By Cadhla McBride in Interpreter Access Project — 08 Mar 2026

Greece Police Department ADA Communication Policy Audit

Monroe County Interpreter Access Audit

Executive Summary

A review of records produced by the Town of Greece in response to Freedom of Information Law (FOIL) requests raises governance and documentation questions regarding interpreter access and communication accommodations for Deaf and hard-of-hearing individuals.

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.

The Greece Police Department maintains a written directive governing communication with persons with disabilities — Policy 333: Communications with Persons with Disabilities.

However, records produced during this audit indicate that the Town reported no documentation demonstrating operational implementation of that policy, including records identifying an ADA coordinator for the department, training materials related to the policy, or administrative implementation documentation.

A complaint submitted regarding these issues resulted in a written response from the department’s Deputy Chief of Internal Standards & Compliance, acknowledging that a policy discrepancy exists and will be addressed administratively.

The FOIL process also raised transparency concerns, including rolling extensions issued without a date certain, a denial under an information-technology security exemption, and several appeals that have not received determinations.

Taken together, the records produced describe a written policy governing communication with individuals with disabilities but limited documentation demonstrating how that policy has been operationalized.

Records Produced

The Town of Greece produced a limited number of records responsive to the FOIL requests associated with this audit.

Records identified include:

Greece Police Department Policy 333 – Communications with Persons with Disabilities
Interpreter services contract documentation associated with Tellmorr International

The Town reported that it possesses no responsive records for several requested categories, including:

records identifying an ADA coordinator for the police department
administrative designation records for that role
training materials related to Policy 333
training attendance records or rosters
administrative implementation documentation associated with the policy

For other request categories concerning incidents involving Deaf or hard-of-hearing individuals, the Town stated that portions of the request were “description insufficient” to locate records.

Governance Considerations

Policy Requirement and Administrative Structure

Greece Police Department Policy 333 establishes an administrative structure intended to support compliance with the Americans with Disabilities Act.

The policy provides:

“The Chief of Police shall delegate certain responsibilities to an ADA coordinator (28 CFR 35.107). The coordinator shall be appointed by and directly responsible to the Operations Bureau Deputy Chief or the authorized designee.”

This language creates a specific organizational requirement: the department must designate an ADA coordinator responsible for administering the policy.

However, in response to FOIL requests seeking records identifying the ADA coordinator and documentation of the role’s designation, the Town reported that it does not possess responsive records identifying such a position for the police department.

The department’s responses therefore describe a written policy requiring an ADA coordinator while simultaneously reporting that no records exist identifying such a position.

The absence of records identifying the position described in the policy raises questions regarding whether the administrative structure required by Policy 333 has been formally established.

Policy Training Requirements

Policy 333 also establishes training requirements for department personnel.

The policy states:

“The Administration Bureau shall maintain records of all training provided and will retain a copy in each member’s training file.”Policy-333-Communications_with_…

However, in response to FOIL requests seeking training materials and training records associated with Policy 333, the Town reported that it does not possess responsive records documenting such training.

The records therefore describe a written policy establishing training requirements while the Town simultaneously reported that it maintains no records documenting training associated with that policy.

Personnel Complaint – 26QSI-004

A complaint was submitted to the Greece Police Department concerning the absence of administrative documentation associated with Policy 333.

The department reviewed the complaint through its Internal Standards & Compliance Bureau and issued the following written response:

“I have reviewed your complaint, entered as tracking number 26QSI-004, and determined this is not a personnel complaint. Please note the policy discrepancy you brought to our attention is being addressed by the Deputy Chief of Administration in coordination with the Town. Policy will be updated upon final resolution.”

The response confirms that the department identified a policy discrepancy, but classified the matter as not constituting a personnel complaint.

A follow-up inquiry requested clarification regarding the criteria used to determine that a command-level failure to comply with a mandated policy requirement does not constitute a personnel complaint.

At the time of publication, no response to that inquiry had been received.

Interpreter Access Structure

The only interpreter-related document identified during the request process was a contract associated with Tellmorr International.

The Town indicated that this contract is held by the Greece Town Court, not the police department, and it was produced as the department’s only interpreter-services record responsive to the request.

The records produced therefore do not identify a police-department interpreter services agreement governing field operations.

Police encounters requiring effective communication with Deaf individuals frequently occur during:

traffic stops
accident investigations
roadside interviews
custodial interactions

The records produced do not clarify how interpreter access is operationalized during those encounters.

Documentation and Operationalization

The records produced describe a policy that establishes specific administrative and training obligations, including the appointment of an ADA coordinator and the maintenance of training records.

The Town’s FOIL responses simultaneously reported that no records exist documenting the ADA coordinator role or training required by the policy.

Taken together, the record describes a written policy establishing compliance structures while the Town reported that no documentation exists showing those structures have been implemented.

FOIL Process Timeline

December 3, 2025 — Initial Requests

FOIL requests were submitted seeking records relating to:

communication policies involving Deaf or hard-of-hearing individuals
interpreter services
ADA coordinator designation
training materials associated with Policy 333
RMS/CAD documentation relevant to communication assistance

One request specifically sought documentation related to the department’s CAD codebook, which can indicate whether dispatch systems include flags identifying disability-related communication needs during police encounters.

January 2026 — RMS/CAD Denial

The Town denied a request for RMS/CAD documentation under Public Officers Law §87(2)(i) (information-technology security).

The denial applied broadly to categories including vendor names, contracts, and system documentation.

FOIL generally requires agencies to release reasonably segregable non-exempt portions of records, and the denial did not identify specific records withheld or explain whether non-sensitive portions could be separated and released.

February 2, 2026 — Rolling Extension

The Town issued a notice stating that the requests required “another 20 days” to process.

The notice did not provide a date certain for production.

February 12, 2026 — Substantive Response

The Town issued a response stating that:

no records exist identifying an ADA coordinator for the police department
no training records exist related to Policy 333
portions of the request were deemed “description insufficient.”

Appeals

Administrative appeals were filed regarding several of the Town’s responses.

Appeals associated with the following requests remained unresolved at the time of publication:

FOIL Request #25-671
FOIL Request #25-672
FOIL Request #25-673

These appeals concern issues including rolling deadline extensions, “description insufficient” determinations, and the denial of RMS/CAD documentation.

Under Public Officers Law §89(4)(a), an agency must determine an administrative FOIL appeal within ten business days of its receipt.

At the time of publication, the appeals listed above had not received written determinations within that statutory time frame.

When an agency fails to determine an appeal within the time required by statute, the appeal is generally treated as constructively denied.

The absence of determinations on these appeals therefore represents an additional procedural transparency issue within the FOIL process itself.

Source Documents

Documents reviewed for this audit entry include: