Comparison of criminal history information systems in the United States and other nations

Handcuffs laying on top of fingerprint chart in file

Photo by TheCrimsonRibbon/Getty Images

There is considerable variation among the criminal-history information systems of Australia, Canada, Germany, the Netherlands, the United Kingdom, and the United States regarding how they approach the collection, management, and uses of criminal-history information through their national information systems.

What is the issue?

Criminal history records are the linchpin of criminal justice systems worldwide. Knowing about a prior arrest may drive a police decision to detain rather than release a suspect. Criminal history records, or rap sheets, are used on a daily basis by courts and corrections systems, as prior convictions may lead to harsher sentences for new crimes. These records may also be used to determine eligibility for employment or gun ownership, or be used by researchers examining criminal careers and behaviour.

There are however currently some potential limitations in the criminal history records in the US, as a result of jurisdictional variations in reporting standards and data quality. As part of efforts to improve the available data, it is important to understand how other industrialized countries manage and structure their criminal history systems and how the US system compares.

How did we help?

The U.S. Bureau of Justice Statistics (BJS) commissioned RAND to research the development and use of criminal history databases in five countries (Australia, Canada, Germany, the Netherlands and the United Kingdom) in order to provide insights on the experiences of other countries in their collection, assessment and use of official criminal history records for research and statistical purposes. The report will be used by the BJS to help understand what improvements could be made to the U.S. system, and possibly others.

What did we learn?

Characteristics and content of National Criminal Record Information Systems

  • There are discernible differences across all the studied countries in the functions that their national criminal record information systems (CRIS) are designed to perform. These can be grouped into two broad organisational approaches:
    1. In Australia, Canada, England, Wales and the U.S., national CRIS are designed to capture information on the entire history of an individual’s interaction with the criminal justice system. These are created by police agencies, who also act as the primary source of information.
    2. In the Netherlands and Germany, data collection for national CRIS starts later, with individuals needing to progress further in the criminal justice system to develop a record. These national systems therefore primarily rely on data from public prosecutors and courts.
  • Data retention policies are another area where there is variation across the countries. Germany and the Netherlands differ from the other countries and may retain data for a comparatively shorter period.

Access to the System

  • Across all studied countries, law enforcement and other criminal agencies have access to criminal-history information systems to support their operations. Provisions also exist for the international sharing of data.
  • All studied countries allow individuals to check their own records for information held about them, and the countries provide background checks for such purposes as employment, visa applications, and adoption applications.
  • Access to criminal-history data is also granted to researchers in all studied countries, although the level of access varies widely. Typically, access may be approved for specific research activities that may provide a benefit to society and inform practice or policymaking.

Data quality and completeness

Overall, four types of data quality and completeness challenges were identified across the countries:

  1. There are complexities in gathering data from multiple state and local jurisdictions, such as variable data formats, and variation in the type of information that state and territorial agencies share.
  2. The transfer of data from originating agencies to the national system can lead to issues such as missing dispositions or inaccuracies during the receipt and registration of data.
  3. Aging technological infrastructure.
  4. The limited scope of information held in national systems.