Implementation Dashboard

Recommendation: Defining Public Safety

Implemented: Approved by leadership on May 6, 2022, and implemented immediately as USC’s guiding light for reimagining public safety.

The ONE USC Safety Vision was first proposed by the Community Advisory Board (CAB) and was drafted based on input received from the more than 700 students, faculty, staff, and neighbors who attended the CAB’s co-design sessions. With just a few minor revisions, the ONE USC Safety Vision has now been implemented by the university to address the CAB’s very first recommendation of re-envisioning public safety at USC. The implementation team recognized the power and value of the ONE USC Safety Vision to be used as a guiding light for not only reimagining public safety, but for implementing all of the CAB’s subsequent recommendations. The full statement, as approved by USC leadership, reads as follows:

“The ONE USC Safety Vision imagines a USC where everyone feels safe, respected, and protected from crime, while recognizing that this can be achieved only by addressing the diverse experiences and needs of all USC students, faculty, staff, and neighbors.”

Recommendation: Create an independent DPS Oversight Body

Immediately upon forming in 2021, the CAB implementation team began putting in place the plans for a permanent advisory body – a “CAB 2.0.” This ongoing advisory body serves USC in three areas:

• Review DPS’ budget, performance, stop, and misconduct data to ensure that critical performance issues can be identified early and addressed;

• Be a point of contact for the public to discuss implementation of the CAB’s 45 recommendations from the report published on July 28, 2021; and

• Conduct a periodic assessment of and suggest revisions to the ONE USC Safety Vision statement and the alignment of that statement with DPS policies, practices, and operational performance.

Implemented: In November 8, 2022, the charter for this permanent advisory body was approved. The newly formed CAB launched in spring 2023.

Recommendation: Create a public policy statement about the seriousness of racial profiling by DPS, students, faculty, staff, community members and visitors. Statement should include that racial profiling will not be tolerated as a false complaint, nor will it be tolerated as the basis for a subjective suspicious stop in the case of DPS.

Implemented: A statement was first drafted by USC’s Office of Diversity, Equity and Inclusion with input from several teams and departments. It was approved by leadership on May 6, 2022, and was implemented immediately to guide USC’s efforts in addressing racial profiling and related issues. The full statement is posted here and reads:

“Preventing and addressing bias-based community policing is a shared responsibility of all USC stakeholders.

As the ONE USC Safety journey began, we engaged in a community conversation based on our shared commitment to the physical and psychological safety of all. No student, staff, faculty member, community member, or visitor should feel unsafe or distrusted on the basis of race, ethnicity, religion, national origin, or membership in any protected class.

Bias-based policing is unacceptable and will not be tolerated at USC. The Department of Public Safety must always act based on legitimate facts and reasons, in a manner consistent with all DPS, EEO-TIX, and other university policies. Moreover, all members of our community are accountable for helping ensure that complaints to and other interactions with DPS are not infected by illicit bias.

The USC community continues to represent a space of inclusion, equity, and diversity where knowledge and understanding eradicate ignorance, bigotry, and systemic racism. USC reaffirms its commitment to these foundational principles of our community.”

Recommendation: Ensure that sustained complaints or reports of bias, discrimination or profiling – or sustained misconduct investigations involving the same – can result in the termination of employment

Update This recommendation is considered complete as of February 2024. Full details follow below.

Racial bias, discrimination and profiling are already prohibited by USC policy (Policy of Prohibited Discrimination, Harassment, and Retaliation), DPS General Orders (G.O. 2-23-1: Bias-Based Profiling) and California law (Revised version of Sec.4 of Sec. 13519.4 (5e) of the California Penal Code). Accordingly, sustained complaints can result in disciplinary actions, up to and including termination.

The university will expressly define “racial profiling” within the  Policy on Prohibited Discrimination, Harassment, and Retaliation when the planned updates are made to implement new Title IX regulations expected to be released by the U.S, Department of Education in March of 2024.

In July 2023, the university launched the Report & Response website as an easy-to-use online location where members of the USC community can report concerns and get the support they need. By making it simpler to file a report and find supportive resources, the university encourages the reporting of all concerns, including incidents of racial profiling or bias. Our actions evidence the university’s commitment to making USC a place where everyone feels they belong.

The employees of the Department of Public Safety are required to comply with all university policies and procedures, including those addressing discriminatory conduct and unprofessional behavior. DPS leadership has amplified that:

• For concerns based on protected characteristics, DPS will follow the university’s Policy on Prohibited Discrimination, Harassment, and Retaliation and immediately elevate those complaints to the Office for Equity, Equal Opportunity, and Title IX (EEO-TIX). The Policy incorporates a university-wide approach to preventing and responding to discrimination and harassment on the basis of protected characteristics (see: Office of Equity, Equal Opportunity, and Title IX Notice of Non-Discrimination) and specific forms of harassment based on sex.

• Concerns that are not based on protected characteristics will be addressed through existing staff disciplinary policies. . DPS will collaborate with the Office for Professionalism and Ethics or the Employee and Labor Relations unit, as well as their dedicated HR Partner, to provide support and guidance about how to engage with the staff processes.

DPS no longer follows a separate process for complaints and is responsible for complying with these university policies as they apply to all staff.

Please note that through USC’s Office for Equity, Equal Opportunity, and Title IX (EEO-TIX)– in particular its intake, outreach, and support team and supportive measures (such as academic accommodations) are currently available to students who have experienced racial profiling.

Note: The implementation of this recommendation was addressed in tandem with Recommendations #10 and #21.

Recommendation: Develop and provide a Community Engagement Card or QR code, to be furnished to everyone who has an interaction with DPS personnel, which will provide an opportunity to forward information (e.g., commendation, complaint, quality of service) to DPS.

Update: In progress as of October 1, 2022. A QR code has been created, feedback processing procedures have been written, and business cards with the QR codes have been created. Individual QR codes are being created for the DPS website and DPS vehicles to make it even easier to submit feedback anonymously. Officer training on this process began in Fall 2022 and is still in progress.

In accordance with Recommendations #35 and #41, information received from the QR code-driven feedback forms will be made public by way of a DPS Activity Log (in development).

Recommendation: Log sufficient information to analyze the percentage of each officer’s investigative stops in which the detained individual was found to be engaging in criminal activity.

Update: The implementation work for this recommendation is in progress as of October 1, 2022.

Recommendation: Record all self-initiated field contacts with persons in a computerized daily log. This should include reason for contact, outcome of interaction and any potential conflicts. These reports should be submitted at the end of each shift.

Update: The implementation work for this recommendation is in progress as of October 1, 2022.

Recommendation: Create a database that flags/identifies officers who have committed racial profiling stop offenses, and/or who have been released from duty. This database should be one that is accessible for annual USC public reporting, and also shared with local and centralized professional background check hubs – not just those tied to officer background checks.

Update: Implemented as of the Fall of 2023. The Sol Price School of Public Policy maintains a national database that identifies police officers who have been terminated or resigned due to misconduct. DPS officers generally do not appear in this database, however, because DPS officers are not “police officers” under California law and DPS is not a police department as recognized by the State of California.  It is a private security organization. Thus, the only reason that a DPS officer would appear in the Price School’s national database is if they previously worked as a police officer and were terminated or resigned from their police department due to misconduct.

Although the Sol Price database meets some of Recommendation #8’s transparency requirements, USC cannot maintain a similar database for USC DPS officers because personnel records are generally protected by rules of privacy under the California Constitution and any private employer in the State of California (such as USC) generally cannot make personnel information/records publicly available except in response to a legal process, such as a subpoena, or with written permission from the party whose records are to be released.

If for any reason changes in California law allow greater transparency of employment records in the future, CAB may elect to revisit this recommendation to fully realize its original intent.

Recommendation: Engage in a thorough review of the Memorandum of Understanding (MOU) between USC (DPS) and the City of Los Angeles (LAPD) to ensure that the MOU reflects the ONE USC community safety vision.

Note: The implementation of this recommendation is being handled in tandem with the following recommendation:

• Recommendation #11: Review of the Memorandum of Understanding (MOU) between USC (DPS) and the City of Los Angeles (LAPD) at least every three years to ensure that the relationships are clear; that the terms of the MOU sufficiently incorporate new practices, technology, experience, and changes in the law; and that the MOU reflects the goals and values of USC.

Update: The implementation work for these recommendations is in progress as of October 1, 2022.

Recommendation: Adopt a clear and comprehensive policy related to the handling of complaints against officers from the public that extends beyond the Administrative Investigations Management (AIM) database. That policy should, at a minimum, identify those responsible for complaint intake, detail the investigative steps and protocols required for all complaints, identify the standard of proof and categorize and define the possible findings.

Update: This recommendation is considered complete as of February 2024. Full details follow below.

Note: The implementation of this recommendation is being handled in tandem with Recommendations #4 and #21. Please refer to Recommendation #4 for full details.

Recommendation: Review of the Memorandum of Understanding (MOU) between USC (DPS) and the City of Los Angeles (LAPD), at least every three years to ensure that the relationships are clear, that the terms of the MOU sufficiently incorporate new practices, technology, experience and changes in the law, and that the MOU reflects the goals and values of USC.

Update: This recommendation is being implemented in tandem with Recommendation #9. Please refer to #9 for the latest details.

Recommendation: Reassign some of the current duties of armed DPS officers (PSOs) to others. Determine which duties are appropriate for this reallocation.

Update: This recommendation is considered in-progress as of October 2024.

Recommendation: DPS policies and protocols should ensure the equitable response, treatment and enforcement of disturbance calls relating to parties, noise complaints or alcohol-related issues involving students.

Update: This recommendation is considered complete as of Fall 2023. Full details follow below.

1. DPS practice is to respond to all USC student-related public disturbance calls as soon as possible.  Upon arrival to a location, DPS’s initial response is to communicate to the building representative / event organizer the nature of the disturbance complaint and the USC standard for community expectations regarding public disturbances. If appropriate assurances from the building / event representative, DPS will stand down with the assumption that the complaint will be addressed appropriately without any further actions on DPS’s part.

 2. Subsequent disturbance calls to the same event / building on the same day / timeframe can result in escalation, up to and including formal citation(s), referral to the USC Office of Community Expectations, referral to LAPD, and / or an immediate shutdown of the event. The outcome of each response is dependent on each event scenario’s circumstances and the receptivity and responsiveness of the building / event owner to DPS direction and local community / neighborhood expectations.

 3. The philosophy behind this progressive escalation posture is informed by the University’s responsibility for its students, their collective and individual safety, wellbeing, education, and development.  “The university protects its educational environment by establishing and maintaining standards of conduct for its students as individuals and as members of groups, implementing processes for addressing allegations of student misconduct in a fair and caring way. These standards reflect the very nature of an academic community and are reinforced through USC’s Integrity and Accountability Code, tying all that we do to our mission and Unifying Values. Students are expected to make themselves aware of and abide by the university community’s standards of behavior as articulated in [the] student handbook, the Policy on Prohibited Discrimination, Harassment, and Retaliation, and in related policy statements. Students accept the rights and responsibilities of membership in the USC community when they are admitted to the university.” (Quoted from the USC Student Handbook, p.8)

 4. DPS acts in this capacity within the scope of its MOU with the City of Los Angeles and LAPD, and therefore aligns its response posture in this regard with LAPD to ensure the consistency and continuity of a safe, respectful, fair and equitable community service.

Note: The implementation of this recommendation is being handled in tandem with the recommendation #34.

Recommendation: Develop a comprehensive training and development strategy for all DPS employees.

Update: The implementation work for this recommendation is in progress as of 10/1/2022.

Recommendation: Have other services provide the mental health response. If some functions currently handled by DPS are reassigned to other campus entities, then USC administration and DPS should consider reallocating funding in support of those reassigned services and redirecting resources from DPS to those other campus entities.

Implemented: This recommendation was implemented in Fall 2022 as part of the Mental Health Assistance and Response Team (MHART) pilot program, representing a collaborative effort between the USC Department of Public Safety and USC Student Health. Currently, the program is operational during business hours, but plans are in place to expand this to a 24/7 initiative in the future. Read the USC News Story: MHART pilot program launches to help students experiencing mental health crises

Recommendation: USC Should commit to creating an inclusive and inviting campus for the surrounding communities by assessing its current safety, access and security protocols to implement processes that would welcome USC’s neighbors into USC campus life.

Update: The implementation work for this recommendation is in progress as of October 1, 2022.

Recommendation: USC should commit to the creation of student/ neighbor engagement activities that would create opportunities for each to learn from one another and build egalitarian relationships of trust and care.

Update: The implementation work for this recommendation is in progress as of October 1, 2022.

Recommendation: USC should adopt within its academic policy the ability for a racially profiled student to seek and utilize academic assistance resources due to stress caused from the incidence of being racially profiled. This includes deferral of assignments and tutoring support.

Update: This recommendation is considered complete as of February 2024. Full details follow below.

Note: The implementation of this recommendation is being handled in tandem with Recommendations #4 and #10. Please refer to Recommendation #4 for full details.

Recommendation: USC should fund and create trauma-informed mental health resources, including counselors, to support and provide relief for the experiences of racially profiled students within Student Health Services, at no cost to the student.

Implemented: This recommendation is considered implemented as of Fall 2022 by USC Student Health. Several aspects of Student Health’s recent trauma-informed transformation were designed specifically to address the CAB’s priorities:

• Mental health staff are now offered 1.5 hours of monthly trauma consultation and education trainings, covering adverse childhood experiences, identity-based trauma, gender-based trauma, and more.

• Staff also receive regular DEIB training covering diverse themes such as implicit bias, microaggressions and restorative practice, anti-blackness and mental health equity, and LGBTQIA+ and gender-affirming training.

• Students presenting for care are screened for racial trauma. Examples include:

  • Identity-based bias incident(s) (gender, race/ethnicity, )

  • Stereotype threat/marginalization

  • Traumatic event(s)/circumstance(s)

• The scheduling system in mySHR has been streamlined so students now have the ability to request a provider who can offer culturally informed care.

• A website has been created with tailored mental health information to improve access and education for our diverse populations.

• USC’s Counseling and Mental Health Services (CMH) has embedded clinicians in Student Equity and Inclusion Programs to offer tailored support to the university’s cultural centers.

Recommendation: DPS needs to modify its recruitment and hiring practices to ensure that DPS officers are best situated to be members of a campus community as part of a service organization.

Update: The implementation work for this recommendation is in progress as of October 1, 2022.

Recommendation: DPS trainings should include neighbor-led sessions that provide the community’s historical context and sensitivity training.

Update: The implementation work for this recommendation is in progress as of October 1, 2022.

Recommendation: Leverage existing programs such as Troy Camp and Joint Educational Project (JEP)

Update: The implementation work for this recommendation is in progress as of October 1, 2022.

Recommendations: Create and implement community-led sessions about the history of the region at student orientation, DPS required trainings, and other campus activities throughout the year.

Update: The implementation work for this recommendation is in progress as of October 1, 2022.

Recommendations: Organize neighborhood events and volunteer opportunities – such as “Adopt A Block” events – targeting student groups and organizations to give back to the communities they may at times inadvertently harm.

Update: The implementation work for this recommendation is in progress as of October 1, 2022.

Recommendations: Craft a diverse and broad marketing campaign that invites the community onto campus and highlights university resources that are accessible to all (such as recreation facilities and/or medical campus support services).

Update: The implementation work for this recommendation is in progress as of October 1, 2022.

Recommendations: Continue exploring opportunities for expanded shared spaces within the communities we serve.

Update: The implementation work for this recommendation is in progress as of October 1, 2022.

Recommendation: USC should expand how it offers various services and supports its neighbors utilizing the wealth of campus resources.

Update: The implementation work for this recommendation is in progress as of October 1, 2022.

Recommendation: DPS should review, re-imagine and clearly publicize its mission, which should include providing a safe and secure campus environment that allows students, faculty, staff and campus visitors to realize their academic and social pursuits.

Recommendation: DPS should clearly communicate how DPS is different from the LAPD; what DPS does and what the LAPD does; and the relationship between DPS and LAPD.

Update: The implementation work for this recommendation is in progress as of October 1, 2022.

Recommendation: If possible, DPS should look at ways to immediately change its uniforms so that they can easily be distinguished from LAPD officers in a way that could quickly be implemented.

Note: The implementation of this recommendation is being handled in tandem with the following recommendations:

• Recommendation #38: DPS should change the color of its uniforms and/or create a more approachable look in its uniform design with colors not reminiscent of LAPD or other local municipal police forces so that students and the community around USC can easily identify DPS officers and distinguish them from LAPD and other agencies’ officers.

• Recommendation #39: DPS should form a working group, consisting of students, staff, faculty, and DPS personnel, to determine uniform options and associated costs and present its findings with recommendations to the future oversight body.

• Recommendation #44: The new permanent oversight body and DPS should present a proposal and budget to the university administration for a full uniform change.

Update as of October 1, 2022: Implementation work has begun on these recommendations. Proposals for new uniforms have been approved, and a Uniform Evaluation Committee was formed in Fall 2022.

Recommendation: DPS should clarify its mission and its policies with regard to students whose problematic behavior would normally justify receiving a citation by an LAPD officer if committed by a non-student. DPS should ensure that its officers are responsive to complaints from the local community and not inappropriately protecting students for activity that would otherwise merit a citation.

Update: This recommendation is considered complete as of Fall 2023. Full details follow below.

Note: The implementation of this recommendation is being handled in tandem with Recommendation #13. Please refer to Recommendation #13 for full details.

Recommendation: DPS should clearly publicize the revised mission statement on its website.

Recommendation: DPS must better communicate the services its officers provide and the scope of their respective enforcement.

Update: The implementation work for this recommendation is in progress as of October 1, 2022.

Recommendation: DPS should change the color of its uniforms and/or create a more approachable look in its uniform design with colors not reminiscent of LAPD or other local municipal police forces so that students and the community around USC can easily identify DPS officers and distinguish them from LAPD and other agencies’ officers.

Update: This recommendation is being implemented in tandem with Recommendation #33. Please refer to #33 for the latest details.

Recommendation: DPS should develop educational materials to teach all community members about:

1. The services it provides and its enforcement authority and

2. The different roles of each classification of DPS officers

Update: The implementation work for this recommendation is in progress as of October 1, 2022.

Recommendation: DPS should continually reassess its mission statement and operations and ensure that its website and educational materials are continually amended to provide proactive, accurate and timely information to the USC community.

Recommendation: DPS should work with an on-campus data analysis partner to collect and make available relevant and timely information regarding policing practices and outcomes on and near USC’s campuses. This data should be used to inform and direct nonlaw enforcement resources, not as a tool to increase surveillance and enforcement.

Update: The implementation work for this recommendation is in progress as of October 1, 2022.

Recommendation: The new permanent oversight body and DPS should present a proposal and budget to the university administration for a full uniform change.

Update: This recommendation is being implemented in tandem with Recommendation #33. Please refer to #33 for the latest details.

Recommendation: DPS should review statewide policies and procedures to ensure that its data reporting practices are in alignment with the applicable state laws. These laws include Senate Bill 1421, enacted as an amendment to the California Penal Code Section 832.7, and Assembly Bill 953, enacted as an amendment to the California Government Code Section 12525.5

Update:

Update as of Fall 2023:  The state laws referenced by the CAB in Recommendation #45 apply to “Peace Officers” as defined in Part 2, Title 3, Chapter 4.5 of the California Penal Code.  USC Department of Public Safety officers are not Peace Officers as defined by the State of California, because USC is a private institution.  For private educational institutions (e.g., Pepperdine, Loyola Marymount, Mount St. Mary’s, etc.), security activities on campus are performed by a “private security” organization.  Therefore, the University is not subject to the aforementioned legislation (i.e., SB-1421 and AB-953), and DPS is in alignment with the applicable state laws.

That being said, DPS wishes to embrace the spirit of the legislative requirements insofar as that would not jeopardize the University’s compliance with any applicable labor laws (e.g., the California Business and Professions Code, the California Labor Code, the California Private Security Services Act, etc.), wherein DPS personnel as employees of USC may be afforded additional protections under the law, compared to public employees (i.e., Peace Officers).

In the interests of transparency, DPS intends to make anonymized and aggregated complaint, misconduct, use of force, officer-involved shootings, and dispatched or subject contact data relative to the racial/identity characteristics of persons contacted, the time, date, location, and reason for the stop (also including actions taken during the contact; search information; evidence found; property seized; result of the contact, etc.).

That information will be compiled and made available to the public via the Transparency Dashboard (see Recommendations #6, #7 & #35) as soon as operationally feasible on a date yet to be determined. Compilation of the information and frequency of publication will be conducted in accordance with the guidelines set forth in the responses to those recommendations.