Commercial Lodging Human Trafficking Training Standards

LAST UPDATED: 12/17/2021

Purpose of the Training Standards

The Texas Legislature passed House Bill 390 (87th Regular Session), which requires the Office of the Attorney General (OAG) to create signage and approve training for the hospitality industry. House Bill 390 seeks to provide additional opportunities for human trafficking to be reported to law enforcement by requiring human trafficking training for workers directly employed by certain commercial lodging establishments. This annual training requirement only applies to commercial lodging establishments of 10 or more rooms (as defined by Sec. 114.0001, Texas Business and Commerce Code), but is encouraged for all lodging establishments in the State of Texas regardless of size.

Criteria for Approval of Training Course

To be approved by the OAG, the training course must meet the human trafficking training standards listed below. Each course must also comply with all federal accessibility standards, pursuant to Web Content Accessibility Guidelines (WCAG) 2.1 AA.

The OAG reserves the right to deny approval of any training course regardless of the score earned on the assessment tool if the training is not otherwise in compliance with state and federal law or agency policies. For more information on the review and approval process, please visit the OAG’s website.

OAG approval will be based on three main categories: design requirements, key components, and certificate/compliance. Each category contains specific standards targeting key information to be included in the training. Category scores identify areas of strength or weakness. The total score indicates the degree to which a training complies with statutory requirements, adheres to best practices, includes a comprehensive overview, considers trauma-informed practices, and upholds survivor- informed principles.

The training may be offered in person or online. If the training is in person, the application must include the slides and an instructor’s outline. If the training is online, it must be hosted by the person submitting the training or with their approval. The online training must also include a pacing mechanism that requires the employee to read all course materials, view all videos, complete all coursework, and certify that the employee has completed all coursework before issuing a certificate of completion.

Design Requirements

  1. The training excludes sensationalized imagery, bias, prejudice, or confidential information.
  2. The training is designed with human trafficking survivor consultation.
  3. The training content is evidence-based and free from factual errors. If statistics are used, there should be a citation and references to where these statistics were found and the date the statistic was published.
  4. The learning objectives are clear, and these objectives are met with the training.
  5. The training must cover the key components, found below.
  6. If offering continuing education credit, the training should clearly state the type of continuing education credit that will be awarded and detailed instructions on how to document and apply for the credit.
  7. The training material must not be less than 20 minutes in duration.

Key Components

  1. Includes an overview of human trafficking:
    • The training must define human trafficking.
    • The training describes the concepts of force, fraud or coercion within the context of human trafficking.
    • All major forms of trafficking (including labor, sex, adult, child) are identified and discussed.
    • The training clarifies that trafficking does not require crossing international or state borders.
    • The training differentiates between human trafficking and smuggling as well as sex and labor trafficking.
    • The training includes a description of the experience of human trafficking victims.
  2. Contains guidance on how to identify individuals who are most at risk for human trafficking. This should include specific red flag indicators of human trafficking, including:
    • Person appears submissive, fearful, tense, or paranoid. 
    • Person has physical injuries or branding such as a name tattoo. 
    • Person defers to another person when answering questions.
    • Person works but lacks control over their money or identification documents. 
    • Person is unsure about who they are with and what they are doing.
    • Person works excessive hours and lives where they work.
    • Person’s clothing is inappropriate for weather conditions or the situation.
    • Person has multiple phones or social media accounts. 
  3. Provides information related to the identification of human trafficking in the hospitality industry.
    • The training explains how and why human trafficking takes place in the hospitality industry.
    • The training discusses commercial lodging’s role in addressing sex trafficking.
    • The training identifies different types of hotel contract workers, who are vulnerable to labor trafficking.
  4. Guides staff on their role in reporting and responding to human trafficking:
    • The training provides guidance on the role of an employee in reporting and responding to human trafficking, including how to respond to any victims asking for assistance.
    • The training lists the contact information of appropriate entities for reporting human trafficking, including the National Human Trafficking Hotline toll-free telephone number and text line, appropriate local law enforcement agencies, and a telephone number designated by the attorney general for reporting suspected human trafficking. Specifically, the training must direct the audience to call 911 in an emergency, to contact iWatchTX at or 844-643-2251 if they have information for law enforcement regarding suspicious activity related to human trafficking, and to contact the National Human Trafficking Hotline at 888-373-7888 or text 233733 regarding assistance for victims of human trafficking.
    • The training includes information on the human trafficking signage required to be displayed in commercial lodging establishments.
    • The training includes information regarding the requirement that employees of commercial lodging establishments receive annual human trafficking training, and it must contain the following language: that employees "may not be disciplined, retaliated against, or otherwise discriminated against for making a good faith report of a suspected act of human trafficking."

Certification & Compliance

  1. The training must be approved by the OAG.
  2. The training must be completed by a new employee of the establishment not later than the 90th day after the date the employee is hired.
  3. All employees must be trained annually.
  4. The approved training provider must provide a certificate of completion to every employee who completes the training, and the certificate of must include the date the course was taken and the title of the course.
  5. An operator of a commercial lodging establishment must retain a paper or electronic copy of each annual certificate of completion for every employee who completes the training.
  6. The operator of a commercial lodging establishment is required to maintain sufficient records to show the operator’s compliance with Section 114.0051, Texas Business and Commerce Code. They must make these records available for review and inspection at the request of the OAG, as well as local, state and federal law enforcement.