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Compliance with CFR 28 Part 23 Criminal Intelligence Systems Operating Policies

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As a guide for those interested in criminal intelligence systems such as IntelNexus™, Crime Tech Weekly is publishing the following overview of Title 28, Part 23 of the Code of Federal Regulations (CFR 28 Part 23). The policy reads as follows:

CFR 28 PART 23–CRIMINAL INTELLIGENCE SYSTEMS OPERATING POLICIES
1. Purpose.
2. Background.
3. Applicability.
4. Operating principles.
5. Funding guidelines.
6. Monitoring and auditing of grants for the funding of intelligence systems.

1 Purpose.
The purpose of this regulation is to assure that all criminal intelligence systems operating through support under the Omnibus Crime Control and Safe Streets Act of 1968 are utilized in conformance with the privacy and constitutional rights of individuals.

2 Background.
It is recognized that certain criminal activities including but not limited to loan sharking, drug trafficking, trafficking in stolen property, gambling, extortion, smuggling, bribery, and corruption of public officials often involve some degree of regular coordination and permanent organization involving a large number of participants over a broad geographical area. The exposure of such ongoing networks of criminal activity can be aided by the pooling of information about such activities. However, because the collection and exchange of intelligence data necessary to support control of serious criminal activity may represent potential threats to the privacy of individuals to whom such data relates, policy guidelines for Federally funded projects are required.

3 Applicability.
(a) These policy standards are applicable to all criminal intelligence systems operating through support under the Omnibus Crime Control and Safe Streets Act of 1968.

(b) As used in these policies: Criminal Intelligence System or Intelligence System means the arrangements, equipment, facilities, and procedures used for the receipt, storage, interagency exchange or dissemination, and analysis of criminal intelligence information; Inter-jurisdictional Intelligence System means an intelligence system which involves two or more participating agencies representing different governmental units or jurisdictions; Criminal Intelligence Information means data which has been evaluated to determine that it: (i) is relevant to the identification of and the criminal activity engaged in by an individual who or organization which is reasonably suspected of involvement in criminal activity, and (ii) meets criminal intelligence system submission criteria; Participating Agency means an agency of local, county, State, Federal, or other governmental unit which exercises law enforcement or criminal investigation authority and which is authorized to submit and receive criminal intelligence information through an inter-jurisdictional intelligence system. A participating agency may be a member or a nonmember of an inter-jurisdictional intelligence system; Intelligence Project means the organizational unit which operates an intelligence system on behalf of and for the benefit of a single agency or the organization which operates an inter-jurisdictional intelligence system on behalf of a group of participating agencies; and Validation of Information means the procedures governing the periodic review of criminal intelligence information to assure its continuing compliance with system submission criteria established by regulation or program policy.

us-constitution4 Operating principles.
(a) A project shall collect and maintain criminal intelligence information concerning an
individual only if there is reasonable suspicion that the individual is involved in criminal conduct or activity and the information is relevant to that criminal conduct or activity.

(b) A project shall not collect or maintain criminal intelligence information about the political, religious or social views, associations, or activities of any individual or any group, association, corporation, business, partnership, or other organization unless such information directly relates to criminal conduct or activity and there is reasonable suspicion that the subject of the information is or may be involved in criminal conduct or activity.

(c) Reasonable Suspicion or Criminal Predicate is established when information exists which establishes sufficient facts to give a trained law enforcement or criminal investigative agency officer, investigator, or employee a basis to believe that there is a reasonable possibility that an individual or organization is involved in a definable criminal activity or enterprise. In an inter-jurisdictional intelligence system, the project is responsible for establishing the existence of reasonable suspicion of criminal activity either through examination of supporting information submitted by a participating agency or by delegation of this responsibility to a properly trained participating agency which is subject to routine inspection and audit procedures established by the project.

(d) A project shall not include in any criminal intelligence system information which has been obtained in violation of any applicable Federal, State, or local law or ordinance. In an inter-jurisdictional intelligence system, the project is responsible for establishing that no information is entered in violation of Federal, State, or local laws, either through examination of supporting information submitted by a participating agency or by delegation of this responsibility to a properly trained participating agency which is subject to routine inspection and audit procedures established by the project.

(e) A project or authorized recipient shall disseminate criminal intelligence information only where there is a need to know and a right to know the information in the performance of a law enforcement activity.

(f) (1) Except as noted in paragraph (f) (2) of this section, a project shall disseminate criminal intelligence information only to law enforcement authorities who shall agree to follow procedures regarding information receipt, maintenance, security, and dissemination which are consistent with these principles. (2) Paragraph (f) (1) of this section shall not limit the dissemination of an assessment of criminal intelligence information to a government official or to any other individual, when necessary, to avoid imminent danger to life or property.

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(g) A project maintaining criminal intelligence information shall ensure that administrative, technical, and physical safeguards (including audit trails) are adopted to insure against unauthorized access and against intentional or unintentional damage. A record indicating who has been given information, the reason for release of the information, and the date of each dissemination outside the project shall be kept. Information shall be labeled to indicate levels of sensitivity, levels of confidence, and the identity of submitting agencies and control officials. Each project must establish written definitions for the need to know and right to know standards for dissemination to other agencies as provided in paragraph (e) of this section. The project is responsible for establishing the existence of an inquirer’s need to know and right to know the information being requested either through inquiry or by delegation of this responsibility to a properly trained participating agency which is subject to routine inspection and audit procedures established by the project. Each intelligence project shall assure that the following security requirements are implemented: (1) Where appropriate, projects must adopt effective and technologically advanced computer software and hardware designs to prevent unauthorized access to the information contained in the system; (2) The project must restrict access to its facilities, operating environment and documentation to organizations and personnel authorized by the project; (3) The project must store information in the system in a manner such that it cannot be modified, destroyed, accessed, or purged without authorization; (4) The project must institute procedures to protect criminal intelligence information from unauthorized access, theft, sabotage, fire, flood, or other natural or manmade disaster; (5) The project must promulgate rules and regulations based on good cause for implementing its authority to screen, reject for employment, transfer, or remove personnel authorized to have direct access to the system; and (6) A project may authorize and utilize remote (off-premises) system data bases to the extent that they comply with these security requirements.

(h) All projects shall adopt procedures to assure that all information which is retained by a project has relevancy and importance. Such procedures shall provide for the periodic review of information and the destruction of any information which is misleading, obsolete or otherwise unreliable and shall require that any recipient agencies be advised of such changes which involve errors or corrections. All information retained as a result of this review must reflect the name of the reviewer, date of review and explanation of decision to retain. Information retained in the system must be reviewed and validated for continuing compliance with system submission criteria before the expiration of its retention period, which in no event shall be longer than five (5) years.

(i) If funds awarded under the Act are used to support the operation of an intelligence system, then: (1) No project shall make direct remote terminal access to intelligence information available to system participants, except as specifically approved by the Office of Justice Programs (OJP) based on a determination that the system has adequate policies and procedures in place to insure that it is accessible only to authorized systems users; and (2) A project shall undertake no major modifications to system design without prior grantor agency approval.

audit-400x400(j) A project shall notify the grantor agency prior to initiation of formal information exchange procedures with any Federal, State, regional, or other information systems not indicated in the grant documents as initially approved at time of award.

(k) A project shall make assurances that there will be no purchase or use in the course of the project of any electronic, mechanical, or other device for surveillance purposes that is in violation of the provisions of the Electronic Communications Privacy Act of 1986, Public Law 99-508, 18 U.S.C. 2510-2520, 2701-2709 and 3121-3125, or any applicable State statute related to wiretapping and surveillance.

(l) A project shall make assurances that there will be no harassment or interference with any lawful political activities as part of the intelligence operation.

(m) A project shall adopt sanctions for unauthorized access, utilization, or disclosure of
information contained in the system.

(n) A participating agency of an inter-jurisdictional intelligence system must maintain in its agency files information which documents each submission to the system and supports compliance with project entry criteria. Participating agency files supporting system submissions must be made available for reasonable audit and inspection by project representatives. Project representatives will conduct participating agency inspection and audit in such a manner so as to protect the confidentiality and sensitivity of participating agency intelligence records.

(o) The Attorney General or designee may waive, in whole or in part, the applicability of a particular requirement or requirements contained in this part with respect to a criminal intelligence system, or for a class of submitters or users of such system, upon a clear and convincing showing that such waiver would enhance the collection, maintenance or dissemination of information in the criminal intelligence system, while ensuring that such system would not be utilized in violation of the privacy and constitutional rights of individuals or any applicable state or federal law.
federal-funds5 Funding guidelines.
The following funding guidelines shall apply to all Crime Control Act funded discretionary assistance awards and Bureau of Justice Assistance (BJA) formula grant program subgrants, a purpose of which is to support the operation of an intelligence system. Intelligence systems shall only be funded where a grantee/subgrantee agrees to adhere to the principles set forth above and the project meets the following criteria:

(a) The proposed collection and exchange of criminal intelligence information has been
coordinated with and will support ongoing or proposed investigatory or prosecutorial activities relating to specific areas of criminal activity.

(b) The areas of criminal activity for which intelligence information is to be utilized represent a significant and recognized threat to the population and: (1) Are either undertaken for the purpose of seeking illegal power or profits or pose a threat to the life and property of citizens; and (2) Involve a significant degree of permanent criminal organization; or (3) Are not limited to one jurisdiction.

(c) The head of a government agency or an individual with general policy making authority who has been expressly delegated such control and supervision by the head of the agency will retain control and supervision of information collection and dissemination for the criminal intelligence system. This official shall certify in writing that he or she takes full responsibility and will be accountable for the information maintained by and disseminated from the system and that the operation of the system will be in compliance with the principles set forth in 23.20.

(d) Where the system is an inter-jurisdictional criminal intelligence system, the governmental agency which exercises control and supervision over the operation of the system shall require that the head of that agency or an individual with general policymaking authority who has been expressly delegated such control and supervision by the head of the agency: (1) assume official responsibility and accountability for actions taken in the name of the joint entity, and (2) certify in writing that the official takes full responsibility and will be accountable for insuring that the information transmitted to the inter-jurisdictional system or to participating agencies will be in compliance with the principles set forth in 23.20. The principles set forth in 0 23.20 shall be made part of the by-laws or operating procedures for that system. Each participating agency, as a condition of participation, must accept in writing those principles which govern the submission, maintenance and dissemination of information included as part of the inter-jurisdictional system.

(e) Intelligence information will be collected, maintained and disseminated primarily for State and local law enforcement efforts, including efforts involving Federal participation.

6 Monitoring and auditing of grants for the funding of intelligence systems.
(a) Awards for the funding of intelligence systems will receive specialized monitoring and audit in accordance with a plan designed to insure compliance with operating principles as set forth in 23.20. The plan shall be approved prior to award of funds.

(b) All such awards shall be subject to a special condition requiring compliance with the
principles set forth in 23.20.

(c) An annual notice will be published by OJP which will indicate the existence and the objective of all systems for the continuing inter-jurisdictional exchange of criminal intelligence information which are subject to the 28 CFR Part 23 Criminal Intelligence Systems Policies.

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black versionCrime Tech Solutions is a leading provider of criminal intelligence database management software for 28 CFR Part 23 compliance. The company also develops Case Closed™ investigation case management software, sophisticated link analysis software, and advanced crime analytics.

The Sunny Side of Cloud-Based Solutions

shutterstock-cloud-computingCloud computing for law enforcement, in simple terms, refers to software hosted off-agency and available to the user through their internet connection. This type of software-as-a-service, or “SaaS” offers several advantages over software that is hosted locally on the user’s hardware.

Computer hardware is always being tweaked and improved upon, and state-of-the-art equipment can become obsolete extremely quickly in this environment. Many vital pieces of software that law enforcement rely on can be extremely demanding of hardware resources. With cloud-based software solutions, the software and the hardware required to run it are maintained offsite. The agency users simply access the software through an internet browser on a computer or smart phone, and have access to all the functionality of the software with none of the costs or hassle involved in hosting locally. These costs also include maintenance and security. 

Cloud-based solutions also allow for software to be more portable, as the software can be easily and readily accessed by any user with a smart phone. In addition, compatibility across platforms becomes less of an issue, as the software only needs an internet browser to function. This means law enforcement officials can seamlessly move from using a MacBook at work, to their Windows Phone at lunch, to a Linux based PC at home, without having three separate installs with varying functionality. 

cloud-computing-benefitThere are some things to look out for. While having software and hardware off-site offers great advantages, it’s important to note that data is hosted off-site as well. It’s important to carefully navigate the terms of use and make certain that the agency is not signing away the rights to important, classified, or proprietary data. 

Still, the major advantages of cloud-based software make it a powerful and very accessible tool for law enforcement. The simplicity and ease of access are defining characteristics of the cloud-based revolution.

A Look at Digital Policing

For law enforcement and other police service agencies, the ability to rapidly manage and interpret massive amounts of data is of paramount importance. Front line officers require timely and accurate data that enables intelligence-led decision making, and officers must be deployed proactively in order to deter and prevent criminal behavior.

abmpegasus-intelligence-led-policingAs we have written before, the true lifeblood of effective policing is data. With disparate and poorly integrated systems, however, the intelligence that can be gleaned from that data is mitigated. The information is too often hidden or lost.

In order to better utilize data – coming from sources such as Records Management Systems, Computer Aided Dispatch, Criminal Intelligence Systems, and other such repositories – innovative law enforcement agencies turn to technology-agnostic, scalable analytics platforms which blend historical and real-time data to both solve today’s crimes and predict tomorrow’s. Supported by purpose-built law enforcement analytics, agencies can keep pace with growing volumes of data and stay one step ahead of the criminals via actionable insights.

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For disparate data to be transformed to actionable insights, law enforcement agencies must deal with several challenges:

  • Timeliness – Unlike fine wine, data tends to lose value over time. Crime happens in real time, and what was the case six months ago may not be the case today.
  • Reliability – The data absolutely must be trusted by the officers entrusted with using it.
  • Fragmentation – If the data is overly fragmented or otherwise unavailable, it becomes cumbersome to use and holds little value.
  • Auditability – Without a clear and recognized audit trail, agencies are not able to effectively track the decisions made in the field versus what the analytics pointed to.

5WAn analytics solution helps blend data from disparate sources in order to provide officers with a trusted, single view of the truth. Simply put, the right analytics software will help agencies manage the challenges above.

While there has been a ton of negative news related to predictive policing, recently, using an analytics platform approach allows agencies to consolidate, analyze, and utilize ALL of their data. This analysis can – and does – help agencies become more efficient and more effective.

Wynyard Group’s slow, painful death arrives. Now, what about the customers?

October 28, 2016 – Crime Tech Solutions, a fast-growing and vibrant investigation software company based in Austin, TX, today announced a migration path for software users affected by the recent failure of New Zealand based Wynyard Group. Wynyard had positioned itself as a ‘leader in crime fighting software’, but never did find traction in the markets they coveted.

wynyardfailPer Wynyard Group officials, the company has placed itself in voluntary administration as it battles crippling losses and missed revenue forecasts, leaving customers in the dark as to the future of their investment in the crime fighting technology.

For users of the Wynyard Group case management software, Crime Tech Solutions has introduced a comprehensive ‘path forward’ that includes, in some cases, a license-cost-free replacement of the Wynyard Group system with the popular and robust Case Closed™ investigative case management solution for law enforcement and commercial investigation agencies.

Case Closed Software was developed by investigation professionals and for investigation professionals, and is widely used by investigative agencies across North America.

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“The objective”, said Crime Tech Solutions’ CTO Keith Weigand, “is to provide Case Closed software licenses to interested customers in exchange for the monies they already pay in annual maintenance and support.”

Tyler Wood, Operations Manager at Crime Tech Solutions, added “In essence, it’s a way to put what we think is better case management software into customers’ hands without the need to pay for expensive new software licenses.” While Wood acknowledges that there are internal costs associated with converting to any new solution, he feels that the intuitive and flexible nature of Case Closed is designed to mitigate those costs as much as possible.

About Crime Tech Solutions

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Case Closed Software is developed and supported by fast-growing Crime Tech Solutions

 

Crime Tech Solutions  is a low price / high performance innovator in crime analytics and law enforcement crime-fighting software. The clear price/performance leader for crime fighting software, the company’s offerings include Case Closed™ investigative case management and major case management, GangBuster™ gang intelligence software, powerful Sentinel Visualizer link analysis software, evidence managementmobile applications for law enforcement, comprehensive crime analytics with mapping and predictive policing, and 28 CFR Part 23 compliant criminal intelligence database management systems.

Overland Park senior crime analyst Jamie May joins Crime Tech Solutions

September 16, 2016 – (Leander, TX)  Crime Tech Solutions, a fast-growing provider of low cost / high performance crime fighting software and analytics is delighted to announce the addition of Jamie May as senior analyst and strategic advisor to the company.

jamiemayMs. May has spent over 17 years as a crime and intelligence analyst for Overland Park Police Department in Kansas, and is a recognized expert in crime analysis, mapping, and criminal intelligence. She has sat on critical crime analysis committees including the International Association of Crime Analysts’ Ethics Committee (IACA) and is a past Vice President / Secretary at Mid American Regional Crime Analyst Network (MARCAN).

“Jamie brings an incredible amount of user experience and innovation to the company”, said Kevin Konczal, Crime Tech Solutions’ VP of Sales. “She’s been active in this community for years, and co-authored the ground-breaking guide, GIS in Law Enforcement: Implementation Issues and Case Studies.”

“To me, Crime Tech Solutions represents a truly innovative company that understands how to develop and market very good technology at prices that most agencies can actually afford”, said Ms. May. “I’m looking forward to being part of the continued growth here.”

In her role with the company, Ms. May will interact with customers and prospects to help align the company’s solution strategy with market and user requirements.

black versionCrime Tech Solutions, who earlier this year acquired TN based Case Closed Software, delivers unique value to customers with comprehensive investigative case management software, sophisticated link analysis tools, criminal intelligence management software, and crime mapping technology that includes some of the industry’s best analytics and reporting capabilities.

 

 

 

 

Using crime analysis solutions to take a ‘Byte’ out of crime

_KOK1002_RTCC+(3)Posted by Crime Tech Solutions 

Law enforcement agencies everywhere are tasked with reducing and investigating crime with fewer and fewer resources at their disposal. “To protect and serve” is the highest responsibilities one can sign up for, particularly in light of recent well-publicized criticisms of police by activists in every city.

That responsibility weighs even heavier in a world with no shortage of criminals and terrorists. There’s never enough money in the budget to adequately deal with all of the issues that face an individual agency on a daily basis. Never enough feet on the street, as they say.

New Tools for Age-Old Problems

Perhaps that’s why agencies everywhere are moving to fight crime with an evolving 21st century weapon – law enforcement software including investigative case management, link and social network analysis, and, importantly, crime analytics with geospatial and temporal mapping.

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Crime analytics and investigation software have proven themselves to be valuable tools in thwarting criminal activity by helping to better define resource allocation, target investigations more accurately, and enhancing public safety,

According to some reports, law enforcement budgets have been reduced by over 80% since the early 2000s. Still, agencies are asked to do more and more, with less and less.

Analytics in Policing

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Predictive Analytics for Policing

Analytics in law enforcement  play a key role in helping law enforcement agencies better forecast what types of crimes are most likely to occur in a certain area within a certain window of time. While no predictive analytics solution offers the clarity of a crystal ball, they can be effective in affecting crime reduction and public safety.

Predictive analysis, in essence, is taking data from disparate sources, analyzing them and then using the results to anticipate, prevent and respond more effectively to future crime. Those disparate data sources typically include historical crime data from records management systems, calls for service/dispatch information, tip lines, confidential informant information, and specialized criminal intelligence data.

The Five W’s of Predictive Analytics

Within this disparate data lie the 5 W’s of information that can be used by crime analysis software to build predictions. Those key pieces include:

  1. Arrest records – who committed crimes
  2. Geospatial data – where crimes have occurred
  3. Temporal data – when crimes have occurred
  4. Statistical data – what crimes have occurred
  5. Investigation data – why (and how) the crimes occurred

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Using the 5 W’s, agencies are able to gain insight and make predictions about likely future criminal behavior. For example, if a certain type of crime (what) tends to occur in ‘this’ area (where) at ‘this’ time (when), and by ‘this’ type of individual (who) for ‘this’ reason (why)… it would be wise to deploy resources in that area at that time in order to prevent the incidents from ever occurring. This, of course, is a dramatic over-simplification of the types of analytics that make up predictive policing, but illustrates the general concept well.

Although criminals will always try to be one step ahead of the law, agencies deploying predictive analytics are able to maximize the effectiveness of its staff and other resources, increasing public safety, and keeping bad guys off the street.

More about Crime Tech Solutionsblack version

Crime Tech Solutions is an Austin, TX based provider of crime and fraud analytics software for commercial and law enforcement groups. Our offerings include sophisticated Case Closed™ investigative case management and major case management, GangBuster™ gang intelligence software, powerful link analysis software, evidence management, mobile applications for law enforcement, comprehensive crime analytics with mapping and temporal reporting, and 28 CFR Part 23 compliant criminal intelligence database management systems.

Data continues to influence policing

Great article by Megan Favignano at New Press Now. Original article at http://www.newspressnow.com/news/local_news/data-continues-to-influence-policing/article_ef968ba2-389c-5289-b341-a9818ae231d7.html

A copy of the article follows:

5WA recent report questions how some police departments are using data to forecast future crimes.

The report examined how departments are utilizing predictive policing, a computer software that uses data to forecast where crime may happen, who may commit it and who could be potential victims.

Logan Koepke, an analyst who coauthored the report, said the handful of departments that use the software don’t appear to give patrol officers much guidance on what to do with the information provided.

“One problem we’ve seen is there is not a lot of direction from police departments or from vendors about what officers in the field should do once they look at a prediction,” Koepke said.

Upturn, an analysis organization out of Washington, D.C., that works with a variety of groups, published the report “Stuck in a Pattern” last month. “Predictive policing,” the report states, is a marketing term popularized by vendors who sell the software.

The group’s research showed areas that use the software often don’t engage the public in discussion about predictive policing and questioned whether or not departments who use it are measuring the impact the data-driven tool has on policing and crime rates.

AnalyticsHow police departments nationwide utilize crime statistics and the software available to patrol officers monitoring incidents has evolved a lot in the past couple decades, Sgt. Tracy Barton with the St. Joseph Police Department said. Barton started as a patrol officer 20 years ago. He said having software like police have today would have been useful.

“I was in District 7, which is the Midtown area. It would have been really cool to know where crime is occurring in District 7 and that I could look that up on a computer and have it at my fingertips where I could see it on an up-to-date basis,” Barton said.

In the past, crime analysts used physical maps and mathematical algorithms to do what software does instantly today. Barton, the St. Joseph Police Department’s crime analyst, uses software that takes into account crimes reported to police to show crime hot spots in the city. A map of those hot spots is available online. Officers, he said, have access to a more in-depth version of that hot spots map, which includes extra details about the area and the crimes occurring.

The hot spots approach St. Joseph police use is most helpful in preventing crime when a series of crimes occur or when there is a crime pattern in a given area, he said. St. Joseph’s small size, Barton added, poses an extra challenge.

Crime analytics Mapping Predicitive Policing

The St. Joseph Police Department has had its current software for just a few years. It doesn’t fit the definition of the predictive policing software Upturn outlines in the recent report. The software used locally depends on crime reports police receive. Predictive policing also looks at what types of business are located in an area, if repeat offenders live nearby and other information to predict where crimes may occur. Typically, according to the recent report, predictive policing takes one of two approaches, focusing either on place-based data or person-based data to make predictions.

Kevin Bryant, sociology and criminology professor at Benedictine College, said when people hear predictive policing described, they often think of the movie “Minority Report.” The software, he said, is nothing like in the movies.

“Predictive policing now has kind of morphed into better proactive methods that are based on prediction to some extent in forecasting risk,” Bryant said of how data-driven policing has changed over time. “But what we’ve learned through evaluation studies is that it’s really more important what the police do when they’re in a crime hot spot.”

Ba10ryant worked with the Shawnee, Kansas, Police Department on research that looked at what he calls “smart policing.” In his research and in other work he has read, Bryant said it’s important for police to have a high visibility in crime hot spots, for officers to make connections with the public and for them to avoid staying in crime hot spots for extended periods of time.

When police are in a hot spot for too long, public surveys show area residents feel like they are being picked on rather than protected, he said. Predictive policing takes into account businesses in a given area. Bryant said some types of facilities are at a higher risk of victimization and others can attract crime to an area.

“Knowing where bars, taverns, restaurants, gas stations, convenience stores are, we can actually use their locations as a means of forecasting where crime might emerge at a later date,” Bryant said. “Part of predictive policing is predicting who the risky offenders are and that can be controversial.”

Upturn’s report also explored an ongoing debate among criminologists on the impact of using crime reports when determining patrol.

“Criminologists have long emphasized that crime reports and other statistics gathered by the police are not an accurate record of the crime that happens in a community,” the report states.

Police statistics, Koepke said, reflect officer enforcement efforts, not just crime.

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