Technical Assistance to the Boston Regional Intelligence Center (BRIC)
In October 2021, DHS I&A requested IIR provide technical assistance to the BRIC by reviewing a series of policies and procedures, assisting the BRIC with conducting a privacy impact assessment on an information technology system, and evaluating a recent surveillance technology ordinance.
In consult with DHS, the objectives for this project will be achieved by a collaborative team of P/CRCL experts, composed of IIR and subcontractor SMEs. The work of this project will be distributed across two grant awards. The primary activity undertaken by IIR personnel will be reported under this award. The work completed by the subcontractor SMEs will be reported under Grant Award number 2017-D6-BX-0001—State, Local, Tribal, and Territorial Information Sharing and Nationwide
Suspicious Activity Reporting Initiative Technical Assistance Program.
The policies under review by the team include:
1. Privacy, Civil Rights, and Civil Liberties Protection Policy
2. Social Media Policy
3. Threat
4. Tips and Leads
5. Request for Information
6. Collection and Product Development
7. Analysis
8. Criminal Intelligence File Guidelines
9. Outreach Plan
The contractor SMEs, and IIR personnel, convened at least 12 meetings with the BRIC Director and other BRIC personnel to discuss substantive issues related to the policies and procedures under review.
In early December 2021, IIR and a contractor SME provided support to the BRIC by assisting with the development of a privacy impact assessment (PIA) of its use of the Enterprise Insight Analysis (EIA) platform. To that end, IIR researched and identified a suitable PIA template for use in the process and requested relevant documentation related to EIA such as vendor materials and representations, testimony, memorandum of understanding, security documentation, etc. IIR and a contractor SME travelled to the BRIC in Boston, Massachusetts to familiarize themselves with the system and to assess the privacy impacts associated with its use of EIA. An initial draft PIA was developed through this process. Upon completion of the PIA, IIR will coordinate with the BRIC to identify recommendations related to the PIA process.
In addition, during this reporting period, IIR researched the jurisdictions that have adopted CCOPS ordinances or similar restrictions and consulted with five law enforcement agencies to get guidance on the applicability of such restrictions to various types of technology, the reporting requirements, the impact on law enforcement operations, and promising practices. On December 15, 2021, Boston Police Department representatives and members of four other law enforcement agencies participated in a roundtable discussion focusing on these topics. As a follow-on activity, IIR will develop and share recommendations and promising practices related to CCOPS and similar ordinances for distribution to the NNFC and other SLTT law enforcement partners.
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