345.00, Employee Information System (EIS)
Refer:
- DIR 215.00, Member Performance Evaluations
- DIR 905.00, Non-Force After Action Reporting
- DIR 1010.00, Use of Force
- Professional Standards Division Standard Operating Procedure 44, Employee Information System Alert Processing Guide
- Professional Standards Division Standard Operating Procedure 47, Force Data Analysis at the Group and Supervisor Level
- PPA Labor Agreement
Definitions:
- Alert: A threshold break notification that is assigned a case number by the Employee Information System Administrator; a Responsibility Unit (RU)-generated request to review a member’s performance and/or behavior; and/or a Force Inspector-generated request to review force trends at the RU level.
- Alert Management System (AMS): A system within EIS that serves as a repository for all case notes associated with any alert.
- Employee Information System (EIS): The EIS consists of a read-only database that collects information from external data sources, the Alert Management System, and the Performance Discussion Tracker.
- Performance Discussion Tracker (PDT): A system within EIS that allows supervisors to record conversations about member performance and/or behavior and any follow up on those conversations. Members may also submit a response within the system.
- Supervisor: A sworn Portland Police Bureau member at the rank of sergeant or above (or anyone acting in those capacities) and non-sworn personnel with oversight responsibility for other sworn members.
- Supervisory Action: A non-disciplinary process designed to give sworn members feedback on their performance and promote best practices. Supervisory actions may include coaching, commending, debriefing, monitoring, referring to the Employee Assistance Program (EAP), requiring training, temporarily re-assigning, or some other form of non- disciplinary action.
- Supervisor Review: A review of information concerning a sworn member’s performance and/or behavior.
- Threshold: Pre-programmed criteria established by the Chief of Police, including:
- Shift Force Ratio: a sworn member’s force ratio is greater than or equal to three (3) times their shift’s average ratio in the preceding six (6) months;
- Force Ratio: a sworn member’s force ratio is greater than or equal to 20% of their arrests in the preceding six (6) months;
- Force Count: a sworn member uses force three (3) or more times in the preceding thirty (30) days;
- Criminal Complaint: a member receives a complaint with an allegation of criminal misconduct;
- Complaint in Same Category: a member receives two (2) or more complaints with at least one (1) allegation in each complaint being in the same category such as two (2) complaints that both have conduct allegations) for events in the preceding six months;
- Complaint Count: a member receives three (3) or more complaints for events in the preceding six (6) months;
- Traumatic Incidents: a member experiences three (3) or more traumatic incidents in the preceding thirty (30) days;
- Commendations: a member receives two (2) or more commendations for events in the preceding six (6) months.
- Threshold Break: An automatic notification to the EIS Administrator when a member reaches or exceeds a threshold.
- Type I Alert: An alert notification that pertains to a complaint- or commendation-related threshold break.
- Type II Alert: An alert notification that pertains to a force- or traumatic incident-related threshold break.
- Type III Alert: An alert notification that pertains to statistically meaningful deviations from normative behavior, with respect to groups and their respective supervisors, which the Force Inspector has determined places such groups and the respective supervisors at risk of problematic trends.
Policy:
1. The EIS is an application that compiles information from the Police Bureau and other data sources to enable a comprehensive review of a sworn member’s work performance. The use of EIS benefits the Bureau and sworn members alike by facilitating professional growth through a feedback process that reinforces the Bureau’s management and accountability systems, standards, and expectations.
2. It is the policy of the Bureau to encourage and develop personnel. EIS supports this goal by supplying information to supervisors that will allow them to better develop, manage, and support their sworn members.
3. EIS and the information developed therein shall not form the basis for disciplinary action but may be used for non-disciplinary notice purposes, such as development of work performance plans and letters of expectation. The reports from EIS may not be used by the City for disciplinary, transfer or promotion decisions. However, if the underlying data that appears in EIS is maintained separately by the City and is simply reflected in EIS, nothing in this directive prevents the City from making appropriate use of the underlying data in disciplinary, transfer, or promotion decisions.
4. The AMS and PDT shall be treated as confidential material.
Procedure:
1. Performance Discussion Tracker:
1.1. The PDT allows supervisors to record discussions about a member’s performance and behavior. Every entry to a member’s PDT should be preceded by a discussion with the member.
1.2. Supervisors who observe positive behavior or performance related to a member’s job duties as described in the member’s personnel evaluation form (ref: Directive 215.00, Member Performance Evaluations) are encouraged to discuss the observation with the member and make an entry to the member’s PDT.
1.3. Supervisors who counsel a member or engage in other non-disciplinary corrective action, whether during normal operations; during an after action review in accordance with Directives 905.00, Non-Force After Action Reporting and 1010.00, Use of Force; or as part of another formal process such as a Supervisory Investigation, shall make an entry about the event and the corrective action undertaken in the member’s PDT.
1.4. At minimum, any entry made under Section 1.2 or 1.3 shall contain a brief synopsis of the incident, any relevant reference number (case number, CAD number, etc.), and an indication of how additional information may be obtained (e.g., contact the supervisor, review an after action, etc.).
1.5. Upon notification that a sworn member’s use of force has resulted in a finding of liability in a civil trial, the EIS Administrator shall make an entry reflecting the event in the member’s PDT. In addition, the EIS Administrator shall generate an alert and send it to the sworn member’s RU Manager for review.
1.6. EIS automatically generates an e-mail to a member when a supervisor makes an entry in their PDT.
1.7. Members may submit a response to PDT entries by writing a memorandum through their chain of command, to their RU Manager, and sending an electronic copy of the memorandum to the EIS Administrator.
1.7.1. Upon receipt, the RU Manager will forward a copy of the memorandum to the EIS Administrator, retaining the original in their file.
1.7.2. The EIS Administrator will enter the response in the sworn member’s PDT upon receipt of the copy of the memorandum described in Section 1.7.1.
2. Review of Sworn Member Data Upon Transfer:
2.1. Supervisors who have sworn members new to their command, whether due to the transfer of the supervisor or transfer of the sworn members, shall review the sworn members’ EIS record and document this review occurred in the sworn members’ PDT within thirty (30) days of the transfer.
2.1.1. This requirement applies to all temporary assignments (TDY, acting supervisor, etc.) that are in effect for more than thirty (30) continuous days, as well as a return to normal status from a temporary assignment (including all types of leave described in Directive 210.21, Leaves from Service) in effect for more than thirty (30) continuous days.
2.2. Prior to completing a sworn member’s performance evaluation conducted in accordance with Directive 215.00, Member Performance Evaluations, or Human Resources Administrative Rule 9.02, Performance Management, supervisors will review the information available in EIS, including the various external data sources, PDT, and AMS.
2.2.1. EIS contains aggregate and comparison data that may be useful in completing the evaluation and facilitating a career development conversation.
2.2.2. After concluding the review, the supervisor shall document that the review occurred in the sworn member’s PDT.
3. Performance Discussion Tracker and After Actions:
3.1. Supervisors who address a sworn member’s performance in the Recommendation and Critique Section of an After Action Report written in accordance with Directives 905.00, Non-Force After Action Reporting and 1010.00, Use of Force, shall place an entry in the sworn member’s PDT. This requirement applies to the following events/incidents:
(a) Vehicle pursuits;
(b) Force events;
(c) Complaint of improper force;
(d) Complaint of injury or physical injury;
(e) All critical firearm discharge;
(f) Injury to suspect in custody;
(g) Police vehicle collision;
(h) Damage to or loss of city property; and
(i) Destruction of animal(s).
3.1.1. This entry shall be made prior to forwarding the After Action Report to the next level of review unless the supervisor is unable to either personally make the entry or cause the entry to be made within the timelines established in Directives 905.00, Non-Force After Action Reporting and 1010.00, Use of Force. If the entry is not made prior to forwarding the After Action Report to the next level of review, the supervisor shall do the following prior to forwarding the After Action Report:
3.1.1.1. Note the inability to make the entry in the After Action Report;
3.1.1.2. E-mail either the EIS Administrator or a supervisor in the member’s RU and request the entry be made; and
3.1.1.3. Request in the After Action Report that the next level of review verify that the entry has been made in the sworn member’s PDT.
3.1.2. Supervisors who receive an After Action Report where an EIS entry has been requested but not made under the procedure described in Section 3.1.1 shall document that the entry has been made in their After Action Report comments.
3.1.3. The entry shall include, at a minimum:
3.1.3.1. The case number of the incident,
3.1.3.2. The nature of the incident and, if applicable, the type of force used,
3.1.3.3. Whether the incident was within policy,
3.1.3.4. Any positive performance, and
3.1.3.5. Any training deficiencies, policy deficiencies, or poor tactical decisions identified as well as any non-disciplinary corrective action taken to remedy them.
3.2. Pursuant to Directives 905.00, Non-Force After Action Reporting and 1010.00, Use of Force, all After Action Reports must be reviewed by the sworn member’s chain of command. A manager (lieutenant or above) who is reviewing an After Action Report prepared by a subordinate shall make an EIS entry under the following circumstances:
3.2.1. When the manager identifies a previously unidentified training deficiency, policy deficiency, or poor tactical decision made by the sworn member, the manager shall make an entry in the sworn member’s PDT in accordance with this directive, in addition to ensuring the appropriate corrective action is provided to the sworn member.
3.2.2. When the manager concludes the critique, analysis, or other commentary provided by any subordinate level of review is inadequate, inaccurate, or incomplete, the manager shall, if the matter is not referred to Internal Affairs (IA), provide the appropriate non-disciplinary corrective action and document it in the subordinate’s PDT with:
3.2.2.1. The case number of the incident,
3.2.2.2. The nature of the incident,
3.2.2.3. The nature of the deficiency, and
3.2.2.4. The non-disciplinary corrective action taken.
3.2.3. Entries made in accordance with Sections 3.2.1 and 3.2.2 may require the manager to make entries in multiple subordinates’ PDTs.
3.2.4. The manager shall make any PDT entry required by Section 3.2.1., and 3.2.2., prior to forwarding the investigation to the next level of review.
3.3. When a subordinate’s performance on an After Action investigation or review exceeds the expectations of the organization, managers and supervisors shall make an entry to the subordinate’s PDT documenting the performance.
4. Type I and Type II Alerts and Review Process.
4.1. EIS Administrator Alert and Review Process Responsibilities:
4.1.1. If a member has reached a threshold, the EIS Administrator shall generate an alert in the AMS.
4.1.1.1. Every alert is evaluated by the EIS Administrator in accordance with the Professional Standards Division’s (PSD) Standard Operating Procedure (SOP) 44 for individual sworn members and SOP 47 for groups and their respective supervisors.
4.1.1.2. If the EIS Administrator determines that the member’s supervisor should review the alert, the EIS Administrator shall send the alert to the member’s RU Manager with a request for the RU Manager to review the alert.
4.1.1.3. If the EIS Administrator does not request an RU Manager Review, the alert is sent to the PSD Lieutenant for review as outlined in Section 4.4.3.
4.1.1.4. Any decision made during this process, and the reason(s) for it, shall be documented in the “case notes” section of the alert.
4.1.2. The EIS Administrator shall review and process alerts as described in this section within thirty (30) days of EIS creating a system notification of the broken threshold. Exceptions to this requirement may be granted by the PSD Lieutenant for good cause. When the PSD Lieutenant receives a request for an exception, the request, and whether it was granted, the decision and the rationale for it, shall be documented in the “case notes” section of the alert.
4.1.2.1. When an alert that was assigned for RU Manager review, as described in Section 4.2. of this directive is returned to PSD, the EIS Administrator shall review the RU Manager’s response to the alert.
4.1.2.2. If the documentation and process requirements of this directive have been fulfilled, the EIS Administrator shall close the alert.
4.1.2.3. If the documentation and process requirements of this directive have not been fulfilled, the EIS Administrator shall return the alert to the RU Manager for correction.
4.1.2.4. Any decision made during this process, and the reason(s) for it, shall be documented in the “case notes” section of the alert.
4.1.2.5. The EIS Administrator shall review and process alerts, as described in this section, within fifteen (15) days of the alert being returned to PSD. Exceptions to this requirement may be granted by the PSD Lieutenant for good cause. Whether this request was granted, and the rationale for the decision, shall be documented in the “case notes” section of the alert.
4.2. RU Manager Process and Responsibilities:
4.2.1. Within fifteen (15) days of an alert being assigned to an RU Manager by the EIS Administrator, they shall:
4.2.1.1. Review the content of the alert and make a reasonable determination supported by the facts about whether to require a Supervisor Review as described in Section 4.3.
4.2.1.2. Document the decision made, and the reason(s) for making it, in the “case notes” section of the alert.
4.2.2. Within thirty (30) days of a Supervisor Review being returned to an RU Manager, they shall:
4.2.2.1. Determine whether the Supervisor Review is complete and notify the supervisor if additional information is required.
4.2.2.2. Review, approve, reject, and/or add Supervisory Actions as appropriate.
4.2.2.3. The RU Manager shall not recommend an alert for closure until all Supervisory Actions have been completed.
4.2.2.4. Document the actions taken and the reason(s) for the actions in the case notes section of the alert.
4.2.3. Exceptions to the timelines required by Sections 4.2.1. and 4.2.2. may be granted by the PSD Commander for good cause. Whether this request was granted, and the rationale for the decision, shall be documented in the “case notes” section of the alert.
4.3. Supervisor Review Process and Responsibilities:
4.3.1. When assigned a Supervisor Review, the supervisor will review the sworn member’s performance by doing all of the following:
4.3.1.1. Review of relevant information contained in the EIS data sources, the PDT, and the AMS;
4.3.1.2. Review of relevant reports, IA case files, after actions, and other written documentation;
4.3.1.3. Discuss the sworn member’s performance with other supervisor(s); and
4.3.1.4. Review other material as appropriate.
4.3.2. At the conclusion of the review, the supervisor shall make a recommendation regarding Supervisory Action(s) to the RU Manager.
4.3.2.1. The Supervisory Action(s) recommended should be based on the information gained during the Supervisor Review process.
4.3.2.2. The supervisor shall document the Supervisory Action(s) recommended and the reason(s) for the Supervisory Action(s) in the “case notes” section of the alert.
4.3.3. Supervisor Reviews shall be completed within thirty (30) days of the alert being assigned to the RU Manager by the EIS Administrator. Exceptions to this requirement may be granted by the PSD Commander for good cause. Whether this request was granted, and the rationale for the decision shall be documented in the “case notes” section of the alert.
4.4. Additional PSD Responsibilities:
4.4.1. The EIS Administrator is responsible for the following:
4.4.1.1. Maintain EIS,
4.4.1.2. Manage the AMS, including alerts and open reviews,
4.4.1.3. Monitor access and usage of EIS,
4.4.1.4. Assist other members with EIS, including AMS, and PDT, when requested,
4.4.1.5. Solicit and provide feedback on the system and its usage to all Bureau members,
4.4.1.6. Develop and provide on-going training to all Bureau members,
4.4.2. Semi-annually and as directed conduct data analysis of units and supervisors to identify and compare patterns of activity in accordance with established PSD SOPs,
4.4.2.1. Semi-annually and as directed select a sample of employees to ensure the review of EIS as described in Section 2.1 of this directive has occurred,
4.4.2.2. Produce an annual report describing EIS usage and trends,
4.4.2.3. Develop and train sufficient alternate EIS Administrators to provide EIS service if the EIS Administrator is unavailable for an extended period,
4.4.2.4. Grant temporary additional access to EIS as described in Section 7, and
4.4.2.5. Ensure EIS administrative rights granted to Bureau members are consistent with current assignments.
4.4.3. The PSD Lieutenant Responsibilities:
4.4.3.1. Ensure the EIS Annual Report and other documents described in Section 4.4.2., are produced in a timely manner.
4.4.3.2. Review alerts recommended for closure by the EIS Administrator and either close or return the alerts to the EIS Administrator for additional work.
4.4.3.3. Review requests for additional review time made by the EIS Administrator and either approving or rejecting the request as described in Section 4.1.2.
4.4.4. The PSD Commander is responsible for the following:
4.4.4.1. The overall administration of the EIS Program, and
4.4.4.2. Reviewing requests for additional review time made by RU Managers and either approving or rejecting the request as described in Sections 4.2.3. and 4.3.3.
5. Type III Alert and Review Process.
5.1. Force Inspector (“the Inspector”) Responsibilities:
5.1.1. The Inspector shall conduct a quarterly analysis of force data in accordance with PSD SOP 47, Force Data Analysis at the Group and Supervisor Level.
5.1.2. After consultation with RU Manager, if the Inspector has determined that statistically meaningful deviations from normative behavior places groups and their respective supervisors at risk of problematic trends, the Inspector shall notify the EIS Administrator via memorandum. The notification shall prompt the EIS Administrator to generate an alert to the RU Manager with specific instructions and/or recommendations from the Inspector.
5.1.3. Upon notification from the EIS Administrator that the RU Manager has submitted a response to the Type III alert, the Inspector shall complete a review of the response within seven days.
5.1.3.1. If the Inspector determines the RU Manager’s response adequately addresses the alert, the Inspector shall document the response in the “case notes” section of the alert and notify the EIS Administrator that the alert can be closed.
5.1.3.2. If the Inspector determines the RU Manager’s response is insufficient, the Inspector shall direct the RU Manager to submit a revised response to adequately address the alert and document this direction in the “case notes” section of the alert.
5.2. EIS Administrator Responsibilities:
5.2.1. Within seven days of receiving a memorandum from the Inspector that a force use trend has been identified, the EIS Administrator shall generate an alert to the appropriate RU Manager.
5.2.2. The EIS Administrator shall notify the Inspector within seven days of receipt (in EIS) of the RU Manager’s response to the alert.
5.2.3. The EIS Administrator shall close the alert when instructed by the Inspector to do so.
5.3. RU Manager Responsibilities:
5.3.1. Upon receipt of a Type III alert, the RU Manager shall complete a review of the Inspector’s recommendations and provide a response within 30 days.
5.3.2. Document the actions taken and reasons for those actions in the “case notes” section of the alert. The RU Manager shall also make an entry into both the identified group’s and the respective supervisor’s pages of the AMS.
5.3.3. If the RU Manager’s response is deemed insufficient by the Inspector, they shall submit a revised response to adequately address the recommendation(s) within 15 days of the alerts reassignment with EIS by the EIS Administrator.
5.4. Branch Assistant Chief Responsibilities:
5.4.1. If the Inspector and the RU Manager do not agree on a resolution, the Branch Assistant Chief shall consider the Inspector’s memo and decide upon the appropriate resolution. The Branch Assistant Chief shall direct implementation of the resolution and the recording of Branch Assistant Chief’s determination and the resolution in the “Case Notes.”
6. EIS obtains data from the following outside sources:
6.1. Regional Justice Information Network (RegJIN): Arrests, Computer Aided Dispatch (CAD), Investigative Cases, Street Checks, Traumatic Incidents, and Uses of Force.
6.2. SAP: Employee Leave, Extra Employment, Leave Summary, Overtime, and Work Hour Summary.
6.3. Administrative Investigations Management (AIM): Commendations, Complaints.
6.4. Oregon e-Courts: Traffic Citations
6.5. Cite Search: Traffic Citations (electronic citations only)
7. EIS Data Access:
7.1. EIS administrative rights are controlled by the EIS Administrator under the direction of PSD Commander.
7.2. All Bureau members will be granted access to their own data in EIS.
7.3. A supervisor will be granted access to the EIS data of any subordinate members in their chain of command.
7.4. Temporary or additional access may be granted by submitting a written request to the EIS Administrator.
7.5. The following persons have access to the entire Bureau in EIS:
7.5.1. The Chief of Police, Assistant Chiefs, and their adjutants,
7.5.2. The PSD Commander, PSD Captain, PSD Lieutenant, Inspector, and EIS Administrators,
7.5.3. The Training Division Manager and Field Training Evaluation Program Sergeant,
7.5.4. Information Technology Division employees tasked with supporting EIS, and
7.5.5. Other members as directed by the PSD Commander or PSD Lieutenant.
8. EIS Data Retention:
8.1. Retention of EIS data pertain to entries in the PDT, as well as the AMS. Data from outside sources (RegJIN, SAP, etc.) are obtained each night, discarding prior data as new data are acquired.
8.2. EIS data will be retained for no less than ten years from the date of separation.
8.3. Questions regarding the retention of EIS data should be directed to the City Attorney’s Office.
History:
- Originating Directive Effective: 06/11/11
- Last Revision Signed: 04/15/19
- Effective Date: 05/15/19
- Next Review Date: 05/15/20