Report 2015-130 All Recommendation Responses

Report 2015-130: The CalGang Criminal Intelligence System: As the Result of Its Weak Oversight Structure, It Contains Questionable Information That May Violate Individuals' Privacy Rights (Release Date: August 2016)

Recommendation for Legislative Action

To ensure that CalGang, or any equivalent statewide shared gang database, has an oversight structure that supports accountability for proper database use and for protecting individuals' rights, the Legislature should designate Justice as the state agency responsible for administering and overseeing CalGang or any equivalent statewide shared gang database.

Description of Legislative Action

Assembly Bill 90 (Weber, Chapter 695, Statutes of 2017) establishes the California Department of Justice as the state agency responsible for administering and overseeing any shared gang database in which California law enforcement agencies participate.

  • Legislative Action Current As-of: October 2017

California State Auditor's Assessment of 1-Year Status: Legislation Enacted


Description of Legislative Action

Legislation has not been introduced to address this specific recommendation.

  • Legislative Action Current As-of: November 2016

California State Auditor's Assessment of 60-Day Status: No Action Taken


Recommendation for Legislative Action

To ensure that CalGang, or any equivalent statewide shared gang database, has an oversight structure that supports accountability for proper database use and for protecting individuals' rights, the Legislature should require that CalGang or any equivalent statewide shared gang database adhere to federal regulations and relevant safeguards from the state guidelines, including supervisory reviews of database entries and regular reviews of all records.

Description of Legislative Action

Assembly Bill 90 (Weber, Chapter 695, Statutes of 2017) requires shared gang databases to be used and operated in compliance with all applicable state and federal regulations, statutes, and guidelines.

  • Legislative Action Current As-of: October 2017

California State Auditor's Assessment of 1-Year Status: Legislation Enacted


Description of Legislative Action

AB 2298 (Chapter 752, Statutes of 2016) requires these databases to comply with federal requirements regarding the privacy and accuracy of information in the database and other operating principles for maintaining these databases.

  • Legislative Action Current As-of: November 2016

California State Auditor's Assessment of 60-Day Status: Legislation Enacted


Recommendation for Legislative Action

To ensure that CalGang, or any equivalent statewide shared gang database, has an oversight structure that supports accountability for proper database use and for protecting individuals' rights, the Legislature should specify that Justice's oversight responsibilities include developing and implementing standardized periodic training as well as conducting—or hiring an external entity to conduct— periodic audits of CalGang or any equivalent statewide shared gang database.

Description of Legislative Action

Assembly Bill 90 (Weber, Chapter 695, Statutes of 2017) requires the California Department of Justice to develop and implement standardized periodic training for all users authorized to enter data in a shared gang database, as well as for all persons with access to the CalGang database.

  • Legislative Action Current As-of: October 2017

California State Auditor's Assessment of 1-Year Status: Legislation Enacted


Description of Legislative Action

Legislation has not been introduced to address this specific recommendation.

  • Legislative Action Current As-of: November 2016

California State Auditor's Assessment of 60-Day Status: No Action Taken


Recommendation for Legislative Action

To promote public participation in key issues that may affect California's citizens and to help ensure consistency in the use of any shared gang database, the Legislature should require Justice to interpret and implement shared gang database requirements through the regulatory process. This process should include public hearings and should address adopting requirements for entering and reviewing gang designations, including establishing a retention period for gangs.

Description of Legislative Action

Assembly Bill 90 (Weber, Chapter 695, Statutes of 2017) requires Justice to promulgate regulations governing the use, operation, and oversight of any shared gang database.

  • Legislative Action Current As-of: October 2017

California State Auditor's Assessment of 1-Year Status: Legislation Enacted


Description of Legislative Action

Legislation has not been introduced to address this specific recommendation.

  • Legislative Action Current As-of: November 2016

California State Auditor's Assessment of 60-Day Status: No Action Taken


Recommendation for Legislative Action

To promote public participation in key issues that may affect California's citizens and to help ensure consistency in the use of any shared gang database, the Legislature should require Justice to interpret and implement shared gang database requirements through the regulatory process. This process should include public hearings and should address adopting criteria for identifying gang members. These criteria should define which offenses are consistent with gang activity.

Description of Legislative Action

Assembly Bill 90 (Weber, Chapter 695, Statutes of 2017) requires Justice to promulgate regulations governing the use, operation, and oversight of any shared gang database.

  • Legislative Action Current As-of: October 2017

California State Auditor's Assessment of 1-Year Status: Legislation Enacted


Description of Legislative Action

Legislation has not been introduced to address this specific recommendation.

  • Legislative Action Current As-of: November 2016

California State Auditor's Assessment of 60-Day Status: No Action Taken


Recommendation for Legislative Action

To promote public participation in key issues that may affect California's citizens and to help ensure consistency in the use of any shared gang database, the Legislature should require Justice to interpret and implement shared gang database requirements through the regulatory process. This process should include public hearings and should address specifying how user agencies will operate any statewide shared gang database, including requiring user agencies to implement supervisory review procedures and periodic record reviews. The user agencies should report the results of the reviews to Justice.

Description of Legislative Action

Assembly Bill 90 (Weber, Chapter 695, Statutes of 2017) requires Justice to promulgate regulations governing the use, operation, and oversight of any shared gang database.

  • Legislative Action Current As-of: October 2017

California State Auditor's Assessment of 1-Year Status: Legislation Enacted


Description of Legislative Action

Legislation has not been introduced to address this specific recommendation.

  • Legislative Action Current As-of: November 2016

California State Auditor's Assessment of 60-Day Status: No Action Taken


Recommendation for Legislative Action

To promote public participation in key issues that may affect California's citizens and to help ensure consistency in the use of any shared gang database, the Legislature should require Justice to interpret and implement shared gang database requirements through the regulatory process. This process should include public hearings and should address standardizing practices for user agencies to adhere to the State's juvenile notification requirements, including guidelines for documenting and communicating the bases for juveniles' gang designations.

Description of Legislative Action

Assembly Bill 90 (Weber, Chapter 695, Statutes of 2017) requires Justice to promulgate regulations governing the use, operation, and oversight of any shared gang database.

  • Legislative Action Current As-of: October 2017

California State Auditor's Assessment of 1-Year Status: Legislation Enacted


Description of Legislative Action

Legislation has not been introduced to address this specific recommendation.

  • Legislative Action Current As-of: November 2016

California State Auditor's Assessment of 60-Day Status: No Action Taken


Recommendation for Legislative Action

To ensure transparency, the Legislature should require Justice to publish an annual report with key shared gang database statistics—such as the number of individuals added to and removed from the database—and summary results from periodic audits conducted by Justice or an external entity. Further, the Legislature should require Justice to invite and assess public comments following the report's release. Subsequent annual reports should summarize any public comments Justice received and actions it took in response.

Description of Legislative Action

Assembly Bill 90 (Weber, Chapter 695, Statutes of 2017) requires Justice to promulgate regulations governing the use, operation, and oversight of any shared gang database. The regulations must provide for periodic audits by law enforcement agencies and Justice staff to ensure the accuracy, reliability, and proper use of any shared gang database. The results of those audits must be reported to the public.

  • Legislative Action Current As-of: October 2017

California State Auditor's Assessment of 1-Year Status: Legislation Enacted


Description of Legislative Action

Legislation has not been introduced to address this specific recommendation.

  • Legislative Action Current As-of: November 2016

California State Auditor's Assessment of 60-Day Status: No Action Taken


Recommendation for Legislative Action

To help ensure that Justice has the technical information it needs to make certain that CalGang or any equivalent shared gang database remains an important law enforcement tool, the Legislature should establish a technical advisory committee to advise Justice about database use, database needs, database protection, and any necessary updates to policies and procedures. The Legislature should specify the qualifications for membership in the technical advisory committee, which should include representatives from local and state agencies that use the shared gang database. Further, it should require that the committee meet at least twice a year and adhere to the Bagley-Keene Open Meeting Act and other relevant open-meeting laws.

Description of Legislative Action

Assembly Bill 90 (Weber, Chapter 695, Statutes of 2017) provides that, commencing January 1, 2018, the CalGang Executive Board will no longer administer or oversee the CalGang database or the shared gang databases that participate in the CalGang database. Justice is required to establish a technical advisory committee with specified members to advise on uses of shared gang databases.

  • Legislative Action Current As-of: October 2017

California State Auditor's Assessment of 1-Year Status: Legislation Enacted


Description of Legislative Action

Legislation has not been introduced to address this specific recommendation.

  • Legislative Action Current As-of: November 2016

California State Auditor's Assessment of 60-Day Status: No Action Taken


Recommendation #10 To: Justice, Department of

As the Legislature considers creating a public program for shared gang database oversight and accountability, Justice should guide the board and the committee to identify and address the shortcomings that exist in CalGang's current operations and oversight. The guidance Justice provides to the board and the committee should address, but not be limited to, developing best practices based on the requirements stated in the federal regulations, the state guidelines and state law, and advising user agencies on the implementation of those practices. The best practices should include, but not be limited to reviewing criminal intelligence, appropriately disseminating information, performing robust audit practices, establishing plans to recover from disasters, and meeting all of the State's juvenile notification law requirements. Justice should guide the board and the committee to develop these best practices by June 30, 2017.

1-Year Agency Response

Justice management attended the CalGang Executive Board and California Node Advisory Committee meetings in May 2017. At the meetings, the board and committee advised that they had updated the existing Policy and Procedures for the CalGang System manual to incorporate components identified in the audit recommendations. The new language was voted on and approved by the board. Justice did not review or provide input, but was provided a copy of the updated manual after it was approved and implemented by the board. In addition, the board is working to ensure consistency in juvenile notifications across the user agencies.

At the February 2017 board and committee meetings, the board requested that Justice examine the possibility of modifying the Attorney General's Model Standards and Procedures for Maintaining Criminal Intelligence Files and Criminal Intelligence Operational Activities to note that the document represents best practices, not requirements. In light of the pending legislation, it was determined Justice would postpone the request.

Since the introduction of Assembly Bill (AB) 90 and Senate Bill (SB) 505, both of which would implement the recommendations of the audit, Justice has been involved in conversations with the authors' offices, providing technical guidance and suggestions as to best ways to implement.

Justice has begun discussions with the CalGang vendor regarding development of disaster recovery planning.

Justice received funding and position authority from the Legislature for enhancements to the CalGang system with the Fiscal Year (FY) 2017-18 budget; however, Justice will have no authority to implement the recommendations made by the California State Auditor (CSA) until legislation is passed.

  • Estimated Completion Date: Dependent on enactment of legislation which would grant Justice the authority to execute and enforce the recommendations.
  • Response Date: August 2017

California State Auditor's Assessment of 1-Year Status: Pending


6-Month Agency Response

Justice compiled an internal Cal Gang working group consisting of management and staff from impacted Justice programs that is researching applicable state and federal regulations, law and guidelines, including the California Attorney General's Model Standards and Procedures for Maintaining Criminal Intelligence Files and Criminal Intelligence Operational Activities for future implementation of best practices procedures.

Justice management attended the CalGang Executive Board meetings on September 9, 2016 and February 3, 2017 and the California Node Advisory Committee meeting on February 2, 2017. At the meetings, the committee advised that it had drafted language to modify the existing Policy and Procedures for the CalGang System manual to incorporate the components identified in the audit recommendations. The new language was voted on by the board. The CalGang Executive Board requested that Justice examine the possibility of modifying the Attorney General's Model Standards and Procedures for Maintaining Criminal Intelligence Files and Criminal Intelligence Operational Activities to note that the document represents best practices, not requirements. The Justice working group is reviewing this recommendation from the CalGang Executive Board.

Justice currently has no existing resources, authority or program in place to handle oversight or administration of CalGang; thus, additional resources and funding will be needed to fully implement this recommendation.

  • Estimated Completion Date: June 30, 2017
  • Response Date: February 2017

California State Auditor's Assessment of 6-Month Status: Pending


60-Day Agency Response

Justice has compiled an internal CalGang working group consisting of management and staff from impacted Justice programs and has begun researching applicable state and federal regulations, law, and guidelines, including the California Attorney General's Model Standards and Procedures for Maintaining Criminal Intelligence Files and Criminal Intelligence Operational Activities.

Justice management also attended the recent CalGang Executive Board meeting on September 9, 2016.

Justice currently has no existing resources or program in place to handle oversight or administration of CalGang, however, the department has begun dialogue with the board on each recommendation and will do everything possible to begin implementation until additional resources and funding are granted to the department.

  • Estimated Completion Date: June 30, 2017
  • Response Date: October 2016

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #11 To: Justice, Department of

As the Legislature considers creating a public program for shared gang database oversight and accountability, Justice should guide the board and the committee to identify and address the shortcomings that exist in CalGang's current operations and oversight. The guidance Justice provides to the board and the committee should address, but not be limited to, instructing user agencies that use CalGang to complete a comprehensive review of all the gangs documented in CalGang to determine if they meet the necessary requirements for inclusion and to purge from CalGang any groups that do not meet the requirements. Justice should guide the board and the committee to ensure that user agencies complete this review in phases, with the final phase to be completed by June 30, 2018.

1-Year Agency Response

At the California Gang Node Advisory Committee and CalGang Executive Board meeting in May 2017, Justice inquired as to whether a timeline for completion of each phase had been completed and requested a written update on the progress toward completing each review, by node and agency, prior to each quarterly meeting. As of August 2017, neither had been provided. The committee stated that user agencies are reviewing all gangs in CalGang with three or less members and purging those that do not meet the defined gang criteria.

Additionally, since the introduction of AB 90 and SB 505, both of which would implement the recommendations of the audit, Justice has been involved in conversations with the authors' offices, providing technical guidance and suggestions as to best ways to implement.

Justice received funding and position authority from the Legislature for enhancements to the CalGang system with the FY 2017-18 budget; however, Justice will have no authority to implement the recommendations made by the CSA until legislation is passed. Justice will continue to work with the board and committee until express authority is granted by the Legislature.

  • Estimated Completion Date: June 30, 2018
  • Response Date: August 2017

California State Auditor's Assessment of 1-Year Status: Pending


6-Month Agency Response

Justice discussed this recommendation with the attendees at the CalGang Executive Board meeting in September 2016 and recommended that the board establish a plan that would include timelines for each phase of the required review to ensure the completion of this recommendation. At the recent California Gang Node Advisory Committee and CalGang Executive Board meeting in February 2017, Justice inquired as to whether a timeline for completion of each phase has been completed and requested a written update on the progress toward completing each review, by node and agency, prior to each quarterly meeting. The Advisory Committee stated that it is developing a plan to provide for the auditing of records by other user agencies. Agencies discussed obtaining assistance from their internal Audit Divisions to assist in establishing proper audit protocol and procedures.

Justice currently has no existing authority, resources or program in place to handle oversight or administration of CalGang, however, Justice has begun dialogue with the board on each recommendation and will do everything possible to begin implementation until additional resources and funding are granted to the department.

  • Estimated Completion Date: June 30, 2018
  • Response Date: February 2017

California State Auditor's Assessment of 6-Month Status: Pending


60-Day Agency Response

Justice management attended the CalGang Executive Board meeting in September 2016 and recommended that the board establish a plan that would include timelines for each phase of the required review to ensure the completion of this recommendation. Justice will follow-up with the board periodically to discuss progress of this recommendation, provide guidance and feedback, and help to ensure completion of each phase.

Justice currently has no existing resources or program in place to handle oversight or administration of CalGang, however, the department has begun dialogue with the board on each recommendation and will do everything possible to begin implementation until additional resources and funding are granted to the department.

  • Estimated Completion Date: June 30, 2018
  • Response Date: October 2016

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #12 To: Justice, Department of

As the Legislature considers creating a public program for shared gang database oversight and accountability, Justice should guide the board and the committee to identify and address the shortcomings that exist in CalGang's current operations and oversight. The guidance Justice provides to the board and the committee should address, but not be limited to, instructing all user agencies to complete a comprehensive review of the records in CalGang to determine if the user agencies have adequate support for the criteria associated with all the individuals they have entered as gang members. If the user agencies do not have adequate support, they should immediately purge the criteria—and, if necessary, the individuals—from CalGang. In addition, the user agencies should ensure that all the fields in each CalGang record are accurate. Justice should guide the board and the committee to ensure that user agencies complete this review in phases, with the final phase to be completed by September 30, 2019.

1-Year Agency Response

At the California Gang Node Advisory Committee and CalGang Executive Board meetings in May 2017, Justice inquired as to whether a timeline for completion of each phase had been completed and requested a written update on the progress toward completing each review, by node and agency, prior to each quarterly meeting. The committee advised it has established an audit protocol in which a statistically valid sample size of records is to be audited. Currently, the user agencies do not have the resources to complete a comprehensive review of all records in the CalGang system. The committee has not provided a plan for completion to Justice, but members stated that records are being reviewed by user agencies on a quarterly basis.

Additionally, since the introduction of AB 90 and SB 505, both of which would implement the recommendations of the audit, Justice has been involved in conversations with the authors' offices, providing technical guidance and suggestions as to best ways to implement.

Justice received funding and position authority from the Legislature for enhancements to the CalGang system with the FY 2017-18 budget; however, Justice will have no authority to implement the recommendations made by the CSA until legislation is passed. Justice will continue to work with the board and committee until express authority is granted by the Legislature.

  • Estimated Completion Date: Unknown
  • Response Date: August 2017

California State Auditor's Assessment of 1-Year Status: Pending


6-Month Agency Response

Justice management attended the CalGang Executive Board meeting in September 2016 and recommended that the board establish a plan to ensure the completion of this recommendation, including timelines for each phase of the required review. Justice will follow-up with the board periodically to discuss progress of this recommendation, provide guidance and feedback, and help to ensure completion of each phase.

At the recent California Gang Node Advisory Committee and CalGang Executive Board meetings in February 2017, Justice inquired as to whether a timeline for completion of each phase has been completed and requested a written update on the progress toward completing each review, by node and agency, prior to each quarterly meeting. The Advisory Committee stated that it is developing a plan to provide for auditing by other user agencies.

Justice currently has no existing authority, resources or program in place to handle oversight or administration of CalGang, however, Justice has begun dialogue with the board on each recommendation and will do everything possible to begin implementation until additional resources and funding are granted to the department.

  • Estimated Completion Date: September 30, 2019
  • Response Date: February 2017

California State Auditor's Assessment of 6-Month Status: Pending


60-Day Agency Response

Justice management attended the CalGang Executive Board meeting in September 2016 and recommended that the board establish a plan to ensure the completion of this recommendation, including timelines for each phase of the required review. Justice will follow-up with the board periodically to discuss progress of this recommendation, provide guidance and feedback, and help to ensure completion of each phase.

Justice currently has no existing resources or program in place to handle oversight or administration of CalGang, however, the department has begun dialogue with the board on each recommendation and will do everything possible to begin implementation until additional resources and funding are granted to the department.

  • Estimated Completion Date: September 30, 2019
  • Response Date: October 2016

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #13 To: Justice, Department of

As the Legislature considers creating a public program for shared gang database oversight and accountability, Justice should guide the board and the committee to identify and address the shortcomings that exist in CalGang's current operations and oversight. The guidance Justice provides to the board and the committee should address, but not be limited to, instructing all user agencies to report to Justice every six months, beginning in January 2017, on their progress toward completing their gang and gang member reviews.

1-Year Agency Response

Justice management attended the CalGang Executive Board meeting in May 2017. User agencies are currently using an existing board and committee-approved audit form to capture information for the biannual report. While Justice has not yet received any reports, user agencies were instructed to provide the audit forms to Justice every six months.

Additionally, since the introduction of AB 90 and SB 505, both of which would implement the recommendations of the audit, Justice has been involved in conversations with the authors' offices, providing technical guidance and suggestions as to best ways to implement.

Justice received funding and position authority from the Legislature for enhancements to the CalGang system with the FY 2017-18 budget; however, Justice will have no authority to implement the recommendations made by the CSA until legislation is passed. Justice will continue to work with the board and committee until express authority is granted by the Legislature.

  • Estimated Completion Date: Dependent on enactment of legislation which would grant Justice the authority to execute and enforce the recommendations.
  • Response Date: August 2017

California State Auditor's Assessment of 1-Year Status: Pending


6-Month Agency Response

Justice management attended the CalGang Executive Board meeting in September 2016. The board and Justice agreed that Justice needs to determine what components should be included in the bi-annual reports. Justice is continuing to hold internal discussions with the CalGang working group to determine what components would be beneficial in tracking progress toward implementation of CSA's recommendation and working on a template for the report. Once Justice determines the components that should be used by all user agencies to help identify and address shortcomings in CalGang's current operations and oversight and report progress of their reviews, Justice will request review and feedback from the board to help ensure a successful implementation.

Justice currently has no existing resources or program in place to handle oversight or administration of CalGang, however, Justice has begun dialogue with the board on each recommendation and will do everything possible to begin implementation until additional resources and funding are granted to the department.

  • Estimated Completion Date: July 1, 2017
  • Response Date: February 2017

California State Auditor's Assessment of 6-Month Status: Pending


60-Day Agency Response

Justice management attended the CalGang Executive Board meeting in September 2016. The board and Justice agreed that Justice needs to determine what components should be included in the bi-annual reports. Justice is holding internal discussions with the CalGang working group to determine what components would be beneficial in tracking progress toward implementation of CSA recommendations. Once Justice determines the components that should be used by all user agencies to help identify and address shortcomings in CalGang's current operations and oversight and report progress of their reviews, Justice will request review and feedback from the board to help ensure a successful implementation.

Justice currently has no existing resources or program in place to handle oversight or administration of CalGang, however, the department has begun dialogue with the board on each recommendation and will do everything possible to begin implementation until additional resources and funding are granted to the department.

  • Estimated Completion Date: November 30, 2016
  • Response Date: October 2016

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #14 To: Justice, Department of

As the Legislature considers creating a public program for shared gang database oversight and accountability, Justice should guide the board and the committee to identify and address the shortcomings that exist in CalGang's current operations and oversight. The guidance Justice provides to the board and the committee should address, but not be limited to, developing standardized periodic training content for all CalGang users and training instructors. Justice should guide the board and the committee to develop such standardized training content by June 30, 2017.

1-Year Agency Response

At the California Gang Node Advisory Committee and CalGang Executive Board meetings in May 2017, Justice discussed the progress of this recommendation. The committee advised it had developed standardized training, which was incorporated into the existing mandatory training components.

All CalGang users and training instructors receive the standardized training. All users are required to complete a CalGang End User Security Notification upon completion of training.

Additionally, since the introduction of AB 90 and SB 505, both of which would implement the recommendations of the audit, Justice has been involved in conversations with the authors' offices, providing technical guidance and suggestions as to best ways to implement.

  • Estimated Completion Date: Implemented according to the committee. However, the CSA's recommendation includes a requirement that the training occur periodically. Until the Legislature grants Justice express authority, Justice cannot compel the board and committee to update or develop further training or to implement or enforce the training.
  • Response Date: August 2017

California State Auditor's Assessment of 1-Year Status: Pending


6-Month Agency Response

Justice management attended the CalGang Executive Board meeting in September 2016. This recommendation was discussed at the meeting. According to the board, there are currently mandatory components used in all agency training. The board will review the mandatory components and develop standardized training for all nodes as well as customized training for each individual node. Justice will review the training prior to implementation.

At the recent California Gang Node Advisory Committee and CalGang Executive Board meetings in February 2017, Justice discussed the progress of this recommendation. At the meeting, the committee advised it has developed standardized training, is on track to implementing by the recommended date, and will send the curriculum to Justice for review.

Justice currently has no existing authority, resources or program in place to handle oversight or administration of CalGang, however, the department has begun dialogue with the board on each recommendation and will do everything possible to begin implementation until additional resources and funding are granted to the department.

  • Estimated Completion Date: June 30, 2017
  • Response Date: February 2017

California State Auditor's Assessment of 6-Month Status: Pending


60-Day Agency Response

Justice management attended the CalGang Executive Board meeting in September 2016. This recommendation was discussed at the meeting. According to the board, there are currently mandatory components used in all agency training. The board will review the mandatory components and develop standardized training for all nodes as well as customized training for each individual node. Justice will review the training prior to implementation.

Justice currently has no existing resources or program in place to handle oversight or administration of CalGang, however, the department has begun dialogue with the board on each recommendation and will do everything possible to begin implementation until additional resources and funding are granted to the department.

  • Estimated Completion Date: June 30, 2017
  • Response Date: October 2016

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #15 To: Justice, Department of

As the Legislature considers creating a public program for shared gang database oversight and accountability, Justice should guide the board and the committee to identify and address the shortcomings that exist in CalGang's current operations and oversight. The guidance Justice provides to the board and the committee should address, but not be limited to, establishing a plan to recertify all CalGang users and training instructors on the new training content. Justice should guide the board and the committee to complete the draft plan by June 30, 2017, and the recertification training by June 30, 2018.

1-Year Agency Response

At the recent California Gang Node Advisory Committee and CalGang Executive Board meetings in February 2017, Justice discussed the progress of this recommendation. The committee advised that it has established a subcommittee to develop the plan to ensure that every CalGang user is recertified every two years.

According to the board, the two-year recertification training will be built into the CalGang database and any current or new users due for training will need to complete and pass the training, prior to obtaining access. The system will require users to digitally sign a new user agreement at the completion of the training. This digitally signed document will be retained electronically within the database, associated with each user.

Additionally, since the introduction of AB 90 and SB 505, both of which would implement the recommendations of the audit, Justice has been involved in conversations with the authors' offices, providing technical guidance and suggestions as to best ways to implement.

Justice received funding and position authority from the Legislature for enhancements to the CalGang system with the FY 2017-18 budget; however, Justice will have no authority to implement the recommendations made by the CSA until legislation is passed. Justice continue to work with the board and committee until express authority is granted by the Legislature.

  • Estimated Completion Date: October 1, 2017
  • Response Date: August 2017

California State Auditor's Assessment of 1-Year Status: Pending


6-Month Agency Response

Justice management attended the CalGang Executive Board meeting in September 2016. This recommendation was discussed at the meeting. The board discussed the possibility of recertification training being done programmatically through the CalGang system. The board will develop the recertification plan and allow Justice to review the plan prior to implementation.

At the recent California Gang Node Advisory Committee and CalGang Executive Board meetings in February 2017, Justice discussed the progress of this recommendation. The committee advised that it has established a subcommittee to develop the plan to ensure that every CalGang user is recertified every two years.

Justice currently has no existing authority, resources or program in place to handle oversight or administration of CalGang, however, Justice has begun dialogue with the board on each recommendation and will do everything possible to begin implementation until additional resources and funding are granted to the department.

  • Estimated Completion Date: June 30, 2017
  • Response Date: February 2017

California State Auditor's Assessment of 6-Month Status: Pending


60-Day Agency Response

Justice management attended the CalGang Executive Board meeting in September 2016. This recommendation was discussed at the meeting. The board discussed the possibility of recertification training being done programmatically through the CalGang system. The board will develop the recertification plan and allow Justice to review the plan prior to implementation.

Justice currently has no existing resources or program in place to handle oversight or administration of CalGang, however, the department has begun dialogue with the board on each recommendation and will do everything possible to begin implementation until additional resources and funding are granted to the department.

  • Estimated Completion Date: June 30, 2018
  • Response Date: October 2016

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #16 To: Justice, Department of

As the Legislature considers creating a public program for shared gang database oversight and accountability, Justice should guide the board and the committee to identify and address the shortcomings that exist in CalGang's current operations and oversight. The guidance Justice provides to the board and the committee should address, but not be limited to, developing policies and procedures requiring the disabling of user accounts for all individuals who no longer have a need to or right to access CalGang because they have separated from their employment with user agencies or for other reasons. Justice should guide the board and the committee to identify and disable all such accounts by September 30, 2016.

1-Year Agency Response

Justice researched relevant state and federal policy and incorporated those into policies addressing the deactivation of accounts as necessary. The policies were presented to and accepted by California Gang Node Advisory Committee and CalGang Executive Board at the February 2017 meetings.

At the May 2017 meetings, the board and committee asked Justice to incorporate into the User Account Policy requirements regarding recertification training if the system is not used in a 12-month period and a two-year recertification training requirement for all users. These additional changes will be presented to and approved by the board and committee at the September 2017 meetings.

Additionally, since the introduction of AB 90 and SB 505, both of which would implement the recommendations of the audit, Justice has been involved in conversations with the authors' offices, providing technical guidance and suggestions as to best ways to implement.

Justice received funding and position authority from the Legislature for enhancements to the CalGang system with the FY 2017-18 budget; however, Justice will have no authority to implement the recommendations made by the CSA until legislation is passed. Justice will continue to work with the board and committee until express authority is granted by the Legislature.

  • Estimated Completion Date: September 2017
  • Response Date: August 2017

California State Auditor's Assessment of 1-Year Status: Pending


6-Month Agency Response

Justice management attended the CalGang Executive Board meeting in September 2016. This recommendation was discussed at the meeting. Justice has researched relevant state and federal policy and incorporated those into draft policies addressing the deactivation of accounts as necessary. The draft is being reviewed by Justice's CalGang working group and upon completion will be submitted to the board for review before the policies and procedures are provided to the user agencies for guidance and implementation.

At the recent California Gang Node Advisory Committee and CalGang Executive Board meetings in February 2017, Justice presented and discussed the proposed policy with the group. The board and committee relayed concerns with the proposed policy and provided suggested revisions. The Justice CalGang working group will review the suggested revisions.

Justice currently has no existing authority, resources or program in place to handle oversight or administration of CalGang, however, Justice has begun dialogue with the board on each recommendation and will do everything possible to begin implementation until additional resources and funding are granted to the department.

  • Estimated Completion Date: Unknown
  • Response Date: February 2017

California State Auditor's Assessment of 6-Month Status: Pending


60-Day Agency Response

Justice management attended the CalGang Executive Board meeting in September 2016. This recommendation was discussed at the meeting. Justice has researched relevant state and federal policy and incorporated those into draft policies addressing the deactivation of accounts as necessary. The draft is being reviewed internally and upon completion will be submitted to the board for review before the policies and procedures are provided to the user agencies for guidance and implementation.

Justice currently has no existing resources or program in place to handle oversight or administration of CalGang, however, the department has begun dialogue with the board on each recommendation and will do everything possible to begin implementation until additional resources and funding are granted to the department.

  • Estimated Completion Date: October 31, 2016
  • Response Date: October 2016

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #17 To: Justice, Department of

As the Legislature considers creating a public program for shared gang database oversight and accountability, Justice should guide the board and the committee to identify and address the shortcomings that exist in CalGang's current operations and oversight. The guidance Justice provides to the board and the committee should address, but not be limited to, determining what steps must be taken to upgrade CalGang's controls to ensure that CalGang will automatically purge all individuals whose records have not been updated by user agencies for five years.

1-Year Agency Response

At the California Gang Node Advisory Committee and CalGang Executive Board meetings in February 2017, the board advised Justice that this recommendation has been completed.

Justice confirmed with the vendor, CSRA, that the automatic purge was implemented.

  • Completion Date: February 2017
  • Response Date: August 2017

California State Auditor's Assessment of 1-Year Status: Fully Implemented

In September 2017, one of our information technology auditors met with Justice and its CalGang database vendor (CSRA). Our auditor observed the various edit checks and controls CSRA has put in place as a result of our audit findings. Based on these observations, we agree that this recommendation has been fully implemented.


6-Month Agency Response

Justice management attended the CalGang Executive Board meeting in September 2016. The board and the CalGang vendor have compiled a list of recommendations to ensure that individuals are purged automatically, as necessary. The CalGang vendor is working to assign cost to implementation of its recommendations.

At the recent California Gang Node Advisory Committee and CalGang Executive Board meetings in February 2017, the board advised Justice that this recommendation has been completed.

  • Completion Date: February 2017
  • Response Date: February 2017

California State Auditor's Assessment of 6-Month Status: Pending


60-Day Agency Response

Justice management attended the CalGang Executive Board meeting in September 2016. The board and the CalGang vendor have compiled a list of recommendations to ensure that individuals are purged automatically, as necessary. The CalGang vendor is working to assign cost to implementation of its recommendations.

  • Estimated Completion Date: To be determined
  • Response Date: October 2016

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #18 To: Justice, Department of

To promote transparency and hold the board, the committee, and user agencies accountable for implementing and adhering to criminal intelligence safeguards, Justice should post quarterly reports on its website, beginning June 30, 2017, that summarize how it has guided the board and the committee to implement and adhere to criminal intelligence safeguards; the progress the board, the committee, and the user agencies have made in implementing and adhering to these safeguards; the steps these entities still must take to implement these safeguards; and any barriers to the board's and the committee's success in achieving these goals.

1-Year Agency Response

Justice developed a template for the quarterly reports, to be utilized by user agencies. Justice presented the template at the California Gang Node Advisory Committee and CalGang Executive Board meetings in May 2017. A draft report was prepared and is awaiting approval by the board and committee. This will be included as a discussion item at the September 2017 meetings. If approval is obtained before the September 2017 meeting, the report will be posted to the Attorney General's website.

Additionally, since the introduction of AB 90 and SB 505, both of which would implement the recommendations of the audit, Justice has been involved in conversations with the authors' offices, providing technical guidance and suggestions as to best ways to implement.

Justice received funding and position authority from the Legislature for enhancements to the CalGang system with the FY 2017-18 budget; however, Justice will have no authority to implement the recommendations made by the CSA until legislation is passed. Justice will continue to work with the board and committee until express authority is granted by the Legislature.

  • Estimated Completion Date: Unknown
  • Response Date: August 2017

California State Auditor's Assessment of 1-Year Status: Pending


6-Month Agency Response

Justice management attended the CalGang Executive Board meeting in September 2016 and discussed this recommendation. The Justice internal CalGang working group will determine the best way to collect the information necessary to compile meaningful reports.

At the recent California Gang Node Advisory Committee and CalGang Executive Board meetings in February 2017, the committee advised that it is developing a plan to provide for auditing by other user agencies. This auditing can be leveraged to provide the information needed for the quarterly reports. Justice is working on a template for the report.

Justice currently has no existing authority, resources or program in place to handle oversight or administration of CalGang, however, Justice has begun dialogue with the board on each recommendation and will do everything possible to begin implementation until additional resources and funding are granted to the department.

  • Estimated Completion Date: June 30, 2017
  • Response Date: February 2017

California State Auditor's Assessment of 6-Month Status: Pending


60-Day Agency Response

Justice management attended the CalGang Executive Board meeting in September 2016 and discussed this recommendation. The Justice internal CalGang working group will determine the best way to collect the information necessary to compile meaningful reports.

Justice currently has no existing resources or program in place to handle oversight or administration of CalGang, however, the department has begun dialogue with the board on each recommendation and will do everything possible to begin implementation until additional resources and funding are granted to the department.

  • Estimated Completion Date: June 30, 2017
  • Response Date: October 2016

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #19 To: Justice, Department of

To promote transparency and encourage public participation in CalGang's meetings, Justice should post summary results from the committee's audits of CalGang records to its website unless doing so would compromise criminal intelligence information or other information that must be shielded from public release.

1-Year Agency Response

Justice developed a template for the reporting of these results, to be utilized by user agencies. Justice presented the template at the California Gang Node Advisory Committee and CalGang Executive Board meetings in May 2017. The template is under review by the board and committee. This will be included as a discussion item at the September 2017 meetings.

Additionally, since the introduction of AB 90 and SB 505, both of which would implement the recommendations of the audit, Justice has been involved in conversations with the authors' offices, providing technical guidance and suggestions as to best ways to implement.

Justice received funding and position authority from the Legislature for enhancements to the CalGang system with the FY 2017-18 budget; however, Justice will have no authority to implement the recommendations made by the CSA until legislation is passed. Justice will begin filling allocated positions and continue to work with the board and committee until express authority is granted by the Legislature.

  • Estimated Completion Date: Unknown
  • Response Date: August 2017

California State Auditor's Assessment of 1-Year Status: Pending


6-Month Agency Response

Justice management attended the CalGang Executive Board in September 2016 and discussed this recommendation. It has been determined that the board can provide the necessary information to Justice to be posted on its website.

At the recent California Gang Node Advisory Committee and CalGang Executive Board meetings in February 2017, Justice advised that it is developing a template for the information to be included.

Justice currently has no existing authority, resources or program in place to handle oversight or administration of CalGang, however, Justice has begun dialogue with the board on each recommendation and will do everything possible to begin implementation until additional resources and funding are granted to the department.

  • Estimated Completion Date: June 30, 2017
  • Response Date: February 2017

California State Auditor's Assessment of 6-Month Status: Pending


60-Day Agency Response

Justice management attended the CalGang Executive Board in September 2016 and discussed this recommendation. It has been determined that the board can provide the necessary information to Justice to be posted on its website.

Justice currently has no existing resources or program in place to handle oversight or administration of CalGang, however, the department has begun dialogue with the board on each recommendation and will do everything possible to begin implementation until additional resources and funding are granted to the department.

  • Estimated Completion Date: June 30, 2017
  • Response Date: October 2016

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #20 To: Justice, Department of

To promote transparency and encourage public participation in CalGang's meetings, Justice should post the agendas, minutes, and referenced attachments for all future board and committee meetings, as well as all other documents of significance such as letters, memos, or agreements to its website unless doing so would compromise criminal intelligence information or other information that must be shielded from public release.

1-Year Agency Response

Justice will continue working with the CalGang Executive Board to obtain and post the agenda and any referenced attachments at least 10 days prior to each future meeting so they can be posted on the Justice website.

  • Completion Date: June 2017
  • Response Date: August 2017

California State Auditor's Assessment of 1-Year Status: Fully Implemented

Justice's website includes agendas, meeting minutes, and attachments for meetings occurring after the publication of our audit in August 2016.


6-Month Agency Response

Justice management attended the CalGang Executive Board in September 2016 and discussed this recommendation. It has been determined that the board can provide the necessary information to Justice to be posted on its website.

Since the September 2016 Board Meeting, Justice obtained and posted the agenda, along with Justice's discussion points prior to the February 2017 CalGang Executive Board meeting. Justice has requested the February 2017 board meeting minutes and attachments so they can be posted on the Justice website.

Justice currently has no existing authority, resources or program in place to handle oversight or administration of CalGang, however, Justice has begun dialogue with the board on each recommendation and will do everything possible to begin implementation until additional resources and funding are granted to the department.

  • Estimated Completion Date: On-Going
  • Response Date: February 2017

California State Auditor's Assessment of 6-Month Status: Pending


60-Day Agency Response

Justice management attended the CalGang Executive Board in September 2016 and discussed this recommendation. It has been determined that the board can provide the necessary information to Justice to be posted on its website.

Justice currently has no existing resources or program in place to handle oversight or administration of CalGang, however, the department has begun dialogue with the board on each recommendation and will do everything possible to begin implementation until additional resources and funding are granted to the department.

  • Estimated Completion Date: December 31, 2016
  • Response Date: October 2016

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #21 To: Justice, Department of

To promote transparency and encourage public participation in CalGang's meetings, Justice should post from the past five years, all available agendas, minutes, and referenced attachments from scheduled and ad hoc board and committee meetings, as well as all other documents of significance. Justice should post these materials by October 31, 2016, to its website unless doing so would compromise criminal intelligence information or other information that must be shielded from public release.

1-Year Agency Response

Justice management discussed with Chairman of the CalGang Executive Board at the meetings in September 2016, December 2016, and February 2017. The board has advised that all available documents have been provided to Justice. Justice posted all documents received to the Attorney General's website at https://oag.ca.gov/calgang/meeting.

  • Completion Date: February 2017
  • Response Date: August 2017

California State Auditor's Assessment of 1-Year Status: Fully Implemented

Although Justice's website does not contain any CalGang meeting agendas and minutes for 2015, and is likely missing a number of other meeting agendas and minutes from the previous five years, Justice appears to have made a good faith effort to obtain these documents. The CalGang Executive Board may simply not have retained or prepared these documents.


6-Month Agency Response

Justice management attended the CalGang Executive Board in September 2016 and discussed this recommendation with the board. The board is working to compile available information to provide to Justice to post to its website.

Justice followed up with the Chairman of the CalGang Executive Board requesting the documents and discussed this request at the recent CalGang Executive Board meeting in February 2017. Justice will continue to inquire with the Chairman of the CalGang Executive Board until the documents are provided.

Justice currently has no existing authority, resources or program in place to handle oversight or administration of CalGang, however, Justice has begun dialogue with the board on each recommendation and will do everything possible to begin implementation until additional resources and funding are granted to the department.

  • Estimated Completion Date: Unknown
  • Response Date: February 2017

California State Auditor's Assessment of 6-Month Status: Pending


60-Day Agency Response

Justice management attended the CalGang Executive Board in September 2016 and discussed this recommendation with the board. The board is working to compile available information to provide to Justice to post to its website.

Justice currently has no existing resources or program in place to handle oversight or administration of CalGang, however, the department has begun dialogue with the board on each recommendation and will do everything possible to begin implementation until additional resources and funding are granted to the department.

  • Estimated Completion Date: October 31, 2016
  • Response Date: October 2016

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #22 To: Justice, Department of

If Justice believes it needs additional resources to guide the board and the committee to identify and address the shortcomings that exist in CalGang's current operations and oversight, to report on the board and committee's progress in addressing CalGang's shortcomings, and to post necessary information to its website, Justice should take steps to secure the resources it needs.

1-Year Agency Response

Justice received funding and position authority from the Legislature for enhancements to the CalGang system with the FY 2017-18 budget; however, Justice will have no authority to implement the recommendations made by the CSA until legislation is passed. Justice will continue to work with the board and committee until express authority is granted by the Legislature.

  • Completion Date: July 2017
  • Response Date: August 2017

California State Auditor's Assessment of 1-Year Status: Fully Implemented


6-Month Agency Response

Justice will seek funding for six new positions, training, and contract resources for CalGang system improvements.

  • Estimated Completion Date: Unknown
  • Response Date: February 2017

California State Auditor's Assessment of 6-Month Status: Pending


60-Day Agency Response

Justice will seek funding for new positions, training, and contract resources for system improvements, however Justice is waiting until the Legislature establishes some statewide policy before requesting any additional resources for program improvements.

  • Estimated Completion Date: Unknown
  • Response Date: October 2016

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #23 To: Los Angeles Police Department

Until the Los Angeles Police Department receives further direction from the board, the committee, or Justice, it should address the specific deficiencies we found by reviewing the gangs it has entered into CalGang to ensure the gangs meet reasonable suspicion requirements. It should also begin reviewing the gang members it has entered into CalGang to ensure the existence of proper support for each criterion. It should purge from CalGang any records for gangs or gang members that do not meet the criteria for entry. Individuals who are independent from the ongoing administration and use of CalGang should lead this review. The agency should complete the gang and gang member reviews in phases, with the final phase for gangs to be completed by June 30, 2018, and the final phase for gang members to be completed by June 30, 2019.

1-Year Agency Response

CSAO Recommendation 23 (a): Review gang members that have been entered in to Cal/Gang to ensure the existence of proper support for each criterion;

LAPD Action Taken: In progress. A statistically valid sample of gang members was calculated by Audit Division and submitted to the Node Administrator. The Node Administrator utilized a randomizer to select the gang member entries that were inspected.

Three of LAPD's four geographic bureaus have completed their gang member inspections. The fourth bureau's gang member inspection should be completed within the next quarter.

The Department will conduct a review of the findings and may require additional inspections.

CSAO Recommendation 23 (b): Purge from Cal/Gang any records for gangs or gang members that do not meet the criteria for entry;

LAPD Action Taken: Not yet implemented.

After results of the inspections have been reviewed by the Cal/Gang Node Administrator, any gangs or gang members that do not meet the criteria for inclusion in the database will be removed. The Cal/Gang Node Administrator will complete the removal.

CSAO Recommendation 23 (c): Complete gang and gang member reviews in phases with the final phase for gangs to be completed by June 30, 2018;

LAPD Action Taken: In progress.

CSAO Recommendation 23 (d): The final phase [review] for gang members to be completed by June 30, 2019.

LAPD Action Taken: In progress.

  • Estimated Completion Date: June 30, 2019
  • Response Date: August 2017

California State Auditor's Assessment of 1-Year Status: Pending


6-Month Agency Response

CSAO Recommendation 23 (a): Review gang members that have been entered in to Cal/Gang to ensure the existence of proper support for each criterion;

LAPD Action Taken: In progress. A statistically valid sample size of gang members was calculated by Audit Division and submitted to the Node Administrator. The Node Administrator utilized a randomizer to select the gang member entries that will be inspected. It is anticipated that Bureau inspections will be completed by the end of April 2017. Following the Bureau inspections, the Department will conduct a review of the findings and may require additional inspections.

CSAO Recommendation 23 (b): Purge from Cal/Gang any records for gangs or gang members that do not meet the criteria for entry;

LAPD Action Taken: Not yet implemented.

After results of the inspections have been reviewed by the Cal/Gang Node Administrator, any gangs or gang members that do not meet the criteria for inclusion in the database will be removed. The Cal/Gang Node Administrator will complete the removal.

CSAO Recommendation 23 (c): Complete gang and gang member reviews in phases with the final phase for gangs to be completed by June 30, 2018;

LAPD Action Taken: In progress.

CSAO Recommendation 23 (d): The final phase [review] for gang members to be completed by June 30, 2019.

LAPD Action Taken: In progress.

  • Estimated Completion Date: June 30, 2019
  • Response Date: February 2017

California State Auditor's Assessment of 6-Month Status: Pending


60-Day Agency Response

The first inspection is anticipated to begin in the fourth quarter of 2016. An inspection matrix was created for this inspection. Once approved by LAPD, the Office of Operations (OO) will be tasked with writing an Operations Order to ensure that Bureau Gang inspection teams conduct inspections. It was determined that a bureau wide, statistically valid sample be utilized for this recommendation and a separate inspection be conducted for juveniles. Results of those inspections will be forwarded to OO and then disseminated to GND.

After results have been reviewed by the Cal/Gang Node Administrator, any gangs or gang members that do not meet the criteria for inclusion in the database will be removed. The Cal/Gang Node Administrator will do removal.

Expanded review and Supervisory responsibilities will be detailed in a revised Special Order related to Special Order No. 15, May 22, 2013, (Cal/Gang System and Gang File Guidelines and Related Subsections). This will include a Department manual update. It is anticipated that the Matrices developed for the inspections will be approved for use at the upcoming bureau meeting in early October 2016.

  • Estimated Completion Date: June 30, 2018
  • Response Date: October 2016

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #24 To: Los Angeles Police Department

Until Los Angeles Police Department receives further direction from the board, the committee, or Justice, it should address the specific deficiencies we found by developing or modifying as necessary all its policies and procedures related to CalGang to ensure they align with state law, CalGang policy, the federal regulations, and the state guidelines. In particular, the agency should implement appropriate policies and procedures for entering gangs; performing supervisory reviews of gang and gang member entries; performing periodic CalGang record reviews; sharing CalGang information; and complying with juvenile notification requirements. The agency should complete this recommendation by March 31, 2017.

1-Year Agency Response

CSAO Recommendation 24 (a):

LAPD Action Taken: In progress. A COD Notice titled "Compliance with Assembly Bill 2298 and Penal Code sections 186.34 and 186.35" is pending review by the LAPD Police Commission and Department approval.

CSAO Recommendation 24 (b):

LAPD Action Taken: Expanded review and Supervisory responsibilities will be detailed in a revised Special Order related to Special Order No. 15, May 22, 2013, (Cal/Gang System and Gang File Guidelines and Related Subsections). This will include a Department manual update.

CSAO Recommendation 24 (c):

LAPD Action Taken:

· In progress. Cal/Gang record review in progress.

· Completed. Sharing Cal/Gang information: A Detective Bureau Cal/Gang Proxy Login Notice dated August 23, 2016, and an accompanying Cal/Gang Telephonic Information Request Form (checklist) was written and published for Department use.

· In progress. A revised notification letter has been drafted and is pending Department approval. The revised notification letter contains expanded language, which complies with California state law.

CSAO Recommendation 24 (d):

Department Response: The CGNAC proposed to the Cal/Gang Executive Board that the Attorney Guidelines not be followed in its entirety because of one provision. Specifically, the provision regarding review of all gang members in Cal/Gang by two Police Captains is not feasible. The LAPD will inspect a statistically valid sample of gang members on an annual basis. The Executive Board approved modified policies and procedures regarding this issue at the February 2017 meeting.

Action Taken: In progress.

  • Estimated Completion Date: September 1, 2017
  • Response Date: August 2017

California State Auditor's Assessment of 1-Year Status: Pending


6-Month Agency Response

CSAO Recommendation 24 (a):Implement appropriate policies and procedures for entering gangs;

LAPD Action Taken: In progress. A COD Notice titled "Compliance with Assembly Bill 2298 and Penal Code sections 186.34 and 186.35" is pending Department approval.

CSAO Recommendation 24 (b):Perform supervisory reviews of gangs and gang member entries;

LAPD Action Taken: Expanded review and Supervisory responsibilities will be detailed in a revised Special Order related to Special Order No. 15, May 22, 2013, (Cal/Gang System and Gang File Guidelines and Related Subsections). This will include a Department manual update.

CSAO Recommendation 24 (c):Implement policies and procedures for performing periodic Cal/Gang record reviews; sharing Cal/Gang information; and complying with Juvenile notification requirements;

LAPD Action Taken:

- In progress. Cal/Gang record review in progress.

- Completed. Sharing Cal/Gang information: A Detective Bureau Cal/Gang Proxy Login Notice dated August 23, 2016, and an accompanying Cal/Gang Telephonic Information Request Form (checklist) was written and published for Department use.

- In progress. The Department is complying with California State law regarding juvenile letter notification requirements. Additionally, a revised notification letter has been drafted and is pending Department approval. The revised notification letter contains expanded language, which complies with California state law.

CSAO Recommendation 24 (d):Recommendation No. 2 should be completed by March 31, 2017. [CSAO recommendation 24 (d) is the same as LAPD Recommendation No. 2 in LAPD's original response].

Action Taken: In progress.

A Chief of Detectives Notice was completed and is awaiting approval for compliance with changes to Penal Code (PC) 186.34 and the creation of PC 186.35. Upon approval of the Notice a Special Order will be completed, which will update Department policy to comply with changes to the law.

  • Estimated Completion Date: June 30, 2019
  • Response Date: February 2017

California State Auditor's Assessment of 6-Month Status: Pending


60-Day Agency Response

The Department is reviewing Assembly Bill 2298, which will have a direct impact on Cal/Gang policy and procedure related to adults.

There was an overall operational issue with one section of the 2007, California Attorney General's Model Standards and Procedures for Maintaining Criminal Intelligence Files and Criminal Intelligence Operational Activities guidelines. On page 38, section "V" (Auditing and Oversight), two Captains are required to annually audit the operations of the "Criminal Intelligence Section," which is equivalent to LAPDs GED, for compliance with [GED] standards and procedures related to criminal intelligence files and all documentation prepared by the sections.

The California Gang Node Advisory Committee (CGNAC) proposed to the Cal/Gang Executive Board that the Attorney Guidelines not be followed in its entirety because of this one issue. The Executive Board did not vote on this issue at the September 9, 2016, meeting. The next CGNAC meeting is scheduled for January 31, 2017, and this will be revisited.

Expanded review and Supervisory responsibilities will be detailed in a revised Special Order related to Special Order No. 15, May 22, 2013, (Cal/Gang System and Gang File Guidelines and Related Subsections). This will include a Department manual update. It is anticipated that the Matrices developed for the inspections will be approved for use at the upcoming bureau meeting in early October 2016.

  • Estimated Completion Date: March 31, 2017
  • Response Date: October 2016

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #25 To: Santa Ana Police Department

Until Santa Ana Police Department receives further direction from the board, the committee, or Justice, it should address the specific deficiencies we found by reviewing the gangs it has entered into CalGang to ensure the gangs meet reasonable suspicion requirements. It should also begin reviewing the gang members it has entered into CalGang to ensure the existence of proper support for each criterion. It should purge from CalGang any records for gangs or gang members that do not meet the criteria for entry. Individuals who are independent from the ongoing administration and use of CalGang should lead this review. The agency should complete the gang and gang member reviews in phases, with the final phase for gangs to be completed by June 30, 2018, and the final phase for gang members to be completed by June 30, 2019.

1-Year Agency Response

Audit Response - Review of Gangs and Gang Members

I. SAPD hired an employee to carry out the audit recommendations related to the review of gangs and gang members. The employee is now fully integrated and trained in the process and has started the review of criminal street gangs.

  • Completion Date: August 2017
  • Response Date: August 2017

California State Auditor's Assessment of 1-Year Status: Partially Implemented


Annual Follow-Up Agency Response From March 2017

I. The Santa Ana Police Department has hired an employee that will be dedicated to implementing the Cal State Auditor's recommendations.

II. SAPD currently has approximately 100 criminal street gangs. The reviewer will begin reviewing all 100 criminal street gangs to ensure their inclusion into CalGang met the reasonable suspicion requirements and have proper documentation to support their inclusion. This process will begin after the training of the non-sworn employee with an estimated completion on or before June 2018.

III. SAPD currently has in excess of 3,000 gang members and/or associates. The reviewer will begin reviewing all of the gang's active participants and ensure proper documentation supports their inclusion. Additionally, the documentation supports the criterion used for CalGang inclusion. This process will begin after item II has been completed with an estimated completion date on or before June 2019.

  • Estimated Completion Date: June 30, 2019

California State Auditor's Assessment of Annual Follow-Up Status: Pending


6-Month Agency Response

I. The Santa Ana Police Department has hired an employee that will be dedicated to implementing the Cal State Auditor's recommendations.

II. SAPD currently has approximately 100 criminal street gangs. The reviewer will begin reviewing all 100 criminal street gangs to ensure their inclusion into CalGang met the reasonable suspicion requirements and have proper documentation to support their inclusion. This process will begin after the training of the non-sworn employee with an estimated completion on or before June 2018.

III. SAPD currently has in excess of 3,000 gang members and/or associates. The reviewer will begin reviewing all of the gang's active participants and ensure proper documentation supports their inclusion. Additionally, the documentation supports the criterion used for CalGang inclusion. This process will begin after item II has been completed with an estimated completion date on or before June 2019.

  • Estimated Completion Date: June 2019
  • Response Date: February 2017

California State Auditor's Assessment of 6-Month Status: Pending


60-Day Agency Response

I. The Santa Ana Police Department is currently conducting a testing process to fill a non-sworn position within the Investigations Bureau. The Department will identify and select a non-sworn employee to be trained on CalGang procedures and review protocols. This employee will not be involved in the current administrative or operational CalGang process. The selection/hiring of the employee should occur within six months/on or before the six month review on February 11, 2017.

II. SAPD currently has approximately 100 criminal street gangs. The reviewer will begin reviewing all 100 criminal street gangs to ensure their inclusion into CalGang met the reasonable suspicion requirements and have proper documentation to support their inclusion. This process will begin after the selection, hiring, and training of the non-sworn employee. Start time estimated to be after February 11, 2017 with an estimated completion on or before June 2018.

III. SAPD currently has approximately 4,500 gang members and/or associates. The reviewer will begin reviewing all of the gang's active participants and ensure proper documentation supports their inclusion. Additionally, the documentation supports the criterion used for CalGang inclusion. This process will begin after the selection, hiring, and training of the non-sworn employee. Start time estimated to be February to June 2018 with an estimated completion date on or before June 2019.

  • Estimated Completion Date: June 2019
  • Response Date: October 2016

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #26 To: Santa Ana Police Department

Until Santa Ana Police Department receives further direction from the board, the committee, or Justice, it should address the specific deficiencies we found by developing or modifying as necessary all its policies and procedures related to CalGang to ensure they align with state law, CalGang policy, the federal regulations, and the state guidelines. In particular, the agency should implement appropriate policies and procedures for entering gangs; performing supervisory reviews of gang and gang member entries; performing periodic CalGang record reviews; sharing CalGang information; and complying with juvenile notification requirements. The agency should complete this recommendation by March 31, 2017.

1-Year Agency Response

Audit Response - Policy and Procedure

I. SAPD has fully implemented a policy and procedure for criminal intelligence systems.

II. The policy and procedure are designed to meet the required legal and policy mandates identified in the audit recommendations.

III. SAPD's policy and procedure identifies a systematic process for supervisory review and quality control review of gang and gang member entries into the CalGang system.

IV. The policy and procedure provides specific direction regarding CalGang entries and the adult and juvenile contestation processes.

V. SAPD is communicating the policy and procedure for criminal intelligence systems to all department personnel via internal communication and training platforms.

VI. SAPD will utilize the CalGang system's proxy features to track sharing of CalGang information.

VII. SAPD has developed and disseminated a refresher course regarding the CalGang Proxy Login Function to all current SAPD CalGang users. This function is covered in the CalGang User Certification Course provided by the node administrator. We are currently using an internal training platform to disseminate and track department training communicated electronically.

  • Completion Date: August 2017
  • Response Date: August 2017

California State Auditor's Assessment of 1-Year Status: Fully Implemented

We reviewed Santa Ana's August 2017 procedures and guidelines for shared gang databases, as well as related policies and trainings, and confirmed that this recommendation has been fully implemented as described by the agency in their one-year response.


Annual Follow-Up Agency Response From March 2017

I. The Santa Ana Police Department has developed a policy and procedure for criminal intelligence systems; specifically CalGang.

II. The Santa Ana Police Department's criminal intelligence systems (CalGang) procedure provides process for entering criminal street gangs into CalGang.

III. The Santa Ana Police Department's policy and procedure identifies a systematic process for supervisory review and quality control review of gang and gang member entries into CalGang.

IV. The Santa Ana Police Department will utilize CalGang's proxy feature to track sharing of CalGang information. SAPD CalGang users will receive annual training on this requirement/feature beginning April 2017.

V. The Santa Ana Police Department's juvenile notification forms have been revised to reflect amended law requirements.

VI. The Santa Ana Police Department's Criminal Intelligence Systems (CalGang) Policy and Procedure, and the revised juvenile notification form have been provided to the California State Auditor's Office.

  • Completion Date: April 2017

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

The criminal intelligence systems policy and procedures Santa Ana shared with us was in draft form. According to the Crimes Against Persons Commander, Santa Ana has implemented the procedures but anticipates modifying the policy and procedures as Santa Ana identifies areas needing improvement. The Commander stated that, once Santa Ana has worked through any issues with the policy and procedures, the Chief of Police will approve it and announce the policy department wide.


6-Month Agency Response

The previous recommendation update indicated completion dates in January 2017. Due to a delay in the hiring of new personnel, the January completion will be delayed until March 31, 2017.

The "Estimated Completion Date" of March 31, 2017 date will remain as our target date.

As of today, the Santa Ana Police Department has hired and assigned a dedicated employee to oversee the recommendations. This will improve the Department's capabilities to complete the recommendations and meet the deadline/target dates.

I. Create policy/procedure for Criminal Intelligence files. This process is already in progress and the fulfillment of this recommendation has an estimated completion date of March 2017.

II. Incorporate into the Lexipol procedure a systematic method for criminal street gang entries into CalGang and establish a supervisory review process for gangs and gang member inclusion. The fulfillment of this recommendation has an estimated completion date of March 2017.

III. Lexipol procedure will create a recurring CalGang entry and document review for gang and gang member entries. The fulfillment of this recommendation has an estimated completion date of March 2017.

IV. A database and/or spreadsheet will be utilized to track any criminal intelligence shared from CalGang by authorized internal and external partners. The fulfillment of this recommendation has an estimated completion date of March 2017.

V. A review of the current juvenile notification form language will be conducted. The fulfillment of this recommendation has an estimated completion date of March 2017.

  • Estimated Completion Date: March 31, 2017
  • Response Date: February 2017

California State Auditor's Assessment of 6-Month Status: Pending


60-Day Agency Response

I. Identify the appropriate Lexipol policy to use as a foundation for the Department's future policy. Collaborate with the City Attorney's Office to ensure policy align with state law, CalGang policy, the federal regulations, and the state guidelines. This process is already in progress and the fulfillment of this recommendation has an estimated completion date of January 2017.

II. Incorporate into the Lexipol procedure a systematic method for criminal street gang entries into CalGang and establish a supervisory review process for gangs and gang member inclusion. This process is already in progress as well and the fulfillment of this recommendation has an estimated completion date of January 2017.

III. Lexipol procedure will create a recurring CalGang entry and document review for gang and gang member entries. The fulfillment of this recommendation has an estimated completion date of February 2017.

IV. A database and/or spreadsheet will be utilized to track any criminal intelligence shared from CalGang by authorized internal and external partners. This process will also be included in the Lexipol procedure. The fulfillment of this recommendation has an estimated completion date of March 2017.

V. A review of the current juvenile notification form language will be conducted. A decision on whether to change the language (i.e., list specific activity used for inclusion) will be made to ensure the Department is in full compliance with the law. The fulfillment of this recommendation has an estimated completion date of January 2017.

  • Estimated Completion Date: March 2017
  • Response Date: October 2016

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #27 To: Santa Clara County Sheriff's Office

Until Santa Clara County Sheriff's Office receives further direction from the board, the committee, or Justice, it should address the specific deficiencies we found by reviewing the gangs it has entered into CalGang to ensure the gangs meet reasonable suspicion requirements. It should also begin reviewing the gang members it has entered into CalGang to ensure the existence of proper support for each criterion. It should purge from CalGang any records for gangs or gang members that do not meet the criteria for entry. Individuals who are independent from the ongoing administration and use of CalGang should lead this review. The agency should complete the gang and gang member reviews in phases, with the final phase for gangs to be completed by June 30, 2018, and the final phase for gang members to be completed by June 30, 2019.

1-Year Agency Response

We are currently updating our policies and procedures to ensure we have a clear supervision of the information being entered into the system. The new procedures will also include sending notifications to adults and juveniles as required by law.

We have identified our Records Division as the independent body to review entries. Implementation will begin in early 2018.

  • Estimated Completion Date: Spring 2018
  • Response Date: August 2017

California State Auditor's Assessment of 1-Year Status: Pending


6-Month Agency Response

WE are currently working on updating our agencies policies and procedures.

  • Estimated Completion Date: 08/01/2017
  • Response Date: March 2017

California State Auditor's Assessment of 6-Month Status: Pending


60-Day Agency Response

The Sheriff's Office Records Administration will identify a staff member from the Records Division (independent from the ongoing administration). The Records staff member will review the information entered into CalGang and identify records that need to be purged.

  • Estimated Completion Date: March 2017
  • Response Date: October 2016

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #28 To: Santa Clara County Sheriff's Office

Until Santa Clara County Sheriff's Office receives further direction from the board, the committee, or Justice, it should address the specific deficiencies we found by developing or modifying as necessary all its policies and procedures related to CalGang to ensure they align with state law, CalGang policy, the federal regulations, and the state guidelines. In particular, the agency should implement appropriate policies and procedures for entering gangs; performing supervisory reviews of gang and gang member entries; performing periodic CalGang record reviews; sharing CalGang information; and complying with juvenile notification requirements. The agency should complete this recommendation by March 31, 2017.

1-Year Agency Response

We are currently updating our policies and procedures to ensure we have a clear supervision of the information being entered into the system. The new procedures will also include sending notifications to adults and juveniles as required by law.

  • Estimated Completion Date: 12/01/2017
  • Response Date: August 2017

California State Auditor's Assessment of 1-Year Status: Pending


6-Month Agency Response

We are currently updating our policies and procedures to ensure we have a clear supervision of the information being entered into the system. The new procedures will also include sending notifications to juveniles as required by law.

  • Estimated Completion Date: 08/01/2017
  • Response Date: March 2017

California State Auditor's Assessment of 6-Month Status: Pending


60-Day Agency Response

The Sheriff's Office Records Administration will identify a staff member from the Records Division (independent from the ongoing administration). The Records staff member will review the information entered into CalGang and identify records that need to be purged.

The Santa Clara County Sheriff's Office Special Operations Division Administration is in the process of updating the existing policies and procedures related to CalGang to ensure we are in alignment with state law, CalGang policy, federal regulations, and the state guidelines.

  • Estimated Completion Date: March 2017
  • Response Date: October 2016

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #29 To: Sonoma County Sheriff's Office

Until Sonoma County Sheriff's Office receives further direction from the board, the committee, or Justice, it should address the specific deficiencies we found by reviewing the gangs it has entered into CalGang to ensure the gangs meet reasonable suspicion requirements. It should also begin reviewing the gang members it has entered into CalGang to ensure the existence of proper support for each criterion. It should purge from CalGang any records for gangs or gang members that do not meet the criteria for entry. Individuals who are independent from the ongoing administration and use of CalGang should lead this review. The agency should complete the gang and gang member reviews in phases, with the final phase for gangs to be completed by June 30, 2018, and the final phase for gang members to be completed by June 30, 2019.

6-Month Agency Response

As of December 31, 2016, the Sonoma County Sheriff's Office terminated from CalGang as a user and node administrator. All Sheriff's Office records have been purged from CalGang. Although the Sonoma County Sheriff's Office believes that the CalGang database is a valuable and successful tool in combating gang related crimes, we simply cannot continue to provide unlimited resources towards meeting the recommendations and new legal requirements.

  • Response Date: January 2017

California State Auditor's Assessment of 6-Month Status: Will Not Implement

As indicated in the Sheriff Office's response, it terminated its use of CalGang.


60-Day Agency Response

The Sonoma County Sheriff's Office is reviewing all aspects of the recommendation and working with the California Gang Node Advisory Committee (CGNAC) and the CalGang Executive Board (CEB). By the next recommendation update, we hope to have a comprehensive plan.

  • Estimated Completion Date: 6/30/2018
  • Response Date: October 2016

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #30 To: Sonoma County Sheriff's Office

Until Sonoma County Sheriff's Office receives further direction from the board, the committee, or Justice, it should address the specific deficiencies we found by developing or modifying as necessary all its policies and procedures related to CalGang to ensure they align with state law, CalGang policy, the federal regulations, and the state guidelines. In particular, the agency should implement appropriate policies and procedures for entering gangs; performing supervisory reviews of gang and gang member entries; performing periodic CalGang record reviews; sharing CalGang information; and complying with juvenile notification requirements. The agency should complete this recommendation by March 31, 2017.

6-Month Agency Response

As of December 31, 2016, the Sonoma County Sheriff's Office terminated from CalGang as a user and node administrator. All Sheriff's Office records have been purged from CalGang. Although the Sonoma County Sheriff's Office believes that the CalGang database is a valuable and successful tool in combating gang related crimes, we simply cannot continue to provide unlimited resources towards meeting the recommendations and new legal requirements.

  • Response Date: January 2017

California State Auditor's Assessment of 6-Month Status: Will Not Implement

As indicated in the Sheriff Office's response, it terminated its use of CalGang.


60-Day Agency Response

The Sonoma County Sheriff's Office is working with the California Gang Node Advisory Committee (CGNAC) and the CalGang Executive Board (CEB). CalGang® Policy is a matter of system-wide import and should come from the CalGang Executive Board so all individual agencies policies and procedures are consistent. A sub-committee was formed to discuss implementation procedures. By the next recommendation update, we hope to have a comprehensive plan.

  • Estimated Completion Date: 3/31/2017
  • Response Date: October 2016

California State Auditor's Assessment of 60-Day Status: Pending


All Recommendations in 2015-130

Agency responses received are posted verbatim.


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