Brockport Police Department ADA Communication Policy Audit
Executive Summary
Transparent Law Enforcement requested records from the Village of Brockport relating to how the police department provides communication access to individuals who are Deaf or hard of hearing during non-courtroom interactions.
This review is part of the Monroe County Interpreter Access Audit (MCIAA), an ongoing project examining how local agencies document interpreter access for Deaf or hard-of-hearing motorists.
The Village reported that it located no records responsive to the request.
No written policies, training materials, interpreter access procedures, or documentation requirements were produced for the Brockport Police Department.
On this record, a documented communication-access framework for field encounters is not identified. The materials provided do not show how communication decisions are structured, supported through training, or reviewed in practice.
The Village of Brockport is below the 50-employee threshold under 28 C.F.R. § 35.107 and is not required to designate an ADA Title II coordinator or adopt a formal grievance procedure. This review is limited to operational communication access during police encounters.
Update: A notice regarding this review has been issued to the Village of Brockport. [Read the notice]
Records Produced
The Village issued a formal disposition of:
“Denied – No record found.”
The response states that the Village conducted a search reasonably calculated to locate documents responsive to the request.
No records were produced identifying:
- policies governing communication with Deaf or hard-of-hearing individuals
- training materials related to communication access
- interpreter service agreements or vendor information
- procedures for requesting or obtaining interpreters
- documentation requirements for communication accommodations
No alternative operational description (such as informal practices or ad hoc procedures) was provided.
The response was issued by Barbara A. Krizen, Village Clerk (Records Access Officer), and copied to the Village Board and Village Attorney. The request was received February 24, 2026, and a response was issued March 20, 2026.
Governance Considerations
Absence of a documented communication framework
The request sought records governing interpreter access, field encounters, procedures for obtaining interpreters, and documentation of communication accommodations.
No records were produced in any of these categories.
The available record does not identify a defined system governing how officers are expected to communicate with Deaf or hard-of-hearing individuals during field encounters.
This differs from agencies that maintain written policies but cannot demonstrate implementation. In this case, neither a policy framework nor an operational structure is visible in the materials produced.
Auditability and operational visibility
Communication-access systems that are structured and repeatable typically generate administrative artifacts—policies, training records, interpreter agreements, activation procedures, and documentation reflected in incident reports.
No such materials were produced.
The available record does not show:
- how communication barriers are identified in the field
- what methods are used to resolve them
- whether interpreter services are available or used
- whether officers receive training on communication access
- how accommodations are recorded or reviewed
In the absence of defined procedures, communication barriers must be resolved at the officer level in real time. How those determinations are made and what standards guide them is not visible in the materials produced.
Availability vs. system design
In other Monroe County responses, including East Rochester, agencies without formal policies described availability-based approaches, such as locating a sign-language-trained officer or using ad hoc communication tools.
No such description was provided here.
The record does not indicate whether communication access is governed by a defined system, handled through informal availability-based methods, or addressed through another undocumented approach.
Source Documents
- Brockport FOIL request (Deaf/HOH communication access)
- Brockport FOIL response (March 20, 2026)
- Additional procedural history relating to this request is being documented separately.
Conclusion
- Policy Framework: Not identified in record
- Operational Procedures: Not identified in record
- Documentation Requirements: Not identified in record
- Implementation Evidence: Not assessable from record
The available record does not identify how communication access is structured or evaluated in practice
This review is part of the Monroe County Interpreter Access Audit (MCIAA), an ongoing Transparent Law Enforcement project examining how local agencies document interpreter access for Deaf or hard-of-hearing motorists.