1. Audit of the Police Property Room 'C
ABSTRACT
Controls over high-risk inventory are
generally appropriate despite inadequate
AN ` ►o �i`'+ facilities. This audit recommends some
improvements to strengthen controls and
improve facility conditions.
City Auditor's Office
AUDIT OF THE POLICE
PROPERTY ROOM
OF
DENTON
The City of Denton Internal Audit Report Audit of the Police Property Room
June 2019
Table of Contents
ExecutiveSummary......................................................................................................................................3
Introduction..................................................................................................................................................5
ManagementResponsibility.....................................................................................................................5
Audit Objectives, Scope, and Methodology..............................................................................................5
BackgroundInformation...........................................................................................................................6
WhatWorks Well? .......................................................................................................................................7
Staff has Mitigated Some Property Room Facility Weaknesses...............................................................7
Internal Controls Over High-Risk Inventory Have Improved Over Time...................................................8
Opportunities for Improvement..................................................................................................................9
Facilities are Inadequate for Evidence Item Storage................................................................................9
Property Room Security Measures Do Not Adequately Mitigate the Risk of Internal Theft..................11
Inventory Integrity Cannot be Assured...................................................................................................13
Long-term Storage Locations of Some High-Risk Items Should Be Further Secured..............................14
Controls Over High-Risk Destructions Can Be Easily Improved..............................................................15
Funding Should be Provided for Untested Sexual Assault Kits...............................................................16
Appendix 1: Memorandum from the Denton Police Department ...........................................................17
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The City of Denton Internal Audit Report Audit of the Police Property Room
June 2019
Executive Summary
Honorable Mayor and members of the City Council,
We have completed an audit of the Property Room Unit(Unit). The objective of this audit was to evaluate
internal controls over evidence and other items stored in the Unit.The Unit stores items such as drugs,
guns, cash, etc.that are highly vulnerable to the risk of theft due to their street value and potential for
misuse.Therefore, security and accountability of these properties are critical.The Property Room Unit is
responsible for safeguarding evidence items collected by Police detectives and officers as well as found
property and property submitted for safekeeping.
Annually,the Unit receives 11,000 items and currently stores more than 100,000 items at their location.
We found that staff has done a good job in mitigating certain control concerns in their environment;
however, as reported, several significant concerns still need attention.
The following are salient observations:
• We could not find one drug item out of 153 items selected for inspection.The department has
addressed this finding in the attached response.
• The security of Property Room facilities need improvement in accordance with the accepted
standards.
• Currently, the facility is congested and does not have room to grow. Police staff have
recommended renovating the existing Police Station and constructing a new Police Substation,
both of which would complete construction in 2022. Based on growth trends from 2009 through
2018,we expect the Property Room inventory to double in size by 2028. Before construction
completes, more than 45,000 items will be added to the Property Room inventory.The existing
facilities may not accommodate the expected addition to property count during this time.A
significantly larger empty space suitable for the Unit's operations is available in the Police Station.
We have recommended that the Unit's operations be temporarily moved to this location until a
permanent location is constructed.
• We found that Property Room operations are generally secure, though there is room for
improvement.
• The accuracy of the Unit's inventory has not been verified for a substantial period. Potentially
allowing for missing items to not be identified and followed up on in a timely manner.
• The accepted standards require that separate individuals perform the duties of collecting
evidence, storing evidence, and authorizing movement(including disposal) of evidence. It is
imperative that this segregation of duties remain intact to provide assurance that the Property
Room inventory is complete. Currently,the Property Room staff are performing incompatible
duties.
• Between 2014 and 2018, the Unit adequately documented destruction authorization, staging,
transportation, and witnessing, however, documentation of item verification is lacking.The
accepted standards require that destruction documentation include independent authorization
and verification of each item and the identity and certification of who staged,verified,
transported and witnessed the destruction of each item. Destruction documentation control
deficiencies present an unacceptably high risk of theft.
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The City of Denton Internal Audit Report Audit of the Police Property Room
June 2019
The Police Department has concurred with all but two recommendations made in this report.The two
non-concurrences are significant.These recommendations were intended to strengthen segregation of
duties to provide assurance that the property and evidence inventory was complete. Without these
needed controls, items submitted to the Property Room by police officers could be omitted or deleted
from the Police Department's Records Management System (RMS). While reviewing deleted items
quarterly may identify deleted items, items may still be omitted by Property Technicians prior to being
entered into the system. Property and evidence items entered by Technicians in RMS are the only easily
reconcilable database of items. Without proper segregation of duties, assurance that II submitted items
are accounted for cannot be provided.
We appreciate the cooperation of Police staff.The Police Department's response to this report is
attached in Appendix 1. If you have a question related to this report, please contact me at extension 8158
or at umesh.dalal@cityofdenton.com.
Sincerely,
Umesh Dalal, City Auditor
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The City of Denton Internal Audit Report Audit of the Police Property Room
June 2019
Introduction
The City Internal Auditor is responsible for providing: (a) an independent appraisal of City
operations to ensure policies and procedures are in place and complied with, inclusive of
purchasing and contracting; (b) information that is accurate and reliable; (c) assurance that assets
are properly recorded and safeguarded; (d) assurance that risks are identified and minimized; and
(e) assurance that resources are used economically and efficiently and that the City's objectives
are being achieved.
The City Auditor's Office has completed a performance audit of the Property Room Unit of the
Police Department. We conducted this performance audit in accordance with generally accepted
government auditing standards. Those standards require that we plan and perform the audit to
obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objectives. We believe that the evidence obtained provides a
reasonable basis for our findings and conclusions based on our audit objectives.
Management Responsibility
City management is responsible for ensuring: resources are managed properly and used in
compliance with laws and regulations; programs are achieving their objectives; and services are
being provided efficiently, effectively, and economically.
Audit Objectives, Scope, and Methodology
This report is intended to provide assurance on the City's ability to properly record and safeguard
high-risk property and evidence items — defined as narcotics, currency, and firearms — by
evaluating:
• The effectiveness of the Property Room's physical environment to maintain property and
evidence items in an appropriate condition; and
• The effectiveness of internal controls over high-risk property and evidence items to
adequately mitigate risk of theft and malfeasance.
Audit fieldwork was conducted during January 2019. The following summarizes major procedures
performed during this time. The scope of review varied depending on the procedure being
performed.
• Reviewed documentation to develop criteria including industry standards, best practices,
previous audit reports, and policies and procedures;
• Interviewed relevant City staff and property and evidence room staff in similar
municipalities;
• Developed a process narrative to identify current control activities, which was certified by
the Property Room supervisor;
• Analyzed relevant documentation including supervisory reports and access logs from 2016-
2018 and Records Management System (RMS) data from 2002-2018;
• Observed and documented Property Room conditions; and Ln
The City of Denton Internal Audit Report Audit of the Police Property Room
June 2019
• Performed an inventory of Property Room high-risk items using a randomly selected
statistical sample of 270 items entered between 2002 and 2018.1
Background Information
The Unit stores items that are highly vulnerable to the risk of theft due to their street value and
potential for misuse. Therefore, security and accountability of these properties are critical. The
Property Room Unit is responsible for safeguarding evidence items collected by Police detectives
and officers as well as found property and property submitted for safekeeping.
The Unit is comprised of two Civilian Property Technicians and a Lead Civilian Property Technician
and is organizationally placed within the Administrative Division of the Police Department.
Technicians must maintain the chain of custody by documenting where items are stored, if they
are checked out and, when and by whom items were moved. Improperly maintaining an evidence
item's chain of custody could have disastrous consequences to an investigation or trial and could
potentially damage the City's reputation.
The Unit disposes of items when appropriate; high-risk items may be destroyed, released, or
deposited depending on the item type.While found property can be easily disposed,evidence item
disposal must be authorized by a court and thus takes more time. In addition, Property Technicians
must identify cases that are closed and initiate the disposal process themselves. Figure one
provides a simplified illustration of a high-risk evidence item's life cycle.
Figure 1: Life Cycle of High-Risk Evidence Items
Property
•Seizes Item Room •Authorizes disposition
•Submits Item to the (Court,District
Property Room •Processes and Stores Attorney)
Item •Receives or destroys
•Maintains Item Chain the item
of Custody
•Researches Case Status
Officer 3rd Party
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1 This sample size provides with 90%confidence that the true population is±5%of the sample estimate.
The City of Denton Internal Audit Report Audit of the Police Property Room
June 2019
Compared to similar municipalities,the Unit's workload is about average.
Figure 2: Average Items Entered per Staff Member
1,000,000 Average
900,000 A
800,000
700,000 Fort Worth
Y 600,000
500,000 I Plano
a 400,000 I Y
300,000 1 ijhhnrk �A Denton
200,000
100,000 ♦Waco
0--San M rcos I 41L College Station
1,000.00 2,000.00 3,000.00 4,000.00 5,000.00
Items Entered/Staff
Throughout this report, the City's Property Room policies, procedures, and practices have been
compared to the International Association for Property and Evidence's (TAPE) professional
standards.The IAPE is a non-profit organization that was established in 1993 and provides training,
certification and accreditation programs, and other resources to property and evidence
organizations throughout the United States and Canada. The professional standards cover all
aspects of a property and evidence room and identify narcotics,currency,and firearms as the most
vulnerable items.
What Works Well?
Staff has Mitigated Some Property Room Facility Weaknesses
The Property Room is currently divided into two sections—the Main Property Room and the
Evidence Cage—both located inside of the Police Station. Property Technicians are officed in a
room that is directly connected to the Main Property Room;the Evidence Cage is about a minute
walk from this office through and out of the Property Room.The auditors found the following:
• Property Room facilities are adequately lit, and a backup generator powers all essential
evidence storage equipment.
• The property and evidence tracking and organizational system,though not efficient, is
generally effective.
• Police Department policy appropriately restricts access to Property Room facilities to only
essential personnel; all visitors are recorded on an access log and monitored by Technicians
while inside the property room.These procedures will aid an investigation if an item is
discovered missing.
• Property Technicians are drug tested at least annually.
• Property Room facility doors are monitored by alarms that are tested weekly, which aids in
detecting outside intrusions.
The City of Denton Internal Audit Report Audit of the Police Property Room
June 2019
• The Property Room's location within the Police Station expedites the packaging and
processing of evidence and property items.
• Constant Police presence, especially after-hours, discourages theft and decreases the
reaction time if an intrusion occurs.
Internal Controls Over High-Risk Inventory Have Improved Over Time
Audit procedures inventoried 270 high-risk inventory items that had been submitted to Property
Technician custody between 2002 and 2018. During this time, 117 items(43.3%)were disposed via
release, deposit, diversion, or destruction. The other 153 items (56.7%) were tracked within
Property Room facilities.The auditors found the following:
• Generally, all observed item packaging was adequately sealed and labels appropriately
described and identified the items contained; all but one narcotics item was located and
examined.
Table 1: Sample Tracking Results (2014-2018)
Status Count
Found 148
Wrong Location 4
Missing 1
Total Items: 153
• Since 2008,the average processing time for high-risk inventory items has been appropriate.
• Most high-risk items (61.1%) are not checked out of the Property Room during their lifetime.
• The last item with inadequate check out documentation was entered in 2004.
• The currency long-term storage location provides appropriate security measures, including
requiring a separate key to open,which is held by an individual without access to the Property
Room. Use of the key is logged and requires an appropriate purpose for use.
• In the past five years, documentation of releases, deposits, and diversion have been adequate
except for firearms and drugs (see Table 2).
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z Processing time is calculated as the number of days between when an item was seized by an Officer and when the item was stored by the
Property Room Technician.Given that Technicians do not work on weekends,but items are still seized,an appropriate processing time was
defined as less than 2 days.
The City of Denton Internal Audit Report Audit of the Police Property Room
June 2019
Table 2: Sample Disposal Results (2014-2018)
Type Count' Adequately
Documented?
Narcotic Destructions 70 No
Currency Releases 8.5 Yes
Currency Deposits with the City 7 Yes
Currency Deposits with the County 6.5 Yes
Firearm Releases 17 Yes
Firearm Diversions 1 Yes
Firearm Destructions 7 No
Total Items: 117
Opportunities for Improvement
Facilities are Inadequate for Evidence Item Storage
On average,the Unit accepts just under 11,000 property and evidence items annually and currently
has over 100,000 items in their facilities—about 15%of inventory items are high-risk.The Unit has
averaged about a 39%disposal rate over the last ten years.
What We Found?
• One exterior wall of the Main Property Room is made of plywood that can easily be cut or
broken through (Picture 1).
• Two entrances to this facility have hinges facing outside of the Property Room, allowing for
easy removal.
• The Property Technicians'office has a service windowthat—though it may be locked—provides
much easier access than allowable by IAPE standards (Picture 2).
• The Evidence Cage is made of chain-link fencing that can be easily cut into (Picture 3).
• Facility areas were crowded and will not allow room for all growth projected over the next ten
years.
• The auditors observed at least one area of floor inside the Property Room with permanent
water damage (Picture 4).
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3 One of the sampled currency items had money that was released to the owner and deposited with the County.
The City of Denton Internal Audit Report Audit of the Police Property Room
June 2019
Picture 4:Prop.Room Exterior Wall
—' rt Picture 4:Service Window
Picture 4:Evidence Cage Picture 4:Water Damage
On February 41", 2019, City Council reviewed a space-needs study of the Police Department and
Public Safety Dispatch, which included additional space for the Property Room Unit.As these plans
move forward, consideration should be given to IAPE standards. Police staff have recommended
renovating the existing Police Station and constructing a new Police Substation, both of which
would complete construction in 2022.
Why Does It Matter?
The documented departures from IAPE's security standards increase the risk of theft from outside
individuals. Specifically, the Evidence Cage may be very easily broken into—items with evidentiary
value should not be stored in this area. Crowding increases the likelihood that items will be
misplaced or lost due to organizational issues.While this is not generally an issue now,the Property
Room inventory will continue to grow due to population growth and disposal rate— exacerbating
the matter.
Based on growth trends from 2009 through 2018, we expect the Property Room Inventory to
double in size by 2028. Before construction completes, more than 45,000 items will be added to
the Property Room inventory. The existing property room may not accommodate the expected
addition to property count during this time.
Staff should be commended for attempting to mitigate flooding issues, however, water damage
can potentially destroy the evidentiary value of items. These issues should not be allowed to 0
persist. r—I
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The City of Denton Internal Audit Report Audit of the Police Property Room
June 2019
Recommendations (High Priority):
1. Until permanent solution is found, temporarily relocate all property and evidence inventory
items to the large empty warehouse behind the Narcotics office to address the short-term,
critical need. This can be accomplished with relatively small amount of resources.
2. Require the Property Room Unit to conduct comprehensive inventory count during the move
to account for every item in its inventory with an increased focus on necessary disposals.
Property Room Security Measures Do Not Adequately Mitigate the Risk of Internal
Theft
General security controls over the Property Room adequately prevent and detect external threats
to property and evidence items; however, controls should be further strengthened to prevent,
detect, and correct internal threats.
What We Found?
Access Controls
• Before employment begins, most Police Department employees — including Property
Technicians—undergo a thorough background check; however,this procedure is not repeated
when employees transfer to more sensitive areas within the Department.
• Entrance to Property Room facilities requires dual authentication measures via a physical key
and electronic "fob" access. A review of electronic access identified that three unauthorized
employees had "fob" access to one of three doors into the Main Property Room.
• Evidence items checked out to Officers are not periodically monitored. No policy exists that
defines how long officers can check out evidence.
Personnel Verification
• Police policy requires Property Technicians to undergo a drug test at least annually.
Monitoring Controls
• Current security camera placement monitors entry points in the Main Property Room and the
Evidence Cage. Security camera footage is stored for 60 days and is not regularly reviewed.
• Monitoring responsibility for the Property Room is placed solely with the Property Room Unit
who can reposition some cameras, which can possibly prevent detection of potential
wrongdoing. Cameras are not always monitored during business hours due to staff workload.
Independent Review
• Police Department policy requires the Property Room Unit to undergo quarterly audits and
biannual inspections by independent Police Department staff.
• Quarterly audit procedures require five narcotics, currency, and firearm items to be
examined each quarter—resulting in a total of 60 high-risk items being inventoried annually.
This is less than 1%of the high-risk items currently in the inventory.This is an inadequate
coverage as it would take number of years before full verification of existing inventory is
accomplished. r—I
• A full inventory of Property Room items has not been performed.
The City of Denton Internal Audit Report Audit of the Police Property Room
June 2019
• Biannual inspections were not being performed due to staff oversight.
Why Does It Matter?
Access Controls
• A dual authentication system provides further assurance that unauthorized access is
prohibited. Allowing unauthorized electronic access to the Property Room compromises this
system and increases the risk of theft.
• Allowing evidence items to be removed from the Property Room for longer period than
necessary increases the risk that they may be stolen or lost.
Personnel Verification
IAPE standards require all staff to undergo a thorough background check before being assigned to
a Property Room—even if transferring from within the Police Department. Personal history checks
provide assurance that the integrity of the evidence system is protected by appropriate individuals.
Given the nature of evidence items, periodic assurance should be provided through drug tests and
financial disclosures.
Monitoring Controls
IAPE standards require security camera footage to be stored for at least three or four years, so as
not to inappropriately restrict investigations if a missing item is identified. Likewise, placing sole
monitoring responsibility of the Property Room with Property Technicians increases the risk of
internal theft—especially due to irregular monitoring and potential camera movement.
Independent Review
Failure to verify all inventory items — especially high-risk items — increases the likelihood that a
missing item will go unnoticed for an unacceptable length of time and hinder an investigation.
Inspections are meant to ensure that Property Room policies and procedures are adequately
mitigating risk.
Recommendations:
3. Revise the General Order to ensure a background check is performed on all staff before they
are assigned to the Property Room. A thorough background check includes: a criminal history
check, sex offender registries, prohibited weapons possession status, drug testing, financial
disclosure, and a polygraph. Consider requiring periodic credit checks similarly to drug testing.
4. Annually verify that only authorized employees have electronic access to the Property Room.
Access reports can be easily and quickly run by Facilities when requested.
5. Establish a formal policy for checking out evidence items. Enforce this policy, ensuring better
monitoring of evidence items that have been checked out to officers along with proper follow-
ups.
6. Store security camera footage for at least three years and require periodic review by someone
independent of Property Room staff.
7. Consider requiring the Dispatch Unit to monitor Property Room cameras.4 A clear reporting
policy should be established to ensure unusual or suspicious activity is appropriately
investigated.
4 Currently the Police Dispatch Unit has access to Property Room cameras and consistently monitors other areas of the Police Station.
The City of Denton Internal Audit Report Audit of the Police Property Room
June 2019
8. Adjust policy to ensure that at least all high-risk inventory items are reviewed annually.
Biannual inspections should be performed according to policy.
Inventory Integrity Cannot be Assured
All property and evidence items collected by Police Officers are submitted to the Property Room
Unit on physical Evidence Sheets. Typically, an original copy of this Evidence Sheet is placed in
Laserfiche by the Officer. Property and evidence items on the Evidence Sheet are then entered into
the Police Department's Records Management System (RMS) by Property Technicians; however,
the Property Room Unit generally relies on physical copies of Evidence Sheets to locate and track
items.
What We Found?
Segregation of Duties
• The evidence information is created and stored in several ways as follows:
o Evidence Sheets stored in Laserfiche by Police Officers provide an independent record of
items submitted to the Property Room, however, it is difficult if not impossible to compile
these records into a single auditable list. This prevents anyone from providing assurance
that all items collected by Officers are being safeguarded by the Property Room Unit.This
record is not usable to perform any analysis or extract information.
o The information is also input by the Property Technician into the Police Department
Records Management System (RMS). We observed that this record is not always
accurate. There no way to know if this record is complete.
o The Property Technician also record chain of custody information on the physical copy of
the evidence sheet. These documents are filed in binders and kept in the property room.
Like RMS records, it is not possible to ensure accuracy or completeness of this record.
• One Property Technician and the Lead Property Technician can and have deleted evidence
records in RMS. RMS maintains an audit log of these deletions, however, it has not been
reviewed.
Missing Item Procedures
• Formalized procedure does not exist that requires Property Room staff to follow up if an item
is discovered to be missing. In addition, there is not a formal threshold to initiate an
investigation when items are discovered missing.
Why Does It Matter?
Segregation of Duties
• IAPE standards require that separate individuals perform the duties of collecting evidence,
storing evidence, and authorizing movement (including disposal) of evidence. It is imperative
that this segregation of duties remain intact to provide assurance that the Property Room
inventory is complete.
• Currently,this assurance cannot be provided because Property Technicians are responsible for
entering the collection and storage of evidence items into RMS and these records cannot be
easily verified to the Evidence Sheets produced by Officers.
The City of Denton Internal Audit Report Audit of the Police Property Room
June 2019
• RMS could be used for verification of inventory items; however, potentially the system could
be manipulated by Property Technicians via omission of items or deletion of records.
According to the Technology Services Representative,the existing LaserFische software has optical
character reading(OCR) capability. This feature allows scanning of the hand written and/or typed
document and convert the information into a searchable database. This feature can be useful to
independently capture unalterable information to ensure integrity of the evidence data. This
information may be converted in more usable format to the Property Room operations.
Missing Item Procedures
• Allowing responsibility for investigating missing items to remain ambiguous potentially hinders
an investigation and increases the change that a perpetrator will not be identified.
Recommendations (High Priority):
9. Work with the Technology Services to implement OCR capability of LaserFische software to
capture and manage evidence data to ensure the integrity of data and improve controls over
evidence.
10. Eliminate Property Technicians' privilege to delete system records.
11. Establish a procedure to notify Property Room Unit superiors if an item is found missing.
Appropriate criteria must be developed to initiate an investigation when necessary.
Long-term Storage Locations of Some High-Risk Items Should Be Further Secured
Within the Property Room, narcotics and firearms are generally stored in separate rows of two
different sets of roll cabinets. Currency and other valuables are stored in a vault. High-risk items
pending destruction and some items pending deposit are moved to separate locations.
What We Found?
Long-Term Storage
• The roll cabinets and vault are monitored by security cameras.
• Roll cabinets are kept unlocked during business hours; all Property Room Unit staff have keys
to unlock these cabinets.
• Only one set of roll cabinets has adequate ventilation for narcotics storage. Proper ventilation
is required to prevent the unique health and environmental hazards presented by storing
narcotics items.
• A count of the currency stored in the Property Room is kept, however, it is not regularly
updated and is accessible by all Unit staff.
Pending Disposal Storage
• Narcotics pending destruction are verified and sealed into a Destruction for Narcotics (DFN)
box by two Property Technicians and stored until they are transported. These boxes are not
always monitored by a security camera.
The City of Denton Internal Audit Report Audit of the Police Property Room
June 2019
• Firearms pending destruction are stored on a disposal shelf that is monitored by security
cameras.
• Some currency items pending deposit to the City are stored in a binder in the Property Room
Office, accessible to all staff.
Why Does It Matter?
High-risk items are the most vulnerable for theft because of their potential market value. In
addition, items pending destruction are even more vulnerable because they are no longer needed
for an investigation or trial.Thus, all high-risk items—even those pending destruction—should be
placed under enhanced security measures past those of general property and evidence items, as
required by IAPE standards.
The IAPE recommends using a "rule of two," which would require the presence of two staff
members to access the secure items.This"rule of two" may be created by using two different locks
on the storage container, locker, or room/vault.
Recommendations:
12. Store all high-risk items, including those marked for destruction or deposit, in locations with
enhanced security measures. High-risk items should be separated by category but may share
a location with enhanced security measures such as a "Narcotics Cage," "Weapons Vault," etc.
13. Install an adequate ventilation system above all narcotics storage areas.
14. Maintain an up-to-date count of currency stored in the Property Room.
Controls Over High-Risk Destructions Can Be Easily Improved
The inventory procedure reviewed the documentation of 77 (28.5%) items marked as destroyed.
What We Found?
• Between 2014 and 2018, the Unit adequately documented destruction authorization, staging,
transportation, and witnessing, however, documentation of item verification is lacking.
• There was evidence that some older items marked for destruction were being verified by
Property Technicians, however, this evidence was not available for recent destruction
documentation.
• Item destruction and deposit lists were accessible by all Property Technicians and there was
no record of changes made to these lists. Appropriate verification cannot be completed
without a record of items to be destroyed that cannot be manipulated by Unit staff.
Why Does It Matter?
IAPE standards require that destruction documentation include independent authorization and
verification of each item and the identity and certification of who staged, verified,transported, L1)
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and witnessed the destruction of each item.
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The City of Denton Internal Audit Report Audit of the Police Property Room
June 2019
In combination,these control deficiencies present an unacceptably high risk of theft. Theft or loss
of high-risk items may be detrimental to an investigation, could be harmful to the City's
reputation, and could have potential to decrease the public safety.
Recommendations (High Priority):
15. Require an independent witness to perform or oversee the verification for high-risk items
marked for destruction. Verification documentation should be maintained and should include
the signatures of who was involved.
16. Maintain an independent record of high-risk items marked for destruction.
Funding Should be Provided for Untested Sexual Assault Kits
In 2011, the Texas state legislature enacted a law requiring law enforcement agencies to send all
newly collected sexual assault kits to a crime lab for testing within 30 days. In addition, the law
required these agencies to count the untested sexual assault kits in their storage facilities and to
have them analyzed by September 2014.
What We Found?
Prior to 2011, Police Department policy required Property technicians to receive officer instruction
before sending sexual assault kits to be tested. This policy has since changed, and all collected
sexual assault kits are now sent to the City's partner laboratory for testing immediately. However,
Property Room staff informed us that about 90 sexual assault kits collected prior to 2010 were
found to be untested.
The City's partner laboratory has refused to accept these untested kits for analysis due to backlog
issues. This has required the Police Department to identify a separate laboratory to conduct the
testing, which requires additional funding. As of the issuance of this report, the Police Department
has identified a laboratory' and funding to analyze about ten of these kits, however, additional
funding will be needed to complete this process.According to staff,the Police Department is in the
process of applying for a federally-funded, competitive grant to help cover these costs.
Why Does It Matter?
The City must comply with Section 420.042 Analysis of Sexual Assault Evidence of the Local
Government Code.
Recommendation:
17. Necessary funding needs to be provided to the Police Department for analyzing of old,
untested sexual assault kits.
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S The selected laboratory will only accept five untested kits per month due to work load issues.
CITY
OF WM
DENTON
Department of Police
601 E. Hickory St., Suite E • Denton,TX 76205 • (940) 349-8181 • FAX (940) 349-7966
MEMORANDUM
Denton Police Department
Office of the Chief of Police
TO: Chris Watts, Mayor/City Council
CC: Todd Hileman, City Manager
FROM: Frank Dixon, Chief of Police
DATE: February 28, 2019
SUBJECT: Denton Police Department Property Room Audit
Mr. Mayor and Council Members,
This memorandum is being written in response to an internal performance audit completed by the City Internal
Auditor's Office on the DPD Property Room. In January 2019,the Auditor's Office conducted fieldwork,
reviewing documentation, including best practices, industry standard, previous audit reports, and DPD policies
and procedures. Upon the receipt of the final audit report, I met with the Auditor's Office to receive a briefing
on their findings.The DPD Property and Evidence staff enters almost four thousand items of evidence per year.
With a staff of three, including two property technicians and one lead, this is high in number. Although staff
does a tremendous job, despite the overall functionality of the space provided, a few areas in need of
improvement were identified.There were also areas where staff has positively mitigated the challenges
identified.These include:
CITY
OF WM
DENTON
Department of Police
601 E. Hickory St., Suite E • Denton,TX 76205 • (940) 349-8181 • FAX (940) 349-7966
• Property Room facilities are adequately lit, and a backup generator powers all essential evidence
storage equipment.
• The property and evidence tracking and organizational system,though not efficient, is generally
effective.
• Police Department policy appropriately restricts access to Property Room facilities to only essential
personnel; all visitors are recorded on an access log and monitored by Technicians while inside the
property room.These procedures will aid an investigation if an item is discovered missing.
• Property Technicians are drug tested at least annually.
• Property Room facility doors are monitored by alarms that are tested weekly,which aids in detecting
outside intrusions.
• The Property Room's location within the Police Station expedites the packaging and processing of
evidence and property items.
• Constant Police presence, especially after-hours, discourages theft and decreases the reaction time if an
intrusion occurs.
• Since 2008,the average processing time'for high-risk inventory items has been appropriate.
• Most high-risk items (61.1%) are not checked out of the Property Room during their lifetime.
• The last item with inadequate check out documentation was entered in 2004.
• The currency long-term storage location provides appropriate security measures, including requiring a
separate key to open,which is held by an individual without access to the Property Room. Use of the key
is logged and requires an appropriate purpose for use.
• In the past five years, documentation of releases, deposits, and diversion have been adequate.
Opportunities for improvement, with our responses include:
• Generally, all observed item packaging was adequately sealed and labels appropriately described and
identified the items contained; all but one narcotics item was located and examined. The one item was
logged as evidence in a federal court case. We are currently working with our federal partners to
determine if they have or destroyed the item once the case was adjudicated.
• Facilities are inadequate for evidence item storage. We are currently working with the City Manager's
Office to improve the overall building conditions at DPD. The evidence room is one of the areas
identified as a priority. City staff presented potential plans for renovation or new construction to
Council in February.
'Processing time is calculated as the number of days between when an item was seized by an Officer and when the item was stored by the Property Room
Technician.Given that Technicians do not work on weekends,but items are still seized,an appropriate processing time was defined as less than 2 days.
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Department of Police
601 E. Hickory St., Suite E • Denton, TX 76205 • (940) 349-8181 • FAX (940) 349-7966
• One exterior wall of the Main Property Room is made of plywood that can easily be cut or broken through.
That wall faces the enclosed and secured sally port, which is only accessible by credentialed personnel.
That area is also under video surveillance at all times.
• Two entrances to this facility have hinges facing outside of the Property Room, allowing for easy removal.
The entrances are within the secure portion of the police department. Without having proper
credentials, it is not possible to gain access to them. The room is monitored by video surveillance at all
times.
• The Property Technicians' office has a service window that — though it may be locked — provides much
easier access than allowable by IAPE standards. The Property Room in located within the secured police
facility. Evidence is not stored in the technician's office space, and a separate door is secured from their
office into the actual storage location. It is monitored by video surveillance at all times. We are in the
process of preparing to refurbish the building, which will allow us to re-design the space without a
window.
• The Evidence Cage is made of chain-link fencing that can be easily cut into. The evidence cage is located
within the secure police facility. The plan for renovation or construction will offer DPD the opportunity
to have a properly built,spaced, and secured evidence cage. This is also monitored at all times via video
surveillance.
• Facility areas were crowded and will not allow room for all growth projected over the next ten years. The
plans for renovation or new construction will resolve the functionality and space limitations of the
current facility.
• The auditors observed at least one area of floor inside the Property Room with permanent water damage.
The plans for renovation or new construction will resolve this issue.
Whether the police facility is remodeled or moved to new construction, all areas of the Property and Evidence
Room will meet or exceed IAPE standards.
• Until permanent solution is found, temporarily relocate all property and evidence inventory items to the
large empty warehouse behind the Narcotics office to address the short-term, critical need. This can be
accomplished with relatively small amount of resources.
• #1 This has been completed during the month of February 2019.
• Require the Property Room Unit to conduct comprehensive inventory count during the move to account
for every item in its inventory with an increased focus on necessary disposals.
0 #2 This has been completed during the move mentioned above.
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Department of Police
601 E. Hickory St., Suite E • Denton, TX 76205 • (940) 349-8181 • FAX (940) 349-7966
• Before employment begins, most Police Department employees—including Property Technicians undergo
a thorough background check; however,this procedure is not repeated when employees transfer to more
sensitive areas within the Department.
• #3 Since there is a policy mandating that employees disclose any contact with law enforcement to their
chain of command, there will be a portion of the transfer policy to capture a new background check if
an employee transfers into a more sensitive area.
• Entrance to Property Room facilities requires dual authentication measures via a physical key and
electronic "fob" access. A review of electronic access identified that three unauthorized employees had
"fob" access to one of three doors into the Main Property Room.
• #4 The fob access controls have been corrected as of February 2019.
• Evidence items checked out to Officers are not periodically monitored. No policy exists that defines how
long officers can check out evidence.
• #S While there are a myriad of reasons that an officer may need to check out items of evidence, there
will be enhanced tracking and mandating weekly updates on items of evidence checked out by officers
until they are returned, released, or destroyed per policy.
• Current security camera placement monitors entry points in the Main Property Room and the Evidence
Cage. Security camera footage is stored for 60 days and is not regularly reviewed.
• #7 1n the Evidence/Property Room Standard Operating Procedures, a cursory check of the video will
occur in the first hour of the workday from the preceding night, and Monday morning for weekend
footage. We have asked City of Denton IT to store the video longer, up to 240 days, which will mirror
our ability to discipline employees per our Meet and Confer Agreement.
• Monitoring responsibility for the Property Room is placed solely with the Property Room Unit who can
reposition some cameras,which can possibly prevent detection of potential wrongdoing. Cameras are not
always monitored during business hours due to staff workload.
• #6 While staff currently has the ability to reposition cameras, any noted difference in camera footage
will be immediately reported to the Lieutenant assigned to the Property/Evidence Room. The Property
Room policy will prohibit the repositioning of cameras, unless approved by the assigned Deputy Chief,
Assistant Chief, or Chief of Police.
• Police Department policy requires the Property Room Unit to undergo quarterly audits and biannual
inspections by independent Police Department staff.
• Quarterly audit procedures require five narcotics, currency, and firearm items to be examined each
quarter— resulting in a total of 60 high-risk items being inventoried annually. This is less than 1% of the
high-risk items currently in the inventory.This is an inadequate coverage as it would take number of years
before full verification of existing inventory is accomplished.
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601 E. Hickory St., Suite E • Denton, TX 76205 • (940) 349-8181 • FAX (940) 349-7966
• #8 We will adhere to best practices in the auditing of high-risk items.
• A full inventory of Property Room items has not been performed.
• When the Property and Evidence Room is relocated, staff will conduct a full inventory. In their current
space, it would take over one year of constant auditing to complete this.
• Biannual inspections were not being performed due to staff oversight.
• #8 The Manager assigned to manage the Property and Evidence Room will ensure that biannual
inspections are completed, and that those findings are memorialized and stored in a restricted drive.
• RMS allows for effective verification of inventory items; however, potentially the system could be
manipulated by Property Technicians via omission of items or deletion of records.
• One Property Technician and the Lead Property Technician can and have deleted evidence records in RMS.
RMS maintains an audit log of these deletions, however, it has not been reviewed.
• #8 The assigned Manager will ensure that a quarterly audit is completed for RMS logs. In addition, the
City is currently in the process to purchase and implement an up to date RMS system that will allow for
more efficient audits. This will digitally log any time a record is accessed, modified, or deleted, leading
to better oversight. Only the Lead Property Technician will have access to delete evidence, after
documenting the reason behind it in a supplemental offense report.
• Formalized procedure does not exist that requires Property Room staff to follow up if an item is discovered
to be missing. In addition, there is not a formal threshold to initiate an investigation when items are
discovered missing.
• #11 The new Property and Evidence Room Standard Operating Procedure manual will mandate an
immediate notification and Internal Affairs investigation occur when a high-risk item is found to be
missing. This will also trigger an overall audit, consistent with best practices.
• IAPE standards require that separate individuals perform the duties of collecting evidence, storing
evidence,and authorizing movement(including disposal)of evidence. It is imperative that this segregation
of duties remain intact to provide assurance that the Property Room inventory is complete.
• Currently, this assurance cannot be provided because Property Technicians are responsible for entering
the collection and storage of evidence items into RMS and these records cannot be easily verified to the
Evidence Sheets produced by Officers.
• #9 The current staffing allocated to the Property and Evidence Room will not allow for this separation
of duties. DPD is in the process of purchasing a new Records Management System which will take away
the need to use paper evidence forms and switch to all digital forms.
0 Eliminate Property Technicians' privilege to delete system records.
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Department of Police
601 E. Hickory St., Suite E • Denton,TX 76205 • (940) 349-8181 • FAX (940) 349-7966
• #10 The lead technician will be allowed to delete items, with a notification made to the manager
assigned to the Property and Evidence Room. Under the new Records Management System this will be
all digitally logged,notification sent to the manager,both of which can also be tracked.
• The roll cabinets and vault are monitored by security cameras.
• Roll cabinets are kept unlocked during business hours; all Property Room Unit staff have keys to unlock
these cabinets.
• Only one set of roll cabinets has adequate ventilation for narcotics storage. Proper ventilation is required
to prevent the unique health and environmental hazards presented by storing narcotics items.
• #12 The renovation or new construction will address this concern.
• A count of the currency stored in the Property Room is kept, however, it is not regularly updated and is
accessible by all Unit staff.
• #14 When conducting their quarterly audit, all currency will be counted and recorded, per the new
Property and Evidence Room Standard Operating Procedure.
• Narcotics pending destruction are verified and sealed into a Destruction for Narcotics (DFN) box by two
Property Technicians and stored until they are transported. These boxes are not always monitored by a
security camera.
• Firearms pending destruction are stored on a disposal shelf that is monitored by security cameras.
• Some currency items pending deposit to the City are stored in a binder in the Property Room Office,
accessible to all staff.
• #14 As we move forward with the design of a renovated or newly constructed Property and Evidence
Room, the proper storage of narcotics,firearms,and currency will be addressed. There is no mechanism
in place to allow for us to complete this.
• Between 2014 and 2018, the Unit adequately documented destruction authorization, staging,
transportation, and witnessing, however, documentation of item verification is lacking.
• There was evidence that some older items marked for destruction were being verified by Property
Technicians, however,this evidence was not available for recent destruction documentation.
• Item destruction and deposit lists were accessible by all Property Technicians and there was no record of
changes made to these lists. Appropriate verification cannot be completed without a record of items to
be destroyed that cannot be manipulated by Unit staff.
• #15416 DPD will work to formalize an independent witness for evidence destruction and verification
moving forward. This will be included in the Property Room Standard Operating Procedure manual.
• In 2011,the Texas state legislature enacted a law requiring law enforcement agencies to send all newly
collected sexual assault kits to a crime lab for testing within 30 days. In addition,the law required these
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Department of Police
601 E. Hickory St., Suite E • Denton,TX 76205 • (940) 349-8181 • FAX (940) 349-7966
agencies to count the untested sexual assault kits in their storage facilities and to have them analyzed by
September 2014.
• DPD is in the process of applying for a Department of Justice Sexual Assault Kit Initiative grant, which
will fund testing of old kits,purchase some needed equipment upgrades, and provide training for staff
centered around sexual assault investigations.
• Prior to 2011, Police Department policy required Property technicians to receive officer instruction before
sending sexual assault kits to be tested.This policy has since changed, and all collected sexual assault kits
are now sent to the City's partner laboratory for testing immediately. However, Property Room staff
informed us that about 90 sexual assault kits collected prior to 2010 were found to be untested.
• #17 DPD has been working to get the backlogged kits out and tested. To date, 10 kits have been sent to
the Texas Department of Public Safety Lab for testing, analyzation and entry into CODIS. The
department is in the process of applying for a Department of Justice Sexual Assault Kit Initiative Grant
to fund backdated kits, and for training and equipment to improve our overall response to sexual
assaults. DPD will be working with the University Of North Texas Forensic Science Center, Friends of the
Family, Denton County District Attorney's Office, and the Children's Advocacy Center of Denton County
to improve response to, educate our community, and criminally prosecute offenders in sexual assault
cases. These partnerships will be related to the SAKI grant mentioned above.
I, along with all DPD staff are committed to identifying, addressing, and critiquing the work that we do. This will
allow us to stay trusted and respected by the community we serve, and become a model agency for other law
enforcement organizations to model. We take all aspects of the Evidence and Property Room seriously, and will
work to implement these identified changes as soon as we can.
With Respect and Gratitude,
Frank R. Dixon
Chief of Police