Skip to main content

Campus Safety Audit Report


Prepared by Judge LaDoris H. Cordell (Ret.)
December 2020


I. Purpose of the Audit: On August 26, 2020, the President of Santa Clara University (SCU) retained Judge LaDoris H. Cordell (Ret.) to conduct an audit of the SCU Campus Safety Services (CSS) Department “for the purpose of making recommendations concerning the manner in which it provides security for the University.”

II. Auditor’s Background: LaDoris H. Cordell is a 1974 graduate of Stanford Law School. She is a retired Superior Court Judge who served on the Santa Clara County bench from 1982-2001. Her work in academia included positions as Assistant Dean of Stanford Law School (1978-1982) and Vice Provost & Special Counselor to the President of Stanford University (2001-2009). From 2010-2015, she was the Independent Police Auditor for the City of San Jose where her office engaged in civilian oversight of the San Jose Police Department. She chaired Santa Clara County’s Blue Ribbon Commission that evaluated the county’s jails in the aftermath of the murder of a mentally ill inmate by the jail guards. She was one of three judges who served on a Blue Ribbon Panel that evaluated the San Francisco Police Department in the aftermath of the racist texting scandal involving several officers.

III. The Audit Process

  1. The audit process consisted of the following:
    1. Review of CSS Code of Ethics
    2. Review of CSS Policy Manual
    3. Review of CSS Demographic Data
    4. Review of CSS Training Procedures
    5. Review of CSS Hiring Procedures
    6. Review of CSS Job Requirements
    7. Review of New Officer Orientation PowerPoint
    8. Review of CSS External Complaints
    9. Review of CSS Internal Complaints
    10. Review of CSS Contact Data
    11. Review of Campus Safety Reports
    12. Review of CSS Information Reports
    13. Review of CSS Arrest Data
    14. Review of CSS Budget
    15. Review and Analysis of Community Feedback
    16. Conversations with CSS employees
    17. Conversation with African American faculty
    18. Review of Emails Regarding the Diversity Forum on October 28, 2020
    19. Conversations with African American former CSS employees
    20. Conversation with CSS Director
    21. Conversation with Associate Vice President for Operations
    22. Survey of Campus Safety Departments at Jesuit and non-Jesuit institutions

IV. History of Campus Safety Services at Santa Clara University 

Note: There is no formal history of Campus Safety Services. As a result, the following history was taken from articles in The Santa Clara, the student newspaper, and from information provided by the university’s Archives Department and the Human Resources Department.

Before 1979, the university outsourced campus security by contracting with Wells Fargo. However, in May 1979, because the cost of contract security had become prohibitive, the university began the process of phasing out Wells Fargo and replacing it with a university operated security system. According to John Killen, the then-Director of campus security, “We are striving for quality over quantity, but the main issue is money.” He continued, “Wells Fargo has a high turnover rate; they can’t establish a rapport with faculty or students.” The university envisioned a new security system to be a full-time force of 15 trained Public Safety Officers who would receive training, including cardio-pulmonary resuscitation techniques and fire safety inspection. (Source: The Santa Clara, 5/3/1979)

In September 1981, William Dortch was hired as the Director of Public Safety, having been promoted to that position after serving for one year as the Assistant Director. He was the Director until March 1986 when he resigned in the wake of staff morale problems and turmoil within the Department. (Source: SCU Human Resources; The Santa Clara, 10/2/1986)

In January 1986, Public Safety officers petitioned the University to carry batons and mace after 275 dorm rooms were ransacked in December 1985. They petitioned a second time after two officers were involved in a confrontation with three males in Campisi Hall in May 1986. Then, according to a story in The Santa Clara, “[o]n July 7, 1986, CSS officer Ken Vinyard faked an attack on himself by hitting himself on the head with a bottle in a Swig Hall stairwell and then told police he had been attacked by a man wearing a ski mask. He later told authorities that he had staged the incident in part to demonstrate a need for arming Public Safety officers.” To address this issue, Director Dortch announced that he would conduct an evaluation of Public Safety “and determine the role it should play at SCU.” It does not appear that an evaluation was ever undertaken. Currently, Campus Safety Services officers do not carry batons or mace, and do not carry firearms.

In 1986, Richard Damon, formerly the Deputy Police Chief of the Santa Cruz Police Department and with 20 years of law enforcement experience, became the university’s Director of Public Safety. In November of that year, he reorganized the department by restructuring the chain of command so that officers would form the base of the organization with four Watch Commanders above them, reporting to the Director. Prior to this reorganization, Director Damon’s predecessor William Dortch had utilized five different ranks: director, senior controller, controllers, sergeants, and officers. In a story in The Santa Clara, Director Damon was quoted as saying that Mr. Dortch’s rank structure had “too many chiefs and not enough Indians.” Under Damon’s reorganization, Watch Commanders would have at least five years of public safety experience at SCU. He also announced his intention to increase the training of officers and require higher educational and training standards for future Public Safety officers.

With respect to recruitment and training, Director Damon “hoped to recruit officers with some college background and at least four years of experience in security.” Training, at the time, consisted of 16 hours of classroom instruction concentrated primarily on laws of arrest and scope of authority of security officers. Director Damon characterized the work of the Department as “service-oriented rather than police or law enforcement-oriented.”
(Source: The Santa Clara, 11/6/1986)

In October 1989, Director Damon transferred to the position of Director of Physical Plant at SCU. He was replaced by Dan Fite who served as Public Safety Director until July 1993. Director Fite also had a law enforcement background, having risen to the rank of Lieutenant within the Santa Cruz Police Department.

In July 1993, Mr. Fite’s tenure as Public Safety Director ended, and Richard Damon returned as Public Safety Director. In 1999, Director Damon was “relieved from operation responsibilities” and served in an “advisory and consulting role.” His tenure at SCU ended in July 2000. (Source: SCU Human Resources; The Santa Clara, 10/2/1986)

In January 2001, Charlie Arolla was hired as the Director after retiring as the Chief of the Santa Clara Police Department. His tenure ended October 1, 2010. (Source: SCU Human Resources)

All of the Campus Safety Directors have been males with law enforcement experience.

In or about 2000, Public Safety Services was renamed Campus Safety Services.
(Source: The Santa Clara, 2/3/2000)

V. Campus Safety Services Structure

The Campus Safety Services Department is comprised of three divisions: Patrol, Emergency Planning, and Parking & Transportation. With 41 allocated positions, but with 32 positions actually filled, CSS is headed by Director Philip J. Beltran, who is supported by an administrative assistant. Assistant Director John Loretto, supervises the Patrol Divisions with its four Watch Commanders, five Assistant Watch Commanders, and 13 Campus Safety Officers. Director Millicent Kenney supervises the Parking & Transportation Division. Reporting to her are an Office Manager, one Watch Commander, and two Parking Control Officers. (Pre-COVID, seven Student Assistants performed paid clerical work for Parking & Transportation.) The Emergency Planning Division is comprised solely of a Manager, Don Mattei. (Source:

VI. Campus Safety Services Demographics 

Watch Commanders: There are four Watch Commanders, all of whom are men; two are Caucasian, one is Asian and one is biracial. Four of the five Assistant Watch Commanders are males and one is female; two are Caucasian, one is Latinx, one is Asian and one is biracial.

Campus Safety Officers: There are 13 Campus Safety Officers and two Parking Patrol Officers. Thirteen are male and two are female. Six are Caucasian, four are Latinx, two are Asian, and three are biracial.

Age: The ages of CSS personnel range from the 20s to the 70s. Ten are in their 20s, six are in their 30s, seven are in their 40s, five are in their 50s, three are in their 60s, and one is in his 70s.

Educational Background: Three CSS personnel have post-graduate degrees (including a law degree); eleven have college degrees, seven have community college degrees.

Years of CSS Experience: The length of service of current CSS employees ranges from one year to 32 years. The median length of employment at CSS is 4.9 years; the average length of employment is 9.3 years. 

Law enforcement background: Six current employees, all of whom are men, have extensive law enforcement experience. One was employed for eight years, as a correctional officer and dispatcher at a jail. Five of these six employees hold supervisory level positions in CSS: (1) Director (31 ½ years of prior law enforcement experience), (2) Assistant Director (25 years of prior law enforcement experience), (3) Emergency Manager (38.5 years of prior law enforcement experience), (4) a Watch Commander (20 years of prior law enforcement experience), and (5) an Assistant Watch Commander (10 years of prior law enforcement experience). (Source: SCU Human Resources)

VII. Educational and Experience Requirements for CSS Officers:
CSS personnel must possess a high school diploma, although an Associate or Bachelor degree is preferred. At least two years of customer service-related experience is required, while experience in the security industry is preferred. (Source: Campus Safety Services Position Description)

VIII. Primary Duties of Campus Safety Services Officers:
CSS has six primary duties and responsibilities: (1) patrol, (2) dispatch, (3) campus services, (4) housing and residence life services, (5) parking enforcement, and (6) administrative. What follow are the details of these duties in the CSS’s officer position description:

(1) Patrol: “Conduct security patrols of the 101+ acre SCU properties 24 hours a day, year-round. Conduct routine security checks of the campus 68+ buildings and structures. . . Conduct random patrols in the assigned beat area when not assigned a call or working on administrative tasks. Look for possible criminal activity, persons needing assistance, as well as maintenance issues.”

(2) Dispatch: “Answer both routine and emergency telephone calls. Dispatch appropriate CSO on patrol to calls for service and alarms. Monitor the alarm systems that report to the Dispatch center. Maintain the dispatch log. Take desk reports on prior incidents. . . Greet and serve customers that come into the Dispatch Center. . . Prioritize Campus Safety Services response to competing calls for service. . . Affect an arrest of persons who commit offenses in the presence of a CSO and turn custody over to the Santa Clara Police Department.”

(3) Campus Services: “Secure (arm/disarm) most administrative and academic buildings on a set schedule throughout the week. . . Unlock and secure specified classrooms on the weekends and on holidays when directed to do so . . . Serve as emergency notifying agency for Facilities related issues after business hours. Work with responding personnel (Santa Clara Police, Fire Department, Utilities, EMTs, Paramedics, and other community resources) in handling emergencies on campus. Provide delivery service for sensitive items/materials . . . Provide jumpstarts and lockout assistance. Provide escorts to SCU affiliates from/to SCU property to a 2-block radius upon request . . .Set up barricades and other traffic controls to assist various Facilities projects and arrange for the towing of vehicles out of restricted areas. Perform any other service as directed by a Watch Commander, Campus Safety Manager, or Director.”

(4) Housing and Residence Life Services: “Perform lockouts for resident students whenever the Housing & Residence Life Office is closed. . . Respond to all reported disturbances, emergencies, and suspicious circumstances in the residence halls . . . Work with responding personnel (Santa Clara Police, Fire Department, Utilities, EMTs, Paramedics) in handling emergencies in the residence halls. . . Assist HRL staff in handling uncooperative or confrontational residents, and non-affiliates in the residence halls. . . Check on maintenance problems after hours. . . Perform room searches upon request of HRL staff.”

(5) Parking Enforcement: “Enforce all parking regulations in all campus parking lots. . . Patrol the parking areas during the enforcement hours. . . Issues citations to vehicles found in violation of the parking regulations. . . Arrange towing of vehicles when the offense warrants. . . and breakdown parking barricades upon request.”

(6) Administrative: “Document in a report any affiliates found disturbing the campus or committing minor criminal offenses or violating campus regulations. . . Make reports on most misdemeanor level crimes[.]”
(Source: CSS Campus Safety Officer Position Description)

IX. CSS Equipment and Uniforms: CSS officers, Assistant Watch Commanders and Watch Commanders are unarmed. CSS officers are issued utility belts worn around their waists on which are attached handcuffs, keys, flashlights, disposable gloves, citation printer holders, Motorola radios with attached microphone, and earpieces.

CSS uniforms consist of black shirts with CSS badges sewn on the left chest area, khaki tactical cargo pants, black jackets with CSS badges sewn on the left chest area, and black baseball caps with the words, “SCU Campus Safety” sewn on the front and black knit caps with “CSS” sewn on them. (Source: Campus Safety Services Training Information.)

X. CSS Policy Manual: The policies, rules and regulations that govern Campus Safety Services personnel are contained in the Policy Manual, only recently completed and yet to be formally approved.

XI. CSS Commendations: In 2014, four CSS officers received commendation letters from the Santa Clara Police Department for their work in assisting in the apprehension of a bicycle thief who had stolen a “bait bicycle.” According to the commendation, “They were extremely helpful and suggested the best possible locations to emplace the bicycle[.] . . While diligently monitoring the campus surveillance system, they viewed a suspicious person loitering near the location of our bait bicycle. Using their good sense and judgment, they closely monitored this subject’s actions and were able to on-view him as he removed the bicycle from its secure location and began to ride away. . . [T]hey immediately began following the suspect while simultaneously notifying SCPD communications. A short time later, the suspect was located and arrested for grand theft[.]”

Two CSS officers received the university’s annual Staff Recognition Individual Award for Administration and Finance, one in 2012, and one in 2015.

In 2015, a CSS officer received a “Letter of Appreciation” from the Miller Center for Social Entrepreneurship for providing “a customized R.A.D. [Rape Aggression Defense] training to six of our fellows over two Sundays for three hours each[.] . . The training was so positive that [the fellows] have all decided to take the full R.A.D. course upon their return from the field.”

XII. CSS Complaints:

  1. External Complaints: External complaints are those filed by individuals outside of the Department alleging misconduct of CSS personnel. The CSS complaint process is described in section 1010 of the CSS Policy Manual. CSS produced no records of external complaints in response to the audit request for all such complaints filed since 2010.
  2. Internal Complaints: Internal complaints, initiated from within CSS, were reviewed for this audit. Investigations of internal complaints, the findings and discipline are, by law, confidential.

XIII. CSS Annual Budget:

Budget Fiscal Year 2021

Total Sources of Funds:
Total Salary/Benefits:  $2,485,600.00
Total Dept Operating Expense: $100,000.00
Total General Univ Expense:    0
Total Transfers Out:  $15,000.00

Total Uses of Funds:  $2,600,600.00

Budget Fiscal Year 2020

Total Sources of Funds:
Total Salary/Benefits:    $2,500,700.00
Total Dept Operating Expense: $125,000.00
Total General Univ Expense:    0
Total Transfers Out:  $15,000.00

Total Uses of Funds:   $2,640,700.00

Although arrests are reported in the CSS Crime Summary, the arrests were made, in fact, by Santa Clara Police officers. This is so because CSS officers are unsworn and do not have the authority of sworn officers to make arrests. As a result, CSS officers either participated in the detentions of the arrestees or alerted the Santa Clara Police Department to the suspects. CSS officers can, however, initiate “citizens’ arrests” pursuant to California Penal Code section 837. That law permits any person, not a sworn officer, to detain a person who has committed a crime in that person’s presence.

Over a ten-year period, there were 456 arrests of individuals on or near the Santa Clara University campus, for an average of 45 arrests each year. Arrestees include affiliates of the university and non-affiliates. Arrests can be custodial or by issuance of misdemeanor citations. Below are the types of crimes and number of arrests for each crime listed in the CSS Crime summary.

456: Total Arrests (2010-2020)
Assault (3)
Burglary (1)
Suspicious Persons (10)
Alcohol Violation (175)
Arson (1)
Loitering/Prowling (6)
Drunk in Public (20)
Trespassing (8)
Disturbing the Peace (13)
Other Student Behavior (20)
Drug Abuse Infraction (68)
Drug Abuse Misdemeanor (10)
Drug Abuse Violation (6)
Fire (Non-Arson) (1)
Forgery (2)
Ill or Injured Student (3)
Suspicious Circumstance (1)
Found Property (2)
Information Report (2)
Terrorist Threats (1)
Vandalism (4)
Ill/Injured Due to Alcohol (20)
Liquor Law Violation Plus Drugs (50)
Burglary Tools (10)
Dating Violence (2)
Resisting Arrest (2)
Battery (2)
Vehicle Accident-Property Damage Only (1)
Theft of Bicycle Parts (1)
Weapons Violation (1)
Theft from Motor Vehicle (1)
Bicycle theft (5)
Theft from Buildings (2)
Theft All Other (1)
Theft from Coin-Operated Machines (1)

XV. CSS Information Reports: Report writing is a primary responsibility of CSS officers. “Information Reports” are generated by incidents or “occurrences,” that are, according to an email from Assistant Director John Loretto, “everything from a room search to a sexual assault. We have CAD entries that would not end in a report, say an unlock service.”

Number of Incidents: The number of incidents or occurrences logged by CSS by year are as follows:

2012: 1,672
2013: 1,510
2014: 1,537
2015: 1,617
2016: 1,996
2017: 1,622
2018: 1,612
2019: 1,923
2020: 822 (thru 9/3/2020)

XVI. Snapshot of CSS Activities: What follows is a snapshot of incidents and occurrences as documented in CSS Information Reports for the month of January 2020.

In January 2020, the following activities were documented by CSS officers in 160 Information Reports:

Found Property: 33 reports
Illness/Injury: 32 reports
Trespass: 15 reports
Drug/Alcohol Use: 13 reports
Theft: 11 reports
Vandalism: 9 reports
Disturbing Peace/Noise: 8 reports
Welfare Checks: 7 reports
Scooter Impounds: 6 reports
Fire Alarms/Gas Leaks: 5 reports
Car Damage: 4 reports
Assaults: 1 report
Unlocked Doors: 2 reports
Suspension of Lost Access Card: 2 reports
Other: 12 reports (e.g., unusual phone call to CSS, inquiry re status of non-student, students’ requests to cut bike locks)

Found Property: In the great majority of the Found Property reports, third parties such as students and staff, found abandoned or lost property. They then notified CSS officers who took possession of the property and placed it in storage.

Illness/Injury: In 25 of the 32 Illness/Injury incidents, Emergency Medical Technicians (EMTs) responded and administered first aid to students who were ill (most frequently as a result of intoxication) or injured, (most frequently as a result of sports activities). Students were occasionally provided transport services to nearby hospitals. CSS officers were present, observed and documented the incidents.

Trespass: Trespassers were typically given verbal warnings and escorted off campus by CSS officers, sometimes with the assistance of Santa Clara Police officers. Thereafter, CSS officers issued “Be On The Lookout” (BOLO) bulletins with descriptions of the trespassers. There is a written version of the verbal trespass warning, titled “Trespass Notice.”

The CSS “Trespass Notice,” is comprised of three sections: “Suspect Information,” “Type of Offense,” and “Acknowledgement of Receipt of Trespass Notice.”  The trespasser is required to sign the notice in a space designated “suspect signature.” By signing it, the trespasser acknowledges that he/she is “not allowed on or at any SCU property, building, field, sporting event, performance or any other SCU event.” This appears to be a lifetime ban from the campus. Further, the notice provides that, “Violation of this notice may lead to your arrest.” The “offenses” listed on the form include “sleeping outside,” “non-permitted sales,” “loud or boisterous behavior,” “annoying/bothering students, faculty, staff” and being “uncooperative with CSS officers.”

Some trespassers showed signs of mental illness and/or were transient/homeless.

Drugs/Alcohol: In the majority of these cases, CSS officers were contacted by Community Facilitators or other Residence Hall personnel who had detected odors of marijuana or had reason to believe that students were consuming alcohol. CSS officers conducted 10 room searches and confiscated drugs and/or alcohol in all but one of the searches.

Theft: There were ten thefts of property that included bicycles, a laptop, flags, a golf cart, a street sign from a neighboring city, and a catalytic converter. In one instance, a theft was thwarted when a CSS officer chased a man who attempted to steal a bicycle. In other thefts, CSS officers documented that the thefts occurred and followed up by locating video from surveillance cameras of some of the thefts.

Vandalism:  Examples of vandalism included knocked over motor bikes, minor car damage, election stickers on campus light poles, and sidewalk chalk drawings.

Welfare Checks: The majority of the welfare checks performed by CSS officers involved students in mental health crises. In some instances, CSS officers responded when parents, SCU Professional Staff and/or Residential Life staff called CSS about students in distress. No mental health professionals were present at any of these welfare checks.

XVII. Annual Safety Reports: Pursuant to the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act, the University publishes the Annual Security and Fire Safety Report.  It also publishes the California Annual Safety Plan Report in accordance with California Education Code 67380(a)(1) & (a)(4).  These two reports are issued by the University using data provided by multiple campus units, including Campus Safety. As required by federal and state law, the data published in the reports is minimal in that it specifies only the general type of reported crime and reported hate violence as well as the number of reports of incidents on or around the “core campus.” The specifics of the reports, including their findings and outcomes, are not described.     

XVIII. Feedback About Campus Safety Services: On September 23, 2020, a campus-wide survey, soliciting feedback from the university community about their views and perceptions of Campus Safety Services, as well their personal experiences with members of the department, was electronically distributed to undergraduate students, graduate students, faculty, staff, and alumni. There were 301 responses.

A. Responses by Category:

Undergraduates: 88 (29% of all responses); Graduates: 17 (6% of all responses); Faculty: 54 (18% of all responses); Staff: 111 (37% of all responses); Alumni: 31 (10% of all responses).

B. Responses by Race/Ethnicity:

Undergraduates (88): 37 Caucasian (42% of undergraduate responses); 5 African American (6% of undergraduate responses); 11 Latinx (12% of undergraduate responses); 13 Asian (15% of undergraduate responses); 13 Biracial (15% of undergraduate responses); 2 N. African/Middle Eastern (2% of undergraduate responses); 7 Undesignated (8% of undergraduate responses).

Graduates (17): 2 Caucasian (12%); 1 African American (6%); 4 Latinx (23%); 5 Asian (29%); 1 Biracial (6%); 4 Undesignated (23%)

Faculty (53): 36 Caucasian (68%); 3 African American (6%); 1 Latinx (2%); 3 Asian (6%); 3 Biracial (6%); 2 N. African/Middle Eastern (4%); 5 Undesignated (9%)

Staff (110): 60 Caucasian (54%); 1 African American (1%); 12 Latinx (11%); 23 Asian (21%); 6 Biracial (5%); 2 N. African/Middle Eastern (2%); 6 Undesignated (5%)

Alumni (31): 10 Caucasian (32%); 4 African American (13%); 8 Latinx (26%); 4 Asian (13%); 2 Biracial (6%); 3 Undesignated (10%)

C. General Observations: It is important to note that just 2% of SCU’s 5,694 undergraduates and 1% of the 2,975 graduate students responded to the survey. The 54 faculty respondents represent only 9% of the 568 faculty members with an academic year appointment. And while only three African American faculty members responded, they represent approximately 17% of Black faculty.

Overall, 55% of the respondents had a positive view of CSS. Those respondents with more favorable than negative opinions of CSS were staff (70% of staff responses), faculty (53% of faculty responses) and graduate students (76% of graduate responses). The respondents with more negative than favorable opinions of CSS were undergraduates (64% of undergraduate responses) and alumni (61% of alumni responses).

It is clear from the snapshot of Information Reports that CSS officers most frequently interact with undergraduates. What follows is a summary of positive and negative feedback from undergraduates and alumni, who described actual firsthand experiences with CSS personnel.

D. Positive Feedback from Undergraduates: Twenty-four (24) undergraduates reported that they had good firsthand experiences with Campus Safety. They found CSS officers to be “professional,” “caring about the safety of students,” “helpful and respectful,” and “very kind.” 

Of the 24 positive interactions, 9 (38%) were reported by students of color.

E. Negative Feedback from Undergraduates: Forty-one (41) of the 88 undergraduates who responded reported negative firsthand experiences with Campus Safety. They described CSS officers as “harassing,” “getting off on the power of getting students in trouble,” “following me for no reason [other than my race],” “demeaning,” “aggressive,” and “disrespectful of female students.”

Of the 41 negative interactions, 21 (51%) were reported by students of color.

F. Positive Feedback from Alumni: Eight (8) alumni reported positive firsthand interactions with Campus Safety. Some of their descriptions of those interactions included, “As an Asian woman, I have never had a negative experience with campus safety. With exception of a few parking tickets, I was able to move freely through campus as a student.” “The couple of times I interacted with Campus Safety . . . they were professional, knowledgeable and helpful. . . and quick to respond in times of need.” “I was graduating class of 2015. I have always had pretty positive experiences with CSS.”

Of the eight positive interactions, four (50%) were reported by alumni of color.

G. Negative Feedback from Alumni: Ten (10) alumni reported negative firsthand interactions with Campus Safety. Some of their descriptions of those interactions included the following: “CSS made me and a group of friends prove that we were SCU students while socializing on the grassy field in front of the old engineering building. All in the group were Hispanic/Latinx and to this day I wonder if they would have made us prove we were students if we had been white.” “One day in the summer, I was playing a game with some friends at their house off campus, across from Swig where young girls were staying as a part of a girls soccer camp. Most of us were black. After a camp counselor came over to question us if we had a gun or not, we didn’t and told her no. A few minutes later, CSS officer starts patrolling in front of Swig staring us down. Instead of talking with us to clear things up, the police were called.” “When I was a freshman in 2014, I called campus safety because I felt unsafe walking all the way across campus to my dorm. . . The officer refused to pick me up near the recital hall and made me walk almost all the way to Benson to meet him because it was ‘more convenient for him.’” “When I was a student ambassador, we received training presentation from CSS. We were explicitly told that it was okay to racially profile young black men and women who ‘clearly didn’t’ belong on campus.”

Of the ten negative interactions, five (50%) were reported by alumni of color.

XIX. Conversations: I engaged in conversations with CSS employees, African American former CSS employees, and African American faculty to garner their opinions and perceptions about Campus Safety Services. I promised all with whom I spoke that I would provide them anonymity; therefore, I have summarized their comments to protect their identities.

A. Conversations with CSS Personnel: On October 15, 2020, I attended a Zoom meeting with CSS personnel. The meeting was held at my request for the purposes of introducing myself to them and to invite them to speak with me about their experiences at CSS. At the conclusion of the meeting, I provided them with my email address and cellphone number and encouraged them to contact me. Thereafter, several CSS staff did reach out to me. Eventually, between October 16, 2020 and October 31, 2020, I had conversations with 21 members of CSS. Four themes emerged from the conversations: (1) their opinions of CSS and the SCU community before the August 22, 2020 interaction between an African American professor and CSS officers (hereinafter “Interaction One”), and before the October 28, 2020 exchange between the Assistant Director and attendees at the Diversity Forum (hereinafter “Interaction Two”); (2) their opinions of CSS and the SCU community after the two interactions; (3) their reflections on race relations at SCU; and (4) their recommendations to improve CSS.

(1) CSS Opinions before the Interactions: Nineteen of the 21 CSS employees had positive feelings about their work at CSS. Typical were comments such as, “This is the greatest place to work,” “This job is a breath of fresh air,” and “We are a big family.” All 21 CSS employees had generally favorable attitudes toward SCU students, staff and faculty.

(2)  CSS Opinions after the Interactions: CSS employees were angry and upset about the President’s handling of both incidents. They questioned his leadership ability with comments such as, “The President doesn’t know how to sit and listen to the facts; he is one-sided;” “There was no investigation and the President apologized and hurt CSS;” and “We were thrown under the bus with the President’s emails. He is not supportive of CSS and it doesn’t sit well.”

All but one CSS employee reported a dramatic and negative sea change in the community’s attitude toward them after the interactions, described in comments such as these: “Now, students aren’t friendly. They only see the uniform and my skin color.” “Since the incident, I have been flipped off.” “Students are unfriendly and give us the cold shoulder.” I get the “stink-eye” from faculty.”  “Faculty are hesitant to call CSS. The mood has shifted.” “Students at fraternity houses curse at us when we drive by. Students walking by us yell ‘fuck CSS.’”

(3) CSS Opinions about Race Relations: CSS employees were unanimous that they were not racist and that they perform their work in a color-blind manner. They differed, however, in their views about whether or not there was a racial divide within the department. In October 2020, CSS employees were required to attend an implicit bias training session shortly after the August 22, 2020 interaction. Their reactions to it were mixed. Several felt that the training was helpful, others viewed the training as a form of discipline, and a few felt that it was a waste of time.

(4) CSS Recommendations: When asked what they would do to improve CSS, all of the respondents recommended that their compensation should be increased. Other of their recommendations included body cameras, more surveillance cameras, more patrol vehicles, and a new facility to house CSS.

B. Conversations with African American Faculty: On November 6, 2020, I was invited by some of SCU’s African American faculty to meet with them via Zoom. During that 90-minute meeting, the faculty members expressed their concerns about Campus Safety Services in the aftermath of the August 22, 2020 interaction, and were equally dismayed with October 28, 2020 interaction. They were unhappy with the lack of African American CSS officers, questioned if the surveillance cameras were being utilized by CSS to target people of color, and described some of their own negative interactions with CSS personnel.

C. Conversations with African American Former CSS Employees: I attempted to contact former CSS African American officers, nine of whom were employed by CSS between 2010-2020. Four responded and spoke with me by phone. One of the four, a Black male, had a positive experience at CSS. The other three, Black women, reported negative experiences.

D. Conversation with Director of CSS: I spoke, by phone, with Phil Beltran, the Director of CSS. He was bewildered by the racial tension on the campus in the aftermath of the August 22, 2020 interaction. Mr. Beltran was shaken by negative emails and phone calls that CSS received after that interaction. He instructs his officers to consider only the behavior of individuals before initiating contacts. 

E. Conversation with Associate Vice President for Operations: I spoke by phone with Chris Shay, Associate Vice President of Operations, the self-described “civilian leader of CSS.” He was frustrated and angry about the administration’s response to both interactions. It was his feeling that the President’s handling of the interaction of August 22, 2020 was “an abject failure,” and demonstrated the President’s lack of leadership skills.

F. Assistant Director of CSS: Assistant Director John Loretto declined an invitation to speak with me.

G. Former Director of CSS: Former Director Charlie Arolla did not respond to my request to speak with him.

XX. Campus Security Services at Other Jesuit Educational Institutions: The SCU administration queried 26 Jesuit colleges and universities for information about their respective campus security departments. Sixteen schools (62%) responded. Below are the questions asked and a summary of the responses:

1) To whom does the Director of CSS report? All but one of the campus safety departments report directly to senior members of the schools’ administration (e.g., a Vice President, Assistant Provost, or Chief Financial Officer). At four of the schools, those senior administrators are directly affiliated with student life/affairs.

(2) Do CSS employees carry weapons? Campus security employees carry weapons at eight (50%) of the institutions.

(3) Do CSS employees wear uniforms? Uniforms are worn by campus security personnel at all 16 schools.

(4) Does CSS conduct room searches? At nine of the schools (56%), campus security officers conduct room searches; at seven schools (44%) campus security does not conduct room searches.

(5) Do you have surveillance cameras? If so, how many and how are they utilized? While all sixteen schools deploy cameras, at only one, are cameras exclusively utilized passively and not for surveillance. At that school, cameras are in fixed positions, focused exclusively on public spaces such as entry/exit points of buildings and parking lots. In the rest of the schools, cameras are actively used for surveillance; some are monitored 24/7, and some include surveillance of common areas of residence halls and other buildings. Video storage ranges from 14 days to 60 days. Ten reported the number of cameras at their institutions: 170, 250+, 400+, 450, 544, 600, 800, “numerous” and “a few hundred.”

(6) Is your institution considering changes to campus safety? If so, what are those changes? Three of the sixteen institutions are contemplating changes to their campus safety departments. One institution is considering expanding their services to the Health Sciences Campus. Also, because their campus safety workforce has recently organized as a union, the university is engaging in collective bargaining. Another college will cease outsourcing its patrol officers and will, instead, directly employ campus security personnel. A third, in response to racial issues, is reimagining its public safety department.  

XXI. Campus Security Services at a Bay Area Private University and at an Historically Black University (HCBU)

A. Private University: Campus security is provided by sworn officers who wear uniforms and are armed. Non-sworn security personnel who are unarmed, deal with parking and community service matters. Room searches are extremely rare and are conducted by Student Life. Only when investigating serious crimes does campus security conduct room searches. The university does not have a camera surveillance system. The few cameras that are on campus are used to review footage following an incident. There is no monitoring of cameras.

B. HBCU: Campus security is provided by 120 uniformed “full-fledged” police officers, some of whom are armed. There are surveillance cameras that are actively monitored at three locations---main campus, the law school, and the hospital. Campus security does not conduct room searches. When room searches do occur, they are done by Resident Assistants.

XXII. Findings:

(1) The Mixed Message Disconnect: CSS leadership sends a mixed message to its own personnel and to the SCU community. To the community, CSS purports to be the “Department of Yes,” committed to “customer service.” However, CSS’s training, verbiage, and activities also sends a message that it is primarily law enforcement focused. This mixed message has alienated some students and faculty who view CSS officers solely as enforcers.

One example of this law enforcement focus is the CSS “New Officer Orientation” PowerPoint 163-slide presentation that is infused with law enforcement/military symbols and rhetoric.[1] 

Another example is the CSS Policy Manual, a 407-page document containing the rules and regulations for CSS personnel. It utilizes a format and language that are strikingly similar to those commonly used by law enforcement agencies. Yet another example is CSS attire and paraphernalia. They have law enforcement type badges sewn onto their uniforms, carry handcuffs, wear utility belts, and the department utilizes a badge as its official logo on department stationery. Some of the CSS officers stated that they have never utilized their handcuffs, and one reported that he used them once in his entire time in the department.  Additionally, the names of the various positions within the department---Watch Commander, Assistant Watch Commander, and Officer---are similar to those used in police departments and in the military.

It is, therefore, understandable why a CSS employee described the department as having “the same small feeling of a police department,” while another depicted it as “run like a police department without guns or badges,” and yet another described their work as “enforcers.”

Room searches by CSS officers reinforce the law enforcement image. CSS officers photograph students’ rooms, question students, direct them to leave their rooms while they conduct the room searches, and they document all searches in Information Reports--- all activities that are similar to what police officers do when executing search warrants.

Another concern about these symbols and imagery is that they are “triggers” for people of color whose personal experiences and history of interactions with police have left them understandably suspicious and distrustful of law enforcement. This triggering phenomenon is not unique to Santa Clara University. A recent article in the National Catholic Reporter exploring the relationship between Catholic college campus security departments and campus communities, found that students of color on several Catholic campuses experienced triggers in reaction to their campus security officers.[2] 

(2) The Racial Disconnect: Conversations with CSS leadership and personnel indicate that many, if not most, operate with a color-blind, “I never see a person’s color” mindset. This color-blind ideal, although fine sounding, is difficult, if not impossible, to achieve. In her acclaimed book Biased: Uncovering the Hidden Prejudice That Shapes What We See, Think and Do, social psychologist Jennifer Eberhardt, the nation’s leading authority on implicit bias, notes that, “[T]he color-blind approach has consequences that can actually impede our move toward equality. When people focus on not seeing color, they may also fail to see discrimination.” In fact, Dr. Eberhardt notes that the ideal of color blindness promotes exactly the opposite of what is intended: racial inequality. Interestingly, even after undergoing implicit bias training presented by members of Dr. Eberhardt’s team, several CSS officers continued to assert that they were color-blind. Bottom line---good intentions, uninformed by racial awareness, can have unfortunate impacts.

Over the last ten years, CSS has seen nine African American employees come and go. Currently, there is a biracial Asian/Black employee; no other employees are African American. Some CSS employees believe that the department should actively recruit African Americans. However, there are two employees who are satisfied with the current staffing. Given the importance of having campus security personnel who reflect the community they serve, especially important to people of color who frequently feel marginalized or targeted by law enforcement, the failure of some CSS employees to appreciate the value that African American employees can bring to the department and to the SCU community is concerning and a sign of a racial disconnect within the department, itself.

(3) Need for Racial and Gender Diversity in Leadership Positions: Campus Safety Services has never been led by a woman. All of its Directors and Assistant Directors have been white males, with the exception of the current Director who is a biracial (Caucasian/Latinx) male. Of the nine command staff positions, ---four Watch Commanders and five Assistant Watch Commanders, ---only one is female. The Director of Parking & Transportation Services is female.

(4) Need for Transparency: The Policy Manual containing the rules and regulations that govern Campus Safety Services is not available to the SCU community.

Campus Safety Services does not issue annual reports that describe their activities. As a result, the SCU community is in the dark about exactly what it is that CSS employees do. For instance, several faculty members did not know about the trespass policy, were unaware that there are hundreds of cameras throughout the campus that are monitored 24/7, and that CSS officers carry handcuffs. Some were unaware that CSS officers conduct searches of students’ rooms.

Secrecy promotes distrust; transparency builds trust. If the rules, policies, and activities of a campus safety department are available to the community, then those who are directly impacted by the department---students, faculty and staff--- will better understand how the department operates, and as a result, will likely be inclined to support the work of the department’s employees.

(5) Need for Feedback:

(a) Complaints: There are various forums at which individuals at the university can file complaints such as Human Resources, the Office of Affirmative Action, and EthicsPoint. The complaint process for students, faculty, staff and those not affiliated with the university who have concerns about the conduct of CSS employees is described in section 1010 of the Policy Manual. However, the Policy Manual has yet to be approved. The language in section 1010 mirrors that of most law enforcement agencies. As well, section 1010 adopts a procedure typically utilized by most law enforcement agencies in that all but the most serious complaints against CSS personnel are investigated by individuals within the department.

A formal complaint process is important because it ensures accountability, which, in turn, establishes trust. But that trust is engendered only when the investigations of complaints are conducted objectively and thoroughly. An organization that investigates its own has neither the appearance of, nor the actual ability to do so objectively and without bias.

A complaint process must be user-friendly, with complaint forms that are easily accessible to members of the community. And to ensure transparency, annual reports should be issued describing, with specificity, the nature of all complaints received and the findings for those complaints. Finally, a broad outreach program is necessary to inform the community about the complaint process.

(b) Campus surveys and/or Online Feedback: Until this audit, there had never been a campus-wide survey seeking feedback about the quality of services initiated by CSS. The department has not sought such input from the SCU community, neither has it established an online process to obtain immediate feedback. An organization that does not periodically request feedback from the community it serves is an organization destined to become alienated from that community, and, as importantly, it is an organization that will miss opportunities to improve its own operations.  

(6) Need for Training on Mental Health Issues: Sadly, college campuses have not escaped the mental health crisis that grips this nation. According to The Clay Center for Young Healthy Minds at Massachusetts General Hospital, 73% of students experience some sort of mental health crisis during college. (Source: And the American Psychological Association reports that in a recent survey, 94% of counseling center directors indicated that the trend toward greater numbers of students with severe psychological problems continues to be true on their campuses. (Source:  At Santa Clara University, campus safety services officers responded to ten welfare checks in the month of January 2020, the great majority of which involved students in mental health crises. There were no mental health professionals on site for any of these welfare checks. As well, it does not appear that CSS officers undergo mental health trainings, although Campus Safety Leadership serves on the JED Committee and Behavior Concerns Team.

In addition, individuals contacted by CSS and treated as trespassers frequently showed signs of mental illness. With mental health training that includes information about resources outside of the university, CSS employees could make referrals to assist these individuals.

When campus security are the first responders to calls for assistance for students in crises, it is imperative that their training includes a fundamental understanding of psychological disorders. It is equally important that they understand how to respond to students in a way that alleviates, not aggravates, their stress. Therefore, it is critical that responders to young people who are in the midst of mental health crises demonstrate maturity and sensitivity. For this reason, they should have some real-world experience and an education beyond that of high school.

XXIII. Audit Recommendations

(1) Reimagine Campus Safety Services Utilizing a Holistic Approach

There should be a new and different approach to campus safety at Santa Clara University, beginning with a transition to a reimagined department that is operated under the auspices of the Division of Student Life.

Such a transition is not unprecedented, as some Jesuit institutions require their campus safety departments to report to senior administrators affiliated with student affairs. As well, the transition to Student Life is logical because campus safety officers most frequently interact with undergraduates. For instance, the vast majority of the 160 incident reports generated by CSS in the month of January 2020 involved undergraduate students. Such a realignment will not in any way change the mission of campus safety to care for and protect the entire SCU community. If anything, it will enhance that mission. Why? Because SCU’s Division of Student Life actively seeks to build strong relationships with students, support student success, and collaborate across departments to support a safe campus environment. Reimagined under the Division of Student Life, the department will necessarily shift away from a focus primarily on enforcement to a focus on campus safety and student wellness. With this approach, a reimagined campus safety department can fully embrace the Jesuit philosophy of cura personalis, caring for each person in mind, body and spirit.

(2) Recommendations for the Operation of a Reimagined Campus Safety Department

1. Revise the Policy Manual to reflect the philosophy of the reimagined department.

2. Revise campus safety position descriptions to reflect the reimagined department’s philosophy, including the replacement of law enforcement/military titles of positions with non-law enforcement/military titles.

3. Revise the campus safety website to reflect a reimagined department.

4. Discontinue the use of handcuffs and the wearing of law enforcement type badges.

5. Redesign the uniforms and the logo for a non-law enforcement/non-military look.

6. Discontinue room searches by campus safety.

7. Determine if surveillance cameras should be utilized actively (24/7 monitoring) or passively (unmonitored and used primarily to review footage following an incident).

8. Revise the new officer orientation PowerPoint to reflect the reimagined department’s philosophy.

9. Review and re-evaluate the campus trespass policy and use of the trespass notice form, and ensure that any such policy is fair and conforms with best practices.

10. Include students on the reimagined department’s staff.

11. Ensure that the recruitment, promotion, and retention policies of the reimagined department promote diversity with respect to race, ethnicity, age, gender, sexual orientation, and that best efforts are made to maintain a diverse and representative staff, and a welcoming environment.

12. Require periodic anti-bias and implicit bias training for all personnel.

13. Require a minimum of an A.A. degree or equivalent education for all hires.

14. Ensure that all of the reimagined department’s policies and procedures are available, online, for the entire SCU community.

15. Develop an orientation video about the reimagined department for the SCU community.

16. Prepare and submit an annual comprehensive campus safety report to the President that includes detailed information about all activities, including specific information about all complaints.

17. Maintain an official history of campus safety. 

18. Create a complaint process that provides intake of complaints of misconduct against campus safety personnel by someone outside of CSS; that person will also conduct investigations of those complaints and make findings. The complaint process should include (1) the creation of an official complaint form that is available online, and in hard copies placed in convenient areas throughout the campus; and (2) outreach to inform the SCU community about the complaint process.

19. Create an immediate feedback process for individuals who have had interactions with the reimagined department.

20. Conduct periodic campus-wide surveys about campus safety and report the survey findings, campus wide.

21. Include mental health professionals in the reimagined department’s on-site response team.

22. Require periodic mental health trainings for all of the reimagined department’s personnel.


 [1] Slide #7 shows a white male in a military uniform, his head bowed, with the words, “If you wanna change the world, start off by making your bed.” That slide is followed by two slides entitled, “Chain of Command,” with the hierarchy of CSS personnel: Watch Commander, Assistant Watch Commander, Officers. Slide #26, entitled “New Officer Training Schedule,” is accompanied by a photograph of two men in army camouflage uniforms, one of whom is kneeling and pointing to the other who is doing push-ups. Slide #46, entitled “Job Expectations-Experience,” shows a head shot of a white male wearing the uniform of a private security guard. In Slide #87 entitled, “Mindset,” is a photograph of a white male standing at attention and dressed in a law enforcement uniform. Slide #125 depicts the face of a stern-faced white male with the words “The War Path, Motivational Video.” In slide #151, entitled “Tourniquets-Application to arm,” two men are depicted wearing military fatigues.

[2]  “Students, faculty demand change in policing on Catholic campuses,” by Madeleine Davison, National Catholic Reporter, 12/10/2020,