STEP 2: Create Operational Protocols and Procedures

BTAUs must establish protocols by which the units will operate.

Documenting these procedures allows for a clear understanding of processes, roles, and responsibilities.

Creating written protocols also promotes consistency and continuity while setting the stage for future program evaluation and development.

While agency policies establish the guiding principles and parameters of the behavioral threat assessment program (the “what”), standard operating procedures (SOPs) outline the stages of the BTAU’s daily operations (the “how”).

The SOPs should describe the roles and responsibilities of the BTAU as a whole, its individual members, and any associated community partners involved in the behavioral threat assessment process.

The SOPs should account for each phase of the process (i.e., from receiving an initial report to closing a case) and identify actionable steps and tasks throughout.

The SOPs should identify who is responsible for completing required actions at each step and the timeframe for each of those actions to be completed.

SOPs should also establish the frequency of BTAU meetings and by whom the meetings are led.

The BTAU should convene regularly, regardless of whether any assessments are active.

Routine meetings (e.g., weekly or biweekly) ensure team cohesion and provide consistent opportunities for unit members to: • review previous cases, • participate in scenario-based exercises, • receive training on relevant topics, • make process improvement recommendations, • identify resource shortfalls, and • collectively examine trends in targeted violence.

It is also a best practice to review the established SOPs on a routine basis (e.g., quarterly or annually) to account for lessons learned, new techniques, and revised membership roles and responsibilities that may change as the BTAU matures.

Describe the roles and responsibilities of the BTAU and its members/stakeholders • Account for each phase of the behavioral threat assessment process • Identify actionable steps to move through the process • Identify who is responsible for completing required actions • Identify a timeframe for when actions should be completed • Establish frequency of team meetings and by whom the meetings are led

A distinguishing feature of the Secret Service’s behavioral threat assessment approach is that all cases are centrally administered by the Secret Service Protective Intelligence and Assessment Division (PID).

Centralized case administration ensures standardization in initiating cases, gathering information, and managing cases over time.

For instance, within the Secret Service, each case is centrally administered by special agents and intelligence analysts at Secret Service Headquarters in Washington, DC, while the investigative work for those cases is conducted by special agents in Secret Service Field Offices around the world, all of whom have been trained in behavioral threat assessment methodology.

In other words, Secret Service field agents routinely conduct interviews, review records, write reports, make assessments, and employ behavioral management strategies, while those processes are centrally coordinated, reviewed, and documented at Secret Service Headquarters.

A centralized, dedicated staff provides BTAUs the ability to view a concerning incident in its entirety, ensure that concerning behaviors are assessed appropriately and consistently, and design effective management plans for individuals of concern.

Centralized case administration further aids in the review of trends and the progression of concerning behaviors over time while also allowing the BTAU to direct and advise investigators who may not work on behavioral threat assessments as part of their normal duties.

For example, the BTAU may require a patrol officer to conduct a welfare check or interview an individual of concern and then report back their findings. In these cases, the patrol officer should provide any documentation regarding the results of the encounter to the BTAU in accordance with the BTAU’s requirements.

BTAUs must operate with a comprehensive understanding of individual rights to privacy with a particular focus on the handling and protection of personally identifiable information (PII).

Agencies should consult with their counsel or privacy personnel knowledgeable about the applicable laws and regulations related to individual privacy within their jurisdiction.

Some questions to consider regarding PII include, but are not limited to: • What rules allow the BTAU to request from individuals information that would otherwise be protected? • Where and how will the BTAU maintain documents and files (e.g., completed forms, case plans, and supporting documentation)? • Who will have access to these files? • How will the BTAU facilitate the sharing of information internally and externally with relevant agencies and partners while also ensuring appropriate protections of PII?

In addition to the above considerations, BTAUs should develop an understanding of the rules and laws that govern the sharing of information held by their community partners.

For example, the Health Insurance Portability and Accountability Act (HIPAA) protects the privacy of individual health and medical information held by healthcare providers and healthcare businesses.

Similarly, the Family Educational Rights and Privacy Act (FERPA) protects the privacy of individual education records held by education agencies and institutions receiving funds from any program administered by the U.S. Department of Education.

Units should have a firm understanding of exactly what information these laws protect and what exceptions allow for sharing information when a risk to public safety exists.

Even if mental health providers and local education agencies cannot share information with the BTAU, those agencies can receive whatever information the BTAU is authorized to share. Sharing information with these entities will inform the strategies used by the mental health providers and local education agencies to promote the wellbeing of individuals under their care.

As the behavioral threat assessment proceeds, the BTAU will want to document all relevant information gathered during the assessment. Templated forms can be used to organize, prompt, and standardize information gathered during the behavioral threat assessment process.

Using templated forms will also improve consistency and reliability in the behavioral threat assessment process by ensuring the same type and quality of information is gathered in each assessment.

It is important to remember that templated forms should be used as a starting point for gathering and collecting information. These forms should not be considered all-inclusive and should allow the flexibility to make common-sense adjustments during the behavioral threat assessment process. For example, information learned during an interview may prompt additional follow-up questions not explicitly listed on an interview form.

Assessment forms can facilitate the information gathering process by systematically capturing the following:

basic identifiers of the individual of concern, the reporting party, potential targets, and potential parties to interview;

information about the circumstances that brought the individual of concern to the attention of the BTAU;

answers to the questions posed during interviews with the individual, as well as during corroborative interviews with others;

potential sources for gathering additional information;

individualized case management plans (see STEP 5: Develop Risk Management Strategies); and

updates to case records if an individual returns to the BTAU’s attention;

details about each of NTAC’s 20 Assessment Themes, including the individual’s recent life stressors, concerning communications, and history of contact with law enforcement (see STEP 4: Gather Information to Assess for Risk).