Joint Response to Public Comment Pursuant to DGO 3.01.04(D)
DGO 5.20 Language Access Services
SFPD Department General Order (DGO) 3.01 requires that all policies under development be posted publicly to provide members of the public thirty (30) business days to submit policy recommendations.
Pursuant to DGO 3.01.04 (D), the Department and the Department of Police Accountability (DPA) jointly prepare a public response, which shall be posted on the Department’s website, outlining the recommendations included and not included in the DGO draft submitted to the Police Commission.
Joint responses are captured in the following recommendation grid, which captures the original recommendation, whether the recommendation was included or not included in the draft DGO, and the explanation relating to the decision to include or not include the recommendation in the draft DGO.
The Department reserves the right to remove or not respond to comments if they are:
- Unrelated to the subject of the DGO
- Include private personal information (whether the commenter’s or someone else’s), including home address, home or cell phone number, personal e-mail address, or personal identification.
- Include profanity or obscene language
| # | PUBLIC COMMENT | DATE RECEIVED | SFPD RESPONSE | SFPD EXPLANATION | DPA EXPLANATION |
|---|---|---|---|---|---|
| R1 | The purpose is very wordy and cites sources unlike any other DGO | 2/5/25 | Recommendation has been included in draft DGO | The purpose section has been revised for clarity and conciseness and the citations removed. | agree w/ sfpd. |
| R2 | the definition for certified bilingual member, the second sentence does not make sense here, as this is the definitions section about already trained members and not about training | 2/5/25 | Recommendation has been included in draft DGO | The definition for certified bilingual member has been amended to state "A sworn member who is certified by DHR or other designated qualifying agency to provide interpretation services." | agree w/ sfpd. |
| R3 | A lot of this DGO uses vague language that makes it not concise. For example: "Members can use various tools to identify the primary language..." Just list the tools. | 2/5/25 | Recommendation will be modified and included in the draft DGO | The draft has been updated to remove vague and expansive language where possible. | agree w/ sfpd. |
| R4 | procedures for specific scenarios section should be more concise | 2/5/25 | Recommendation will be modified and included in the draft DGO | The draft has been updated to remove vague and expansive language where possible. | agree w/ sfpd. |
| R5 | translation of documents, digital content, and training sections all are way too wordy | 2/5/25 | Recommendation will be modified and included in the draft DGO | The draft has been updated to remove vague and expansive language where possible. The wording in this section has been modified so its intent and direction for SFPD employees is clear. | agree w/ sfpd. |
| R6 | Recording and Tracking of LEP should not be in a DGO, it is specific to ONE person in the Department and is administrative. Also, LEP should stay under CED as Language Access Services have a direct impact on the San Francisco community. | 2/5/25 | Recommendation will be modified and included in the draft DGO | Requirements for reporting and tracking need to be in policy so the Department can ensure the work is completed. The reporting and tracking section has been moved to the end of the DGO, and the language made more clear and concise. This DGO is silent on where the Language Liaison is assigned in the department. | agree w/ sfpd. |
| R7 | Many iPhone translations apps are easy and effective in both direction cost effective | 2/5/25 | Recommendation will be modified and included in the draft DGO | The Department has included a narrow allowance for the use of other digital (such as translation app) and non-digital (such as a dictionary, paper, etc.) interpretation assistance in limited, non-evidentiary instances. | agree w/ sfpd. This issue was discussed extensively in the working group and the determination was that apps are not yet able to translate at a level required by courts. |
| R8 | revise the definition of LEP. remove "individual" from the term as the acronym is not LEPI. use "individuals whose primary language is not English and who have a limited ability to read, write, speak or understand English" | 2/24/25 | Recommendation will be modified and included in the draft DGO | The definition of LEP was modified for clarity and now states "A person whose primary or preferred language is not English and who has a limited ability to read, write, speak, or understand English." | agree w/ sfpd. |
| R9 | This has too much detail for a DGO and should be included in a unit order or or other document. Patrol does not need to know about this section. | 2/24/25 | Recommendation will be modified and included in the draft DGO | The Language Access Liaison and Reporting procedures have been reduced with the intent of the Unit to provide more detail to the necessary party(ies) in a Unit Order. | agree w/ sfpd. |
| R10 | I suggest deleting any reporting not required by law. The only report should be the one that is already required by admin code. | 2/24/25 | Recommendation has been included in draft DGO | The Department will provide one fiscal year report, as required by Admin Code 91 and in full compliance with Admin Code 96I. | agree w/ sfpd, however the Police Commission may expand SFPD's reporting requirements by resolution. |
| R11 | Every paragraph/section should be revised for brevity. for instance, the section about "bilingual member list" should simply say that Staff Svc keeps the list and shares it with DEM | 2/24/25 | Recommendation has been included in draft DGO | The section on certified bilingual employee list has been modified and now reads "Staff Services Division maintains a list of all certified and Non-Certified Bilingual Members and Certified Civilian Interpreters, and notifies DEM when there are updates." | agree w/ sfpd. |
| R12 | the purpose section is too long - it should only be the purpose | 2/25/25 | Recommendation has been included in draft DGO | See R1 for response. | agree w/ sfpd. |
| R13 | the policy statement is too long. what is the standard for officers to follow?It seems like this should be maybe the first and second sentence. | 2/25/25 | Recommendation has been included in draft DGO | Policy statement has been amended to state "Employees shall inform LEP individuals of their right to request free language access services, and will provide these services when requested or as needed." | agree w/ sfpd. |
| R14 | [Definition section] E and F should be shortened. G should be removed entirely. | 2/25/25 | Recommendation will be modified and included in the draft DGO | All definitions have been modified to be more clear and concise. The only definition that has been removed is 'Exigent Circumstances', as it is in the newly revised DGO 3.02 (Terms and Definitions). | agree w/ sfpd. |
| R15 | [procedures] the paragraph before III.A should be removed ("SFPD members are to follow these procedures in all encounters absent exigent circumstances; however, exigent circumstances may require some deviation. In such situations, SFPD members shall use the most reliable, temporary interpreter available. Once the exigency has passed, members are expected to revert to the procedures set forth in this general order.") III.A is not necessary | 2/25/25 | Recommendation will be modified and included in the draft DGO | This feedback migh be related to the current active DGO, and not the draft DGO for public comment. This language has been removed from this section and incorporated into 5.20.05, Exigent Circumstances. | agree w/ sfpd. |
| R16 | this seems longer than the current version, it should be shorter. All sentences should be shorter and easier for officers to read/understand (especially if they arein the field) | 2/25/25 | Recommendation will be modified and included in the draft DGO | The draft has been updated to make sentences shorter and easier to read/understand. | |
| R17 | nowhere in this procedure does it say how an officer is supposed to request the help of translation services | 2/25/25 | Recommendation has been included in draft DGO | How to request translation services has been added to the DGO and now states "C. Requesting Interpretation Assistance 1.To Request a Certified/Non-Certified Bilingual Member – Ask Dispatch if there are certified (or Non-Certified, if appropriate based on incident) members available. 2. To Request a Certified Civilian Interpreter – Employees may use the designated language access app on their Department phone or call the direct number." | agree w/ sfpd. |
| R18 | [use of interpreters] Could be shortened to just say something about "contact in this order:" and then list in order of preference. Explanations not needed.p | 2/25/25 | Recommendation will be modified and included in the draft DGO | The Use of Interpretors section has been modified and broken into two sections: one for criminal incidents and one for non-criminal incidents. The language has been modified to state "…members should follow this order of preference for interpretation unless there is an exigency" | agree w/ sfpd. |
| R19 | the 1a seems confusing to read for an officer. there are sentences in there that aren't procedures. | 2/25/25 | Recommendation will be modified and included in the draft DGO | This feedback might be related to the current active DGO, and not the draft DGO for public comment. The language for scheduled interviews and custodial interrogations has been separated and the language amended for clarity. | agree w/ sfpd. |
| R20 | the parts that aren't directed toward officers (I.3, K.1, O) should be removed - they don't fit within the scope of the stated policy. [signage, transcribing tapes and evidence, recording and tracking] | 2/25/25 | Recommendation will be modified and included in the draft DGO | This feedback might be related to the current active DGO, and not the draft DGO for public comment. Former I3 was regarding signage, K1 was regarding transcribing tapes and evidence, and O was about recording and tracking langauge access efforts. Information about signage will stay in the DGO to remain compliant with SF Admin Code 91. Transcription of evidence was drastically reduced to contain only the information relevent to officers. A section about reporting is in the amended draft to maintain compliance with the Admin Code. | agree w/ sfpd. |
| R21 | There are too many definitions. Also J doesn't even provide a definition. | 2/25/25 | Recommendation will be modified and included in the draft DGO | J (exigent circumstances) has been removed. The other definitions were shortened for clarity. | agree w/ sfpd. |
| R22 | Do officers really need a whole section on how to identify someone? Is it not apparent when they cannot communicate effectively with them? | 2/25/25 | Recommendation will be modified and included in the draft DGO | This section on identifying LEP Invidivuals has been removed and the section now begins with 'Identify Primary Language'. There is a subsection that provides employees with potential indicators of LEP individuals. | Disagree w/ SFPD response. The section on identifying an LEP individual comes directly from the Department Bulletin on Providing Langauge Access Services. Section 5.20.04.A.2. should be replaced with bulleted list in 12.13.24 version of this DGO. |
| R23 | I don't see anything that tells an officer how to access the language access services | 2/25/25 | Recommendation has been included in draft DGO | See R17 for response. | |
| R24 | why would the department-provided card not be first? Using a "map" or "country flag" is ridiculous and also doesn't necessarily help determine language | 2/25/25 | Recommendation has been included in draft DGO | Asking the person what their primary language is has been included as the first way to determine a person's primary language. Using the department card has been moved to second. | agree w/ sfpd. |
| R25 | Could be made shorter. Telephonic and Non-certified don't need an whole explanation. The section already says "order of preference" | 2/25/25 | Recommendation has been included in draft DGO | Non-procedural language has been removed from the Use of Interpreters section. The language has been amended so it is clear that the order the interpreter options are listed in the order of preference for contact. | agree w/ sfpd. |
| R26 | so much of this policy is in paragraph format which would make it hard for an officer on the street to determine what they are supposed to do in a given circumstance | 2/25/25 | Recommendation will be modified and included in the draft DGO | The proposed draft has been updated to remove vague and expansive language as well as paragraph formatting. | agree w/ sfpd. |
| R27 | not applicable to most people in the department - shouldn't be in this policy [signage]. | 2/25/25 | Recommendation will be modified and included in the draft DGO | The section on signage has been decreased to highlight the information and requirements relevant for most members. | agree w/ sfpd. |
| R28 | some parts of 6 shouldn't be in policy [translation of documents]. | 2/25/25 | Recommendation will be modified and included in the draft DGO | The section on translation of documents has been decreased so that it is easier for members to read and understand their part of the process. | agree w/ sfpd. |
| R29 | shouldn't be in policy [digital content] | 2/25/25 | Recommendation has been included in draft DGO | Translation of documents and other content has been modified for clarity and for applicability to all members. 5.20.07 A (public documents) is kept in the DGO to maintain compliance with SF Admin Code 91. | agree w/ sfpd. |
| R30 | duties of language access liaison shouldn't be in a general policy | 2/25/25 | Recommendation has been included in draft DGO | This information was broadened and included in the definition of the Language Access Liaison which states "an employee responsible for managing the Department’s language access services, including assistance with coordinating training and bilingual certification processes, managing translation and interpreting services, overseeing signage posting, coordinating reporting, and ensuring compliance with SF Admin Code §91. The Liaison may also be used as a resource to assist in coordinating the translation of documents and materials." | agree, this information should be in a unit order or placed on the general sfpd website. |
| R31 | too specific. If these are actual requirements, then details should be somewhere else. [reporting] | 2/25/25 | Recommendation has been included in draft DGO | Reporting requirements have been modified to align with Admin Codes 91.11 and 96I.2(b). This section now states "The Language Access Liaison will coordinate the preparation of the fiscal year report as outlined in SF Admin Code § 91.11, including the number and percentage of LEP individuals who used the Department’s services, a roster of certified and Non-Certified bilingual employees, ongoing training strategy, etc. 1.The report shall be submitted to the Police Commission and OCEIA upon approval by the Chief." | |
| R32 | This definition adds zero guidance and had no practical application. Please delete. [5.20.03 D] | 2/27/25 | Recommendation will be modified and included in the draft DGO | The definition of Required Languages is kept; but has been modified for clarity and states "Languages the Department must provide interpretation and translation services for, and have vital information available in, per SF Admin Code §91." | Agree |
| R33 | Why is national origin mentioned? Should be deleted as this is a bout language not origin. | 2/27/25 | Recommendation has been included in draft DGO | The reference to national origin has been removed. | agree. |
| R34 | A definition that just refers to another DGO? Just delete this definition, totally unhelpful. | 2/27/25 | Recommendation has been included in draft DGO | This definition [exigent circumstances] has been removed. It is included in the newly revised DGO 3.02 (Terms and Definitions). | agree. |
| R35 | There needs to be a line that allows officers to ask about language "do you speak" without getting in trouble. Officers have been in trouble for assuming. In the spirit of this DGO, officers have to be protected. | 2/27/25 | Recommendation has been included in draft DGO | Members are allowed to ask citizens questions in order to communicate with them effectively and efficiently. 5.20.04 A has been modified to include asking a person their primary language. | Agree that officers should feel comfortable asking someone if they speak a language. However, DPA is unaware of discipline cases stemming from our office where someone was asked if they speak a langauge. |
| R36 | "Code-switching" isn't common vernacular and should be changed to a common language alternative. | 2/27/25 | Recommendation will be modified and included in the draft DGO | This term is not commonly used in SFPD. To make it more clear, the term has been modified to "switching between languages" and included in the section 'Potential indicators of LEP individual'. | Agree w/ comment but disagree w/ SFPD's solution. This concept should remain as a common indicator by removing "code". |
| R37 | This policy fails to meet its basic purpose which is to "establish language access procedures," The audience for this DGO is clearly not police officers but the special interests that wrote it. Entire thing should be scrapped as ineffective. | 2/27/25 | Recommendation will be modified and included in the draft DGO | The public comment feedback process has provided substantial feedback that has been incorporated into the draft. The DGO now more clearly outlines procedures for officers while ensuring meaningful access for all communities. | This comment is dissapointing as SFPD members from multiple ranks and stations participated as working group members or on a panel to explain issues with language access. |
| R38 | We are a worldwide destination. The importance of language is obvious to us all. The "Purpose" statement is insulting and unnecessary. Do you even realize how much "training" we receive in Community Groups and Communication? | 3/3/25 | Recommendation will be modified and included in the draft DGO | Thank you for sharing your input. We’ve updated the Purpose statement to read: “This order establishes language access procedures to guide employees in providing service to Limited English Proficient (LEP) individuals, fostering clear communication and reducing barriers that may otherwise limit access to critical rights, obligations, and services while ensuring communication is accurate, respectful, and effective. Department employees should take reasonable steps to ensure timely and accurate language access services to all individuals." | |
| R39 | OVERLY VAGUE LANGUAGE! "... EVERY REASONABLE step to ensure TIMELY and ACCURATE communication and access to ALL individuals..." Really, "every?" What's "reasonable?" What's "timely and accurate? Define "ALL." | 3/3/25 | Recommendation will be modified and included in the draft DGO | These words are from the Policy statement, which has been reworded to provide clear direction for SFPD employees. It now states, "Employees shall inform LEP individuals of their right to request free language access services, and will provide these services when requested or as needed." | Agree w/ comment and SFPD's direct and proactive langauge. |
| R40 | "This order establishes language access PROCEDURES..." So, this isn't a GO. It's a procedure guideline, not a General Order, and should be in a manual. Why are there seven pages of a procedure? | 3/3/25 | Recommendation will be modified and included in the draft DGO | Many of the department policies include procedures. Based on feedback received in the public comment process, this DGO has been clarified, language amended, and the document rewritten so SFPD employees can easily read the DGO, understand the required procedures, and provide service to community members in accordance with this policy and SF Admin Code. | Agree w/ SFPD. |
| R41 | "The Department’s policy is to inform the public that language assistance services are available free of charge..." Then make a media release. Why are you making this a DGO? This is a policy to inform the public. How are Cops responsible for that? | 3/3/25 | Administrative Question and Answer-not for inclusion in DGO | This language has been removed from the DGO and the policy amended to provide clear direction for officers. | Agree w/ change to simplify 5.20.03 as this is a direct and proactive approach. |
| R42 | This entire DGO sounds like a procedural how-to. Most of this sounds like it should relate to Investigators and Admin. Plus, you didn't even provide the Telephonic Interpreter Service Number. | 3/3/25 | Recommendation will be modified and included in the draft DGO | The information in the DGO has been reduced to the information needed for most of the department staff. The information for requesting an interpreter has also been included. | |
| R43 | So I can be given days-off for not providing a Miranda Admonition and all other written forms to a Suspect in their primary language when available? When available? How can the Telephonic Interpreter read the forms to the Suspect?? | 3/3/25 | Recommendation has been included in draft DGO | The Miranda Admonsition section has been amended to state "When required, the Miranda Admonition shall be provided in the suspect’s primary or preferred language." Language about the telephonic interpreter reading forms has been revised and moved under 5.20.04(G) which states, "Forms/Documents – Members will provide forms and documents in required languages. If a form/document is not available in the appropriate language and the LEP individual needs the information immediately, the member will use a Certified Bilingual Member or Certified Civilian Interpreter to read the form/document to the LEP individual. For translations that are not needed immediately, see ‘Translation of Documents and other Content’." | Agree w/ SFPD decision to split into two sections. |
| R44 | What does "code-switching" mean? What is an OCEIA? | 3/3/25 | Administrative Question and Answer-not for inclusion in DGO | Code-switching means switching between two or more languages. OCEIA is the department responsible for overseeing all language access services within the City. A definition for OCEIA has been included in the DGO. References to "code-switching" have been removed from the proposed policy. Language has been included in 'Potential indicators of LEP individual, "...switching between languages". | Disagree w/ SFPD response. While "code-switching" may not be understood, "switching between language" should be included as an indicator of an LEP individual. |
| R45 | Does this mean that we will be handling all transcription/translation services, even for the DA's Office? Who vets the Dept. vendor and will they be available to testify in Court? Shouldn't then we defer all translation services to the Vendor ? | 3/3/25 | Recommendation will be modified and included in the draft DGO | Each City department is responsible for translating their own materials. 5.20.07 (translation of documents and other content) has been separated into External requests (required language and non-required language) and Internal requests (evidence and docments). This should make it clear that we do not transcription/translation services for all agencies. The vendor used for services is managed by the Language Access Liaison. | agree w/ sfpd. |
| R46 | As a Patrol Officer, why do I need to know the Language Access Liaison's Duties? Seems oddly specific to be included in a GENERAL ORDER, for which every employee must maintain working knowledge of said Orders. | 3/3/25 | Recommendation has been included in draft DGO | This section has been amended to provide general duties of the Language Access Liason that are important for all department employees to know. | Agree w/ SFPD, however, the Langauge Access Liason duties should exist somewhere in writing, whether in a unit order or on the SFPD website. |
| R47 | The Policy statement is unclear. I understand that it is "to inform... free of charge to LEP individuals," but are we also required to inform that the Dept will provide these as part of community policing and enforcement? Is it a two fold policy? | 3/10/25 | Recommendation has been included in draft DGO | The policy statement has been amended to read "Employees shall inform LEP individuals of their right to request free language access services, and will provide these services when requested or as needed." | Agree, see R.49. |
| R48 | If someone can articulate what they believe is a "reasonable step," one which I had not though of, I can be held in violation of this policy. The policy states, "every reasonable step," which is all encompassing. There's no way this is valid/legal. | 3/10/25 | Recommendation has been included in draft DGO | This language has been removed from the proposed DGO. Thee policy statement has been amended to read "Employees shall inform LEP individuals of their right to request free language access services, and will provide these services when requested or as needed." | Agree w/ comment and SFPD. New policy language mirrors the affirmative statement requested by many of the Working Group members (which included SFPD members). |
| R49 | this title is too long - why do we need to say for LEP persons? can't it just be language access services? those services are for anyone who wants them, regardless of their ability to speak or read english. | 3/12/25 | Recommendation has been included in draft DGO | The title has been changed to Language Access Services | Agree w/ comment and SFPD. |
| R50 | The terms of certified vs qualified interpreter, certified as through the courts as certified is more appropriate | 3/15/25 | Recommendation will not be included in Draft DGO | The comment is unclear, as "qualified interpreter" was not included in the public comment draft. | Agree w/ sfpd, unclear where qualified comes from. |
| R51 | There is little to no guidance for members to use immediate means to ascertaining information on scene and by giving a specfic order, you are setting up mememebers and LEP folks a severe disadvantage. ex: medical emergency and cannot use Langueline? | 3/15/25 | Recommendation will be modified and included in the draft DGO | We agree with this comment. The proposed draft has been modified and delineates between "criminal" and "non-criminal" use of interpreters. There is also an exigency section that allows members to use "the most reliable, temporary interpreter". | Agree w/ sfpd. |
| R52 | We appreciate the inclusion of factors. These details are important in ensuring SFPD staff have the appropriate guidance needed to support LEP persons they encounter. These two elements are based on national best practices from the U.S. DOJ. [reference for the section on Identifying LEP invidiuals and ID of primary language] | 3/26/25 | Administrative Question and Answer-not for inclusion in DGO | Based on feedback received during the public comment period, these two sections have been combined into one section (Identify Primary Language) and condensed to make it easier for officers in the field to understand broad themes to help them identify people who may be LEP, instead of giving them a specific checklist which could result in missing a trait not listed. Potential indicators of an LEP individual are still provided "2. Potential indicators of LEP individual – Misuse of language, inability to answer questions sufficiently, confusion with intricate enforcement procedures or language, cannot respond to open-ended questions, etc." | Agree w/ comment and SFPD. |
| R53 | The signage should specify that these language service requirements extend for the full life cycle of the case or investigation free of charge when LEP persons are involved. | 3/26/25 | Recommendation will not be included in Draft DGO | Signage requirements are governed by SF Admin Code §91.5(b). Per this DGO, the Language Access Liaison will ensure compliance with SF Admin Code §91. | Agree w/ SFPD |
| R54 | We urge the Department to adhere to the requirement to post the OCEIA's Know Your Rights brochure to let residents know of their right to file a complaint, and work with OCEIA to resolve complaints in a timely manner. | 3/26/25 | Administrative Question and Answer-not for inclusion in DGO | The requirement to post OCEIA's brochure is outlined in SF Admin Code §91.14(g) and noted in the proposed DGO (5.20.09(B)(3). See R59 for response about complaints. | Agree w/SFPD. Complaints are routed by OCEIA to DPA. DPA must follow POBRA rules to conduct investigations and cannot disclose results of the investigations in an identifiable form without a change to State law. |
| R55 | It is critical that SFPD employees are regularly trained on topics including identifying primary language, communicating with a LEP person, working with bilingual personnel, understanding local and district station-level demographic information. | 3/26/25 | Recommendation included in training, Department Manual, or other procedural or guidance document | Department employees are regularly trained in customer service. All employees are required to have a working knowledge of all directives, which includes DGO 5.20. | Agree w/ SFPD. |
| R56 | Training should be offered to all employees that engage with LEP residents at least every calendar year. Initial training shall be conducted within 180 days of the Police Commission’s adoption of this General Order. | 3/26/25 | Recommendation will not be included in Draft DGO | The proposed draft language for training states, "The Department will provide all public-facing employees with periodic training on LEP policies and procedures, interpreting techniques, roles, and ethics." San Francisco is a diverse community - the Department has been conducting training regarding language access services since before a formal DGO was instituted in 2007. As such, there can be no "initial" training to conduct. Moving forward, training will be amended to adhere to this policy. | The Police Commission sets timeline for initial training of this policy. DPA is aware of ongoing Language Access training occuring within SFPD. |
| R57 | Reporting should include language-specific information, as well as utilization (or non-utilization) of language assistance services by district; usage and cost information for each method of interpretation service: in-person, video, phone, bilingual perso | 3/26/25 | Recommendation will not be included in Draft DGO | Reporting requirements have been modified to align with Admin Codes 96I.2(b) [Recordkeeping and reporting to minimize redundancy] and 91.11. This section now states "The Language Access Liaison will coordinate the preparation of the fiscal year report as outlined in SF Admin Code § 91.11, including the number and percentage of LEP individuals who used the Department’s services, a roster of certified and non-certified bilingual employees, ongoing training strategy, etc." | Disagree with comment. While the information would be helpful, it goes beyond the requirements set by the BOS. Commentor could likely request this information through PRA. |
| R58 | Reporting should include: the number of employees and specific languages represented by the Bilingual Officer Program; and any complaints concerning language access, and SFPD’s resolution of language access complaints. | 3/26/25 | Recommendation will be modified and included in the draft DGO | Reporting requirements have been modified to align with Admin Codes 96I.2(b) [Recordkeeping and reporting to minimize redundancy] and 91.11. This section now states "The Language Access Liaison will coordinate the preparation of the fiscal year report as outlined in SF Admin Code § 91.11, including the number and percentage of LEP individuals who used the Department’s services, a roster of certified and non-certified bilingual employees, ongoing training strategy, etc." | DGO already covers the matters raised by the comment. |
| R59 | Complaints: Every resident has the right to file a complaint if they feel their language rights have been violated. The DGO should explicitly specify how language access complaints will be handled and resolved through good faith cooperation with OCEIA. | 3/26/25 | Recommendation will not be included in Draft DGO | Complaints regarding sworn officers are handled by DPA, pursuant to their Charter authority. | Agree w/ SFPD. All complaints about SFPD are routed to DPA. |
| R60 | The Department should publicize the number of language access complaints and the number of complaints resolved. This is the only way for the complaint process to be accessible and for community members to have trust in our public institutions. | 3/26/25 | Recommendation will not be included in Draft DGO | Per SF Admin Code §91.10(d), OCEIA shall submit quarterly reports to the Board of Supervisors that details the number of comptlaints filed within that quarter, including an alysis of individual cases with departmental trends; the number of complaints filed for the year-to-date; a comparision of those numbers with the filings for the previous year; a brief description of the nature of each complaint filed, including the Department named in the complaint; and OCEIA's summary report of its investigation with findings and recommendations. | Agree w/ SFPD. As discussed in the working group, BOS has taked OCEIA with drafting language access reports. |
| R61 | Include an ‘Evaluation’ section that commits the Department to gathering input on and regularly evaluating their performance and provision of language services by soliciting the experiences of LEP individuals, collecting data on language access utilizatio | 3/26/25 | Recommendation will not be included in Draft DGO | This recommendation is outside the scope of this DGO. The department has multiple community surveys (https://www.sanfranciscopolice.org/community/community-surveys) already on the department website that are managed by the Community Engagement Division, and will comply with SF Admin Code §91.14(e). | Partially agree w/ commenter. If you look to 5.20.09.A "reporting", the first sentence is about preparation of the FY report, and includes collecting information on utilization, but then after the comma, includes other roles and responsiblities for the position. This section also previously included meeting with DPA, OCEIA, and community groups which would likely satisfy the second half of the comment. |