Report 2021-105 Recommendation 59 Responses

Report 2021-105: Law Enforcement Departments Have Not Adequately Guarded Against Biased Conduct (Release Date: April 2022)

Recommendation #59 To: Stockton Police Department

To proactively identify signs that officers may need additional training or supports to address possible biased behavior, Stockton Police should, by April 2023, adopt a policy and implement procedures that align with best practices for an effective early intervention system. The system should do the following:
- Track and incorporate data at the officer level related to complaints, uses of force, and other indicators as appropriate, and use these data to identify officers who could benefit from early intervention. The system should include analysis of stops data that identifies officers based on indications of possible biased conduct.
- Specify a range of early intervention options—such as trainings, mentoring or other supervisory approaches, mental health services, or reassignment—with guidance about how to apply them to the particular circumstances of each officer's conduct. The system should require prompt interventions that address the identified issues with or patterns in the officers' conduct, including conduct related to bias.
- Require monitoring of the officers who receive intervention to evaluate whether their performance improves or whether additional interventions are needed.

Annual Follow-Up Agency Response From April 2026

SPD has deployed a fully integrated Early Intervention System (EIS) to proactively identify performance concerns and potential indicators of bias. This system is supported by updated policies, modernized software platforms, and enhanced supervisory training.

Policy 1028 - Early Warning System

- Effective Date: June 28, 2024

- Establishes procedures for identifying early indicators of concern among department members.

Policy 1045 - Performance Tracking

- Effective Date: June 28, 2024

- Purpose (citation): "The department should collect the performance data of its members to identify trends within the department for use in policy development, establishing best practices, and assembling training recommendations."

Systems Implemented

SPD's EIS is fully operational through the following platforms:

- IAPro - Implemented August 2023

- BlueTeam - Implemented September 2023

- EIPro - Implemented October 2023 (no longer operational, replaced with First Sign by Benchmark Analytics)

- First Sign - Implemented September 2025 (replaced EIPro)

These systems track:

- Use of force

- Complaints

- Pursuits

- Behavioral concerns

- Other performance indicators

Automatic threshold alerts prompt supervisory review and intervention.

Newly promoted supervisors receive training on:

- Proper use of IAPro and BlueTeam

- Bias awareness

- Documentation and escalation procedures

- POST Certified Supervisor School

- POST Certified Management School

These measures ensure consistent documentation, early identification of concerns, and timely intervention.

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

The policies that Stockton cites in its response are not in alignment with our recommendation. Specifically, the policies do not address our recommendation for SPD to include stops data as part of the early intervention system, for the policies around the early intervention system to identify a range of intervention options, and for the early intervention system policies to include continuous monitoring of officers identified as needing early intervention to determine if additional intervention is necessary.

Annual Follow-Up Agency Response From October 2023

The Stockton Police Department is updating its policies through Lexipol, a platform representing nationwide standards and best practices. There will be a new early intervention system policy.

For the past several months, the Professional Standards Section has been in the process of implementing a new program (IAPro/Blue Team/EIPro) that is robust and will incorporate data from several categories, such as officers' use of force, Officer-involved shootings, on-duty vehicle accidents, vehicle pursuits, internal and external complaints, inquiries related to behavioral concerns, etc. IAPro and Blue Team were implemented in August and September 2023. EIPro (Early Intervention) is a system that became operative in October 2023.

This information has thresholds set, and if a police officer passes any threshold, it will alert to review the data to see if early intervention is warranted.

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

We look forward to reviewing Stockton's updated policies and procedures regarding its early intervention system when Stockton submits them.

All Recommendations in 2021-105

Agency responses received are posted verbatim.