If you know anything about human trafficking, then you probably know hotels & motels are a hotspot for the activity. Thus, it seems only necessary to ensure the hospitality industry is trained to know exactly how to detect and report suspicious behavior. Don't get us wrong, we agree – the i-5 Freedom Network consulted on SB-970, the legislation that made it California law for hotels to undergo human trafficking awareness training.
But does getting compliance training actually equip hotels to deal with human trafficking on their property? It's been over a year since this bill has been implemented and we want to examine how effective mandatory training has actually been.
Awareness vs. Action
If the goal of these trainings is awareness, then their success is dependent on the training quality and whether the hotel is trying to check a box or check traffickers at the door. And what happens after awareness? What are the actionable steps hotels can take to actually make a difference? When they are not given the tools to implement new policies, or if they are apathetic towards making changes, the training might be doing more harm than good. How could that be? We’ll tell you.
When it’s harmful
Out of 14 Orange County hotels we interviewed at random, 100% of those that had completed training stated they hadn’t implemented any new policies or procedures. We don’t blame them. Without a guide on how to change hotel policy, mandatory compliance training is doing little other than pointing out a problem and leaving.
For example, training might advise a hotel to do a wellness check on rooms that have displayed the “do not disturb” sign for over 3 days. But more often than not, different housekeepers are cleaning the room each day, and there is no hotel policy to keep record of which room has a “do not disturb” sign and when. Let’s say they do happen to keep a “do not disturb” log – this is only effective when someone monitors it and flags those rooms. Furthermore, limited staff and covid restrictions have forced hotels to offer only limited cleaning between guests and not on a daily basis as in the past, creating additional challenges to monitoring in-room activity.
This issue of training without implementation has led to a mess of lawsuits for some hotels. Once they’ve received training, prosecutors argue, they have no excuse for trafficking to continue to happen on their property. They should have known better, done more. Certainly there are hotels out there that turn a blind eye for a myriad of reasons, but we know there are plenty that care and didn’t realize they weren’t properly equipped.
Illusion of Security
This leads us to another unintended consequence of compliance training – it gives a false sense of security that makes hotels feel they’ve done everything necessary to prevent trafficking. Meanwhile, they’re missing signs right in front of them. Before training, most hotels were an open door to trafficking. Getting training is like closing the door to traffickers and thinking you’re safe, but leaving the door unlocked. The key to locking the door is proper implementation.
When it’s helpful
Training is helpful when hotels are given concrete procedural changes they can make. Instead of vague instructions that lack the foresight to see how new changes will interact with existing policy, they need a step-by-step of best practices that will actually do something to prevent trafficking on their premises. Instead of being told to do a wellness check after 3 days, for example, hotels need to be given a housekeeping log and help designating an individual to monitor it not only for "do not disturb" signs but for other red flags as well.
As luck would have it, the i-5 Freedom Network is introducing our After Training Implementation Plan, otherwise known as ATiP. We offer a customized implementation plan for each hotel and provide the materials needed to follow through. The content is designed by a team of people with hotel management experience and human trafficking expertise. An i-5FN point of contact is assigned to each hotel for semi-annual progress updates, and is always available for questions or issues that arise. At i-5 Freedom Network we are hotel allies, and we know that implementing these procedures is not only excellent guest service and a preventative measure against lawsuits, but will help hotels lock their doors to trafficking for good.