Irondequoit Police Department ADA Communication Policy Audit
Monroe County Interpreter Access Audit (MCIAA) – March 2026
Executive Summary
Records produced by the Town of Irondequoit do not identify a police-specific policy, training framework, or operational procedures governing communication with Deaf or hard-of-hearing individuals.
The Town produced ADA-related training materials consisting of a third-party slide deck describing ADA Coordinator responsibilities. However, the production does not include any department-specific policy, directive, or implementation materials linking those concepts to police operations.
Records relating to ADA administrative structure—including Coordinator designation and grievance procedures—were not identified. Correspondence indicates these elements were under review at the time of response, with interim assignment of ADA-related responsibilities.
A disability-related request for reasonable modification was made within the FOIL process itself and remained without determination for an extended period before being addressed.
Taken together, the materials reflect an absence of documented operational systems and an administrative structure in transition.
A notice regarding this review has been issued to the Town [Read the notice]
Scope and Methodology
This review is based on records obtained through the New York Freedom of Information Law (FOIL), including:
- ADA-related training materials
- FOIL request and response correspondence
- Communications regarding ADA coordination and administrative processes
Evaluation Areas:
- Written policy framework
- ADA governance structure
- Interpreter access systems
- Operational implementation
This audit is limited to records produced and does not assess incident-level conduct.
Policy Framework
The production does not identify any written policies, general orders, or departmental directives governing communication with Deaf or hard-of-hearing individuals.
The Town produced a third-party training slide deck describing ADA Coordinator responsibilities. The materials do not indicate that this document constitutes an adopted police department policy or operational directive.
No materials connect ADA communication concepts to:
- Traffic stops or field encounters
- Investigations or custodial interactions
- Officer decision-making in real-time communication scenarios
The record reflects general administrative awareness of ADA requirements, but not a documented police-specific policy framework.
ADA Governance (Town and Department)
The materials do not identify:
- A designated ADA Coordinator
- A formal grievance procedure
- A defined ADA program structure
The Town produced ADA-related training materials describing ADA Coordinator responsibilities, but the production does not identify any individual assigned to that role or any documentation formalizing the position.
Correspondence indicates that ADA coordination and related processes were under review at the time of response, and that the Town Supervisor was identified as a temporary point of contact pending that review.
ADA governance appears transitional rather than defined.
Reasonable Modification (Process-Level Finding)
The record includes a disability-related request for reasonable modification concerning access to Town administrative processes—specifically, the ability to submit materials electronically in place of a mail-only “wet signature” requirement.
- The request remained without a written determination for an extended period
- Multiple follow-ups were required
- Resolution occurred only after escalation through counsel
- Electronic submission was ultimately permitted
This request arose within the FOIL process itself—linking ADA compliance to the mechanism used to request ADA-related records.
Resolution occurred outside a defined administrative process.
Interpreter Access Framework
The record contains no documentation describing how interpreter services are accessed or deployed in practice.
The materials do not include:
- Interpreter service agreements or vendor relationships
- Procedures for obtaining interpreters during field encounters
- Internal guidance governing interpreter use
The production does not describe a system for securing or delivering communication assistance during police interactions.
Operational Implementation
The materials do not include documentation showing how communication accommodations are implemented, tracked, or reviewed within police operations.
There are no:
- Department-specific training materials
- Training attendance or completion records
- Records reflecting interpreter use or communication accommodations
Without training records, usage documentation, or supervisory artifacts, the record does not support reconstruction of how communication needs are addressed in practice.
FOIL Process
The FOIL process reflects extended delays, incomplete follow-through on stated response timelines, and serial changes to submission requirements across correspondence cycles.
Documented patterns include:
- Missed or extended response timelines
- Appeals treated as requiring mailed submission with a “wet signature”
- Subsequent direction to use agency forms or resubmit requests
- Requests marked “complete” without resolving prior issues
Submission requirements changed across correspondence cycles rather than remaining fixed.
The Town initially required submission of certain materials by postal mail and did not accept email submissions. This requirement was later modified following a disability-related request for reasonable modification.
ADA-related requests were not consistently treated as distinct from FOIL processing.
Conclusion
Policy Framework
Not identified in record
ADA Governance
Not identified in record; described as under review, with interim assignment and ad hoc handling of a reasonable modification request
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.