) IC Jane Doe (implied consent)
7) Suspect John Doe (suspect statement)
8) Victim Jane Doe (victim statement)
9) Witness Jane Doe (witness statement)
10) Test
11) Training
12) Impound
D) LEOs shall not attempt to delete, alter, reuse, modify or tamper with MVR or
portable audio/video recorder systems or recordings.
314.11 DATA CLASSIFICATION OF MVR/PORTABLE RECORDER DATA
Nothing in this policy shall be interpreted as changing the underlying
classification of data collected by portable audio/video recorder systems. The
classification of data collected by portable audio/video recorder systems will
need to be determined on a case-by-case basis upon application and
interpretation of the MGDPA and other laws, refer to especially, Minn. Stat 13.82,
13.825, other MGDPA statutes, and related laws.
314.12 PROHIBITED USE OF MVR AND AUDIO/VIDEO RECORDERS
LEOs are prohibited from using department-issued portable recorders and
recording media for personal use and are prohibited from making personal
copies of recordings created while on-duty or while acting in their official
capacity.
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LEOs are also prohibited from retaining recordings of activities or information
obtained while on-duty, whether the recording was created with department-
issued or personally owned recorders. LEOs shall not, view, duplicate or
distribute such recordings, except for authorized legitimate department business
purposes. All such recordings shall be retained at the Department.
LEOs are prohibited from using personally owned recording devices while on-
duty without the express consent of the Watch Commander. Any LEO who uses
a personally owned recorder for department-related activities shall comply with
the provisions of this policy, including retention and release requirements and
should notify the on-duty supervisor of such use as soon as reasonably
practicable.
Recordings shall not be used internally or externally by any LEO for the purpose
of embarrassment, harassment or ridicule.
314.13 RETENTION OF RECORDINGS
All recordings shall be retained for a period consistent with the requirements of
the organization’s records retention schedule but in no event for a period less
than 90 days.
Audio/Video recordings shall be retained according to the General Records
Retention Schedule for Minnesota Cities at a minimum or as required by the
rules of evidence, unless a specific request is made to store them for a longer
period of time by an authorized person. (The stated retention in the General
Records Retention Schedule does not include the year the record originates.
For example:
If a Use of Force incident was recorded in 2014, it has a retention of 7 years, the
disposable date for the 2014 record is January 2022.) When a particular
recording is subject to multiple retention periods, it shall be maintained for the
longest applicable period.
Upon written request by a data subject, the agency shall retain a recording
pertaining to that subject for an additional time period requested by the subject of
up to 180 days. The agency will notify the requestor at the time of the request
that the data will then be destroyed unless a new written request is received.
314.13.1 RELEASE OF AUDIO/VIDEO RECORDINGS
Requests for the release of audio/video recordings shall be processed by
Administrative Services, typically the Police Records Technicians, in accordance
with the MGDPA, related statutes and this policy.
314.13.2 ACCESS TO RECORDINGS
Except as provided by Minn. Stat. § 13.825, Subd. 2, portable recording system
audio/video recordings are considered private or nonpublic data. Any person
captured in a recording may have access to the recording. If the individual
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requests a copy of the recording and does not have the consent of other non-law
enforcement individuals captured on the recording, the identity of those
individuals must be blurred or audio distorted sufficiently to render the subject
unidentifiable prior to release. The identity of on-duty peace officers may not be
obscured unless their identity is protected under Minn. Stat. § 13.82, Subd. 17.
314.14 ACCOUNTABILITY
Any LEO who accesses or releases recordings without authorization may be
subject to discipline (see related policies) (Minn. Stat. § 626.8473).
314.15 SANCTIONS FOR MISUSE OF RECORDED MEDIA
Any LEO misusing recorded media for other than official law enforcement
purposes will be subject to disciplinary action.
314.16 TRAINING
Users of the MVR and portable recording systems and supervisors shall
successfully complete an approved course of instruction prior to being deployed.
This training shall be documented by the Training Lieutenant or designee.