31.2 Equal Employment Opportunity and
Recruitment
Questions from accreditation managers in the
field about these three standards indicate some additional guidance might be
helpful in preparing these accreditation files.
31.2.1 The
agency has ethnic and gender composition in the sworn law enforcement ranks in
approximate proportion to the makeup of the available work force in the law
enforcement agency's service community, or a recruitment plan pursuant to
standard 31.2.2
(M M M M)
Standard 31.2.1 (agency composition)
contains the word “or,” which makes the recruitment standard, 31.2.2
applicable only when the agency does not have an ethnic and gender composition
of sworn personnel in approximate proportion to the makeup of the available
workforce. Restated, if sworn personnel are in near proportion to the available
workforce, it is NOT necessary to have a recruitment plan, nor should
assessors request that your agency develop one.
When the composition of the agency
approximates the makeup of the available workforce in your service area,
standard 31.2.2, Recruitment Plan can be placed in the N/A by
function category. Placing standard 31.2.2 in the N/A category rests in
the agency’s ability to prove to the assessment team that the agency used
reliable data to arrive at that conclusion.
31.2.2 The
agency has a recruitment plan for sworn personnel that includes the following
elements:
a. statement of objectives;
b. plan of action designed to achieve
the objectives identified in bullet (a); and
c. procedures to periodically evaluate the progress
toward objectives and revise/reissue the plan.
(M M M M)
The purpose of a recruitment plan is to
rectify under-representation when it occurs. Some agencies meet or exceed their
hiring goals with ethnic or gender composition, but choose to have an
“on-the-shelf” recruitment plan, which self-activates affirmative action only
when data suggests under-representation is occurring. This is also acceptable
and the assessment team may then place standard 31.2.2 in the compliance
category, despite the current ethnic and gender makeup of the agency.
Some things to
remember when evaluating your agency’s status regarding 31.2.1 and
31.2.2:
(1) Standards 31.2.1 and 31.2.2 are only
applicable to the sworn workforce.
(2) Standard 31.2.1 (agency composition)
requires “approximate proportion,” not “exact proportion” with “available
workforce” data, not raw population data (as found in U.S. Census Reports or
Statistics Canada). Some locally available labor market statistics can be
deceiving and need to be carefully evaluated; Does the data indicate a
percentage of females and minorities “available” for sworn law enforcement, or
is the data representative of the entire labor pool (everything from
professionals to unskilled labor)?
For example, census data is likely to show
approximately 50% female, but the likelihood of most agencies having 50% female
applicants for an opening for a sworn law enforcement job opening are slim. The
National Association of Women Law Enforcement Executives (NAWLEE) indicates the
national average labor market pool for females available for law enforcement
careers is approximately 14%.
Another example
might be where the national census data indicates 14% racial minority, but the
local community is 25% racial minority. In this instance, the agency should
take whatever affirmative steps it can to attract qualified minorities from the
local available workforce. The accurate representation of available workforce
data is essential to the agency’s decision to activate a recruitment plan.
(3) Standard 31.2.2 (recruitment plan) should be
carefully crafted to ensure the agency goals are reasonable and attainable and
the procedures for reviewing and revising the plan ensure the agency is staying
focused on rectifying under representation when it occurs.
CALEA accredited agencies have used a
variety of creative and cost effective methods to enhance their recruitment
efforts, such as holding open house at the police facility and targeting
specific groups for invitation, having officers or deputies pass out recruitment
brochures to traffic violators or other community contacts perceived by the
officer to be potential candidates, or establishing mentoring programs. These
methods are often cited as the reason accredited agencies are so successful in
their recruitment efforts.
31.2.3 The
agency has an equal employment opportunity plan.
(M M M M)
Standard 31.2.3, an equal employment
opportunity plan is an entirely separate issue than a “recruitment plan.” A
common deficiency found with standard 31.2.3, is the agency highlighting
an equal employment opportunity policy statement (usually in a recruitment
brochure or agency written directive) and using this as the sole proof of
compliance. This file should contain a document that qualifies as a “plan.”
The “plan” should have action steps.
The intent of
standard 31.2.3 is for the agency to develop a plan for the internal
monitoring of equal employment opportunity issues. The agency should be open to
any complaints of discrimination and the plan should have a system of redress
for those complaints. An aggrieved individual should not be forced to lodge a
complaint with the Equal Employment Opportunity Commission or Canadian
Provincial Human Rights Commission prior to the agency getting first opportunity
to hear the complaint and possibly come to a resolution.
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