Introduction and Purpose

This guidance provides an overview of the Office of Community Oriented Policing Services’ (the COPS Office) efforts to ensure and maximize the quality, objectivity, utility, and integrity of information disseminated to the public. In addition, this guidance describes the agency's administrative mechanisms for affected persons to seek and obtain correction of information disseminated by COPS that is not considered to comply with COPS, Office of Management and Budget (OMB), or Department of Justice (DOJ) information quality guidelines.

OMB's guidelines define "quality" as comprising utility, objectivity, and integrity. Accordingly, at a minimum, COPS’s Information Quality Guidelines requires its staff to (1) assess the usefulness of the information to be disseminated to the public by continuously monitoring information needs, developing new information sources, or revising existing methods, models, and information products where appropriate; (2) ensure disseminated information is accurate, clear, complete, reproducible, and presented in an unbiased manner by using reliable data sources, sound analytical techniques and documenting methods and data sources; and (3) is protected from unauthorized access, corruption, or revision (i.e., make certain that disseminated information is not compromised through corruption or falsification) by having in place protocols and policies for securing its information as required by the Computer Security and Government Information Security Reform Acts. Any statistical information disseminated will be based on (1) the promotion of sound statistical methods and (2) the principle of transparency.

Office of Community Oriented Policing Services

The COPS Office was created as a result of the Violent Crime Control and Law Enforcement Act of 1994. As a component of the Department of Justice, the mission of the COPS Office is to advance community policing in jurisdictions of all sizes across the nation. Community policing focuses on crime and social disorder through the delivery of police services that includes aspects of traditional law enforcement, as well as prevention, problem-solving, community engagement, and partnerships. The community policing model balances reactive responses to calls for service with proactive problem-solving centered on the causes of crime and disorder. Community policing requires police and citizens to join together as partners in the course of both identifying and effectively addressing these issues.

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Background Information

Section 515 of the Treasury and General Appropriations Act for Fiscal Year 2001 (PL 106-554) directs the Office of Management and Budget (OMB) to issue government-wide guidelines that "provide policy and procedural guidance to federal agencies for ensuring and maximizing the quality, objectivity, utility, and integrity of information (including statistical information) disseminated by federal agencies." OMB's guidance (Feb. 22, 2002, Federal Register Volume 2, No. 67 at 8452) requires that Federal agencies: 1) issue information quality guidelines ensuring and maximizing the quality, objectivity, utility, and integrity of information disseminated; 2) establish administrative mechanisms allowing affected persons to seek and obtain correction of information maintained and disseminated by the agency that does not comply with the OMB guidelines; and 3) report annually to the director of OMB the number and nature of complaints received by the agency regarding agency compliance with the guidelines.

In response to the OMB guidelines, DOJ issued agency-wide Information Quality Guidelines governing all DOJ components. Pursuant to DOJ guidance regarding the implementation of OMB Memorandum M-05-04, Policies for Federal Agency Web Sites (Dec. 17, 2004), COPS is issuing its own Information Quality Guidelines consistent with the DOJ guidelines.

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Scope and Applicability of Guidance

This document provides guidance to COPS staff and informs the public of the agency's policies and procedures to ensure and maximize the quality, objectivity, utility, and integrity of information disseminated to the public. COPS will correct information that does not meet its guidelines or those of DOJ or OMB based on the significance and impact of the correction. These guidelines apply only to information disseminated by COPS, as defined in these guidelines, on or after October 1, 2002, regardless of when the information was first disseminated. This includes COPS initiated or sponsored dissemination of information by grantees, contractors or cooperative agreement recipients. COPS "initiates" the dissemination of information by a grantee, contractor or cooperative agreement recipient when it disseminates the information in a manner that reasonably suggests that COPS agrees with the information and the information represents the agency's views. COPS "sponsors" the dissemination of information by a grantee, contractor or cooperative agreement recipient when it has directed the third-party to disseminate the information or has the authority to review and approve the information before release. Other information distributed by the agency that is not addressed by these guidelines (described below) remains subject to any applicable agency policies and correction procedures.

With the exception of the categories of information listed below, the COPS guidelines apply to any communication or representation of knowledge such as facts or data, in any medium or form, including textual, numerical, graphic, cartographic, narrative, audiovisual forms. The guidelines apply to information that COPS disseminates from a web page, but do not apply to information disseminated by others or accessible through hyperlinks to another source from the COPS web site.

It should be noted that in urgent situations that may pose an imminent threat to public health or welfare, the environment, the national economy, or homeland security these requirements may be waived temporarily.

The COPS Information Quality Guidelines represent the practices, priorities, and policy views of COPS. These guidelines are not legally enforceable and do not create any legal rights or benefit, substantive or procedural, enforceable by law or equity, by any party against the United States, its agencies (including the DOJ or any DOJ component), officers, or employees, or any person, nor do they impose any legally binding requirements or obligations on the agency, its components, or the public. In addition, nothing in these guidelines affects any otherwise available judicial review of agency action. The guidelines do not override other compelling interests such as privacy, trade secrets, intellectual property, and other confidential protections. The guidelines do not apply to opinions where the agency's presentation makes it clear that the material is being offered as someone's opinion rather than fact or the agency's views.

In addition, the guidance does not apply to information disseminated in the following contexts:

• Limited to government employees or agency contractors or grantees unless the agency represents the information as, or uses the information in support of, an official agency position, or the grantee is disseminating the information at the request of the agency, or the grant requires agency approval of the information request
• Intra- or interagency use or sharing of government information
• Responses to requests for agency records under the Freedom of Information Act, the Privacy Act, the Federal Advisory Committee Act or other similar law
• Distribution limited to correspondence with individuals or persons
• Press releases, fact sheets, press conferences, and similar communications (in any medium) that announce, support or give public notice of information in COPS
• Information relating to subpoenas, or adjudicative processes
• Archival records disseminated by federal agency libraries or similar federal data repositories
• Congressional testimony and other submissions to Congress containing information that DOJ has previously provided to the public
• Procedural, operational, policy, and internal manuals prepared for the management and operations of DOJ that are not primarily intended for public dissemination.

Effective Date

These guidelines are effective immediately, and cover information disseminated on or after October 1, 2002, regardless of when the information was first disseminated.

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Oversight/Management Responsibility

The COPS Office's Communications Division is responsible for the overall implementation and oversight of the COPS Information Quality Guidelines, collecting and tracking complaints, and ensuring and maximizing quality, objectivity, utility, and integrity of information disseminated to the public. The Communications Division will manage information quality in collaboration with the COPS Office's Management and Budget and Legal Divisions. The Communications Division will work with the COPS Chief Information Officer (CIO) to assist the DOJ CIO in the preparation of reports required under the OMB guidelines.

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Standards for Disseminated Information

COPS will review all information dissemination products for their quality (including objectivity, utility, and integrity) before they are disseminated. A basic standard of quality will be ensured and established for all information prior to its dissemination. In addition, ongoing disseminated information will be reviewed on a regular basis to ensure that all information is current and complies with established guidelines. OMB's guidelines define "quality" as an encompassing term comprising utility, objectivity, and integrity: therefore, the guidelines sometimes refer to these three terms, collectively, as "quality." For the purpose of these guidelines, the definitions below apply, consistent with the OMB guidelines:

Utility: COPS will assess the usefulness of the information to be disseminated to the public. Utility is achieved by continuously monitoring information needs and developing new information sources or by revising existing methods, models, and information products where appropriate.

Objectivity: COPS will ensure that disseminated information, as a matter of substance and presentation, is accurate, reliable, and unbiased. Objectivity is achieved by using reliable data sources, sound analytical techniques, and documenting methods and data sources.

Integrity: COPS will ensure that information is protected from unauthorized access, corruption, or revision (i.e., make certain that disseminated information is not compromised through corruption or falsification). To ensure integrity of information disseminated, COPS has programs and policies in place for securing its information as required by the Computer Security and Government Information Security Reform Acts and is highly protective of information collected under pledges of confidentiality.

Prior to dissemination of information, COPS will:

• Allow adequate time for reviews, consistent with the level of standards required for the type of information to be disseminated
• Ensure compliance with the OMB, DOJ, and COPS guidelines (i.e., utility, objectivity, and integrity requirements)
• Provide methodologies, origins of data, limitations of the information, etc., whenever possible, as part of information dissemination
• Ensure that the information fulfills the intentions stated and that the conclusions are consistent with the evidence.

Additionally, for statistical information, COPS will ensure that the dissemination of statistical information is based on (1) the promotion of sound statistical methods and (2) the principle of transparency.

Sound statistical methods: Sound statistical methods produce information (data and analysis results) that is accurate, reliable, and unbiased. Guidelines to promote sound statistical methods would cover the planning of statistical data systems, the collection of statistical data, and the processing of statistical data (including analysis).

Transparency: Transparency refers to a clear description of the methods, data sources, assumptions, outcomes, and related information that will allow a data user to understand how the information product was designed or produced. Guidelines to ensure transparency in statistical information cover the dissemination of information, including both presentation and the reporting of information sources and limitations.

For influential information: When information is defined as influential there is an added level of scrutiny afforded this information, including the need to ensure that it is reproducible. At COPS, influential information is that which is expected to have a genuinely clear and substantial impact at the national level, or on major public and private policy decisions as they relate to federal justice issues. The accuracy of this information is significant because of the critical nature of these decisions. A clear and substantial impact, first of all, is one that the agency is firmly convinced has a high probability of occurring. If it is merely arguable that an impact will occur, or if it is a close judgment call, then the impact is probably not clear and substantial. To determine that there is a clear and substantial impact, the agency must have greater certainty than would be the case for many ordinary factual determinations. The impact must be on "important" public policy or private sector decisions that are expected to occur. Even if information has a clear and substantial impact, it is not influential if the impact is not on a public or private decision that is important to policy, economic, or other decisions.

At COPS, the responsibility for determining if information is influential lies with the division that disseminates the information. COPS may designate certain classes of information as either "influential" or not in the context of their specific programs. Absent such designations, COPS will determine whether information is influential on a case-by-case basis, using the principles articulated in these guidelines. The "influential" designation should only be applied to information when clearly appropriate.

Reproducibility: Means that documented methods are capable of being used on the same data set to achieve a consistent result. For more information on this term, please refer to OMB's guidelines on information quality.

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Information Correction Request and Appeal Processes

Submitting a Formal Request for Correction
All requests for correction of COPS information must be submitted by letter, fax, or e-mail to:

Office of Community Oriented Policing Services
Communications Division
(Information Quality Guidelines Request for Correction)
145 N Street, N.E.
11 th Floor
Washington, DC 20530

Fax: 202-616-8572
E-mail: tellcops@usdoj.gov

Requests for correction should include the following information:

• Statement that the request for correction of information is submitted under the COPS Office's Information Quality Guidelines
• Requestor's contact information, including name, title (if any), mailing address, telephone number, fax number (if any), e-mail address (if any), and organizational affiliation (if any)
• The name of the COPS report or data product to be corrected, including the date of issuance or other identifying information, such as the uniform resource locator (URL) of the web page
• A detailed description that clearly identifies the specific information contained in the report or data product for which a correction is being sought
• An explanation that describes how the information is incorrect or fails to meet either the OMB, DOJ, and/or COPS Information Quality Guidelines
• An explanation that describes how the alleged error harms or how a correction would benefit the requestor
• A recommendation for how the information should be corrected and that describes the requestor's position for why COPS should adopt those recommendations
• Any supporting documentary evidence, such as comparable data or research results on the same topic, that will help in evaluating the merits of the request.

Requestors should be aware that they bear the "burden of proof" with respect to the necessity for correction as well as with respect to the type of correction being sought. COPS will base its decision on the merits of the information provided by the requestor. The failure to fully explain the nature of the correction being sought and/or to provide contact information may cause significant delays in an agency response or may result in the agency being unable to process the request. COPS will not contact the requestor to obtain additional information when the submission is incomplete.

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Review of the Request for Correction

The request for correction will be processed by the Communications Division. Based on the explanation and evidence submitted with the request for correction, COPS will conduct a thorough review of the information being challenged, the processes that were used to create and disseminate the information, and the conformity of the information and those processes with both OMB, DOJ, and COPS Information Quality Guidelines.

After it has completed its review, COPS will determine whether a correction is warranted and, if so, what corrective action should be taken. Any corrective action will be determined by the nature and timeliness of the information involved and such factors as the significance of the error on the use of the information and the magnitude of the error. COPS will not take action based on frivolous claims, repetitive requests for correction, claims made in bad faith, or claims without justification or support. COPS is also not required to take corrective action on requests that concern information not covered by the guidelines or from a person whom the information does not affect.

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Response to the Request for Correction

COPS will respond to the requestor by letter, e-mail, or fax within 60 calendar days of receipt of the claim. The response will explain the findings and the actions to be taken (if any) in response to the complaint. If the request requires more than 60 calendar days to resolve, COPS will inform the requestor and provide an estimated decision date.

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Request for Reconsideration of the COPS Decision

If the requestor disagrees with the agency's decision, the requestor may file a request for reconsideration by letter, fax, or e-mail to:

Office of Community Oriented Policing Services
Office of General Counsel
(Information Quality Guidelines Reconsideration)
145 N Street, N.E.
11 th Floor
Washington, DC 20530

Facsimile: 202-514-3456
E-mail: shelley.langguth@usdoj.gov

Persons requesting reconsideration should submit written material to support their case for reconsideration. They need not resubmit the information originally submitted to support the request for correction. Requests for reconsideration must be submitted to COPS within 45 calendar days after the date of the agency's original decision. Requests for reconsideration that are received by COPS after the 45-calendar-day deadline may be denied.

The COPS Office will designate a reconsideration official to review the information in question and make a decision regarding the request based on the material submitted in support of the request for reconsideration, the original request for correction, and the agency's original decision. COPS will then respond to the requestor by letter, e-mail, or fax. The response will explain the reconsideration official's decision and the actions COPS will take (if any) in response to the request for reconsideration. COPS will respond to all requests for reconsideration within 45 calendar days of receipt.

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