Question: I’m the owner of a local boutique hotel. I recently heard that I need to provide training to my employees about human trafficking. I already post a notice about human trafficking as required by law. Do I still need to provide human trafficking training to my employees?
Answer: Yes, under a new California law (SB 970), hotels and motels, excluding bed and breakfast inns, must provide at least 20 minutes of classroom or interactive training to all employees who are “likely to interact or come into contact with a victim of human trafficking.”
Such employees include, but are not limited to, housekeepers, maintenance personnel, room service, concierge, bellhops/porters, valets, guest drivers, parking lot attendants, front desk attendants, servers, bartenders, bussers, food runners and hosts. Although the new law does not require all hotel and motel employees to receive the training, it is recommended that they all receive it because they all may interact with or have contact with a human trafficking victim.
The human trafficking awareness training and education material must include the following:
- The definition of human trafficking and commercial exploitation of children.
- Guidance on how to identify individuals who are most at risk for human trafficking.
- The difference between labor and sex trafficking specific to the hotel sector.
- Guidance on the role of hospitality employees in reporting and responding to this issue.
- The contact information of appropriate agencies to report suspected trafficking including, but not limited to, the National Human Trafficking Hotline toll-free telephone number, 1-888-373-7888, and text line, 233733, and the telephone numbers of the appropriate local law enforcement agencies.
Employers may provide additional training beyond the required 20 minutes and expand the training topics.
As a resource for training materials, employers can use information provided by certain federal agencies, including the Blue Campaign, which is part of an effort by the Department of Homeland Security to combat human trafficking. The Blue Campaign materials can be accessed at https://www.dhs.gov/blue-campaign/request-materials.
Employers must comply with the human trafficking awareness training and education no later than January 1, 2020. If an employer has already provided the training and education to an employee prior to January 1, 2019, the employer is not required to provide the employee with additional training before the January 1, 2020 deadline. Thereafter, employers are required to provide the required training and education every two years. Additionally, each new employee must be provided with the training and education within six months of being hired or when an existing employee’s position changes and the change results in the employee working in a new position that is likely to interact or come into contact with the public.
Although the new law requires that hotel and motel employers provide human trafficking awareness training to employees, it does not change the employer’s obligation to post a notice about human trafficking in a conspicuous place in clear view of the public and employees, such as a public entrance. This requirement applies not only to hotels and motels, but also to various businesses such as bus stations, truck stops, roadside rest areas, and businesses with an on-sale general public premises Alcoholic Beverage Control Act license, to name a few. For more information regarding the posting requirements and to download the notice visit https://oag.ca.gov/human-trafficking/model-notice. In addition to English, the notice is available in 23 languages.