Policy Text
Policy
332Santa Ana Police Department
Santa Ana PD Policy Manual
Copyright Lexipol, LLC 2025/09/03, All Rights Reserved.
Published with permission by Santa Ana Police DepartmentLimited English Proficiency Services - 1Limited English Proficiency Services
332.1 PURPOSE AND SCOPE
This policy provides guidance to members when communicating with individuals with limited
English proficiency (LEP) (42 USC § 2000d).
332.1.1 DEFINITIONS
Definitions related to this policy include:
Authorized interpreter - A person who has been screened and authorized by the Department to
act as an interpreter and/or translator for others.
Interpret or interpretation - The act of listening to a communication in one language (source
language) and orally converting it to another language (target language), while retaining the same
meaning.
Limited English proficient (LEP) - Any individual whose primary language is not English and
who has a limited ability to read, write, speak or understand English. These individuals may be
competent in certain types of communication (e.g., speaking or understanding) but still be LEP
for other purposes (e.g., reading or writing). Similarly, LEP designations are context-specific; an
individual may possess sufficient English language skills to function in one setting but these skills
may be insufficient in other situations.
Qualified bilingual member - A member of the Santa Ana Police Department, designated by the
Department, who has the ability to communicate fluently, directly and accurately in both English
and another language. Bilingual members may be fluent enough to communicate in a non-English
language but may not be sufficiently fluent to interpret or translate from one language into another.
Translate or translation - The replacement of written text from one language (source language)
into an equivalent written text (target language).
332.2 POLICY
It is the policy of the Santa Ana Police Department to reasonably ensure that LEP individuals
have meaningful access to law enforcement services, programs and activities, while not imposing
undue burdens on its members.
The Department will not discriminate against or deny any individual access to services, rights or
programs based upon national origin or any other protected, class, interest or right.
332.3 FOUR-FACTOR ANALYSIS
Since there are many different languages members may encounter while on-duty, the Department
will utilize the four-factor analysis outlined in the U.S. Department of Justice (DOJ) Guidance
to Federal Financial Assistance Recipients, available at the DOJ website, to determine which
measures will provide meaningful access to its services and programs. It is recognized that law
Santa Ana Police Department
Santa Ana PD Policy Manual
Limited English Proficiency Services
Copyright Lexipol, LLC 2025/09/03, All Rights Reserved.
Published with permission by Santa Ana Police DepartmentLimited English Proficiency Services - 2enforcement contacts and circumstances will vary considerably. This analysis, therefore, must
remain flexible and will require an ongoing balance of four factors, which are:
(a)The number or proportion of LEP individuals eligible to be served or likely to be
encountered by department members, or who may benefit from programs or services
within the jurisdiction of the Department or a particular geographic area.
(b)The frequency with which LEP individuals are likely to come in contact with department
members, programs or services.
(c)The nature and importance of the contact, program, information or service provided.
(d)The cost of providing LEP assistance and the resources available.
332.4 TYPES OF LEP ASSISTANCE AVAILABLE
Santa Ana Police Department members should never refuse service to an LEP individual who
is requesting assistance, nor should they require an LEP individual to furnish an interpreter as a
condition for receiving assistance. The Department will make every reasonable effort to provide
meaningful and timely assistance to LEP individuals through a variety of services.
The Department will utilize all reasonably available tools, such as language identification cards,
when attempting to determine an LEP individual's primary language.
LEP individuals may choose to accept department-provided LEP services at no cost or they may
choose to provide their own.
Department-provided LEP services may include, but are not limited to, the assistance methods
described in this policy.
332.5 WRITTEN FORMS AND GUIDELINES
Vital documents or those that are frequently used should be translated into languages most likely to
be encountered. The LEP Coordinator will arrange to make these translated documents available
to members and other appropriate individuals, as necessary.
332.6 AUDIO RECORDINGS
The Department may develop audio recordings of important or frequently requested information
in a language most likely to be understood by those LEP individuals who are representative of
the community being served.
332.7 QUALIFIED BILINGUAL MEMBERS
Bilingual members may be qualified to provide LEP services when they have demonstrated
through established department procedures a sufficient level of skill and competence to fluently
communicate in both English and a non-English language. Members utilized for LEP services
must demonstrate knowledge of the functions of an interpreter/translator and the ethical issues
involved when acting as a language conduit. Additionally, bilingual members must be able to
Santa Ana Police Department
Santa Ana PD Policy Manual
Limited English Proficiency Services
Copyright Lexipol, LLC 2025/09/03, All Rights Reserved.
Published with permission by Santa Ana Police DepartmentLimited English Proficiency Services - 3communicate technical and law enforcement terminology, and be sufficiently proficient in the
non-English language to perform complicated tasks, such as conducting interrogations, taking
statements, collecting evidence or conveying rights or responsibilities.
When a qualified bilingual member from this department is not available, personnel from other
City departments, who have been identified by the Department as having