HOTHTC Policies and Procedures
Table of Contents
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Policies & Procedures Regarding Membership & Participation
GENERAL COALITION MEMBERSHIP
PARTICIPATION
LEADERSHIP & PROCEDURES
VISITATION BY OUTSIDE AGENCIES
INTERACTIONS WITH MEDIA
Policies & Procedures Regarding Victims & Survivors of Human Trafficking
INFORMATION SHARING & DATA COLLECTION
CONFIDENTIALITY
REFERRALS OF POTENTIAL VICTIMS
IDENTIFICATION, SCREENING, AND INTERVIEWING OF VICTIMS
SERVICES NEEDED FOR IDENTIFIED VICTIMS
INTERPRETER/LANGUAGE POLICY
VICTIM PROTECTION AND REQUESTS FOR CONTINUED PRESENCE (CP)
HANDLING CASES WITH A LARGE NUMBER OF VICTIMS
Policies & Procedures Regarding Prevention & Outreach
OUTREACH TO RURAL AND UNENGAGED AREAS
PREVENTION & AWARENESS MATERIALS
SHARING HOTHTC STATISTICS & TRAININGS
POLICIES AND PROCEDURES REGARDING REPORTING & PROGRAM EVALUATION
DATA COLLECTION & REPORTING
POLICIES & PROCEDURES REGARDING MEMBERSHIP & PARTICIPATION
GENERAL COALITION MEMBERSHIP
Coalition membership is established for local, state, and federal agencies and community organizations working within the Heart of Texas Region. Agencies may apply for coalition membership through the website at HOTHTC.org. The HOTHTC will review applications and decide if membership designation will be given. Membership will be evaluated on an annual basis, and the coalition maintains the right to revoke membership for agencies or coalition members not complying with coalition protocols.
Coalition members who represent service agencies are expected to actively participate in coalition activities, including roundtable meetings, subcommittee meetings and other training and public awareness activities. If needed, coalition members will establish an Memorandum of Understanding (MOU) with the Coalition Task Force Coordinator.
Members will designate one main representative/point of contact from the agency. In most cases, this should be an executive director, Chief or other person with decision-making power within the agency. Members can have multiple representatives from their agency, but each representative should be tasked with implementing coalition goals in some part of their role within the agency.
Steering Committee members must attend at least 80% of all Steering Committee meetings and at least 80% of all committee meetings for which they are responsible. The Steering Committee may terminate committee membership if a said member fails to meet this requirement.
PARTICIPATION
Coalition partner agencies are expected to actively participate in coalition activities, including Roundtable meetings, subcommittee meetings and other training and public awareness activities. Coalition partners are encouraged to collaborate with other agencies and initiate contact to give or receive assistance or training.
PARTICIPATION LEVELS:
High Level - Participate in Quarterly Roundtable, Bi-Monthly Subcommittee, Coalition Events
Medium Level - Participate in Quarterly Roundtable
Low Level - Email List
LEADERSHIP & PROCEDURES
The Heart of Texas Human Trafficking Coalition is led by the Steering Committee, also referred to as the Task Force, comprised of co-chairs of each subcommittee and representatives from key leaders of the six-county area. Other Steering Committee members include community leaders identified by the HOTHTC, representing local law enforcement, education, and victim service providers.
The Coalition Chair and Task Force Coordinator will call and lead Roundtable and Steering Committee meetings as well as facilitating the achievement of goals for the coalition. Subcommittee chairs will call subcommittee meetings, facilitate the achievement of subcommittee goals, and report on subcommittee efforts to the Steering Committee. The lead agencies in the HOTHTC are the Advocacy Center for Crime Victims and Children, Unbound Waco, Waco Police Department CAC Unit, McLennan County Sheriff’s Office, Homeland Security Investigations, McLennan County District Attorney’s Office, and the United States Attorney’s Office.
VISITATION BY OUTSIDE AGENCIES
Agencies within the geographic region of the coalition who do not wish to become members and agencies outside of the geographic region are permitted to attend roundtable meetings to learn about regional efforts and receive training. Non-members may not participate in subcommittee meetings or identify as members of the HOTHTC.
The Heart of Texas Human Trafficking Coalition leadership and/or Steering Committee reserves the right to determine membership and visitation eligibility on a case-by-case basis.
INTERACTIONS WITH MEDIA
If media contacts any Coalition partner/organization regarding the Coalition or a human trafficking case, partner agencies are encouraged to reach out to the Task Force Coordinator to collaborate on the media piece.
HOTHTC stakeholders should practice confidentiality and non-disclosure for the safety of victims or potential victims. HOTHTC stakeholders should hold to a "no comment" policy on any open/active cases.
HOTHTC stakeholders are encouraged to use victim-centered, trauma-informed language and vocabulary when discussing prostitution/commercial sex, human trafficking, perpetrators, victims, and other related topics with the media.
All questions regarding HOTHTC’s media practices may be referred to info@hothtc.org.
MEMBERSHIP SHARING POLICY
HOTHTC members may not share or distribute email lists, personal information, or professional contact information provided by coalition members without said member’s permission.
POLICIES & PROCEDURES REGARDING VICTIMS & SURVIVORS OF HUMAN TRAFFICKING
INFORMATION SHARING & DATA COLLECTION
The purpose of information sharing is to work toward collaboration in providing comprehensive services to victims, in conducting successful investigations and prosecutions, and in keeping accurate data on the scope and effectiveness of the work of the Heart of Texas Human Trafficking Coalition (HOTHTC). Data collection for the region is requested by state and federal agencies to keep apprised on human trafficking activities across the nation.
HOTHTC is committed to the protection and appropriate sharing of case information for the safety and confidentiality of victims.
For the safety and service of victim(s), agencies are encouraged do the following options:
Contact the Regional Care Coordinator upon suspicion or identification of trafficking victim(s). The Regional Care Coordinator will contact coalition partner victim service provider(s) in order to provide support and services to victim(s) as soon as possible.
When the Regional Care Coordinator or other victim service provider learns relevant information pertaining to human trafficking, they will notify law enforcement, with informed consent from the potential victim. In the case of a minor, law enforcement will be notified immediately. If law enforcement needs assistance for the placement of the victim, they are encouraged to share basic information needed with the appropriate service provider who will secure safe placement.
CONFIDENTIALITY
HOTHTC member partners will respect the confidentiality of all potential and confirmed human trafficking victims, according to their agency’s policies. Information will only be shared on a need-to-know basis for the purpose of serving victims of human trafficking and according to mandatory reporting requirements.
The Regional Care Coordinator will track victim service information. Each agency is encouraged to maintain a MOU with relevant partner agencies for the sharing of victim information.
When a potential victim is identified by a non-law enforcement HOTHTC member, the victim should be advised of their right to confidentiality and privacy. If possible, minimal central demographic information and information regarding what services the victim/client requests and uses should be collected, including gender, age or age range, ethnicity, immigration status, number of children, types of services requested, and types of services provided.
This information should be provided to the Regional Care Coordinator for case tracking purposes. More extensive intake information may be documented by the service provider(s), after the victim has given consent, according to information-sharing MOUs between victim service providers. Information will remain protected by the agency’s confidentiality policies and practices, unless the victim specifically, in writing, authorizes the sharing of that information between partner agencies. If the victim is a minor, the victim’s parent, legal guardian, or attorney ad litem may sign a Release of Information (ROI) on their behalf. A number and/or a pseudonym will be assigned to each victim, and a victim’s true name will not be disclosed to coalition partners without the victim’s written consent.
REFERRALS OF POTENTIAL VICTIMS
Upon identification of a potential victim, coalition member agencies are encouraged to contact the Regional Care Coordinator, who will contact a case manager to provide an intake and eligibility assessment to determine if the individual is a victim of a severe form of trafficking (under TVPA definition). Depending on the eligibility of the victim, a case manager will be assigned, and a needs assessment and/or individualized service plan will be completed. The victim will then be referred to other service(s), as needed.
The agency assignment for case management of the victim will depend on the victim’s situation (i.e. their location, age, immigration status, custody/guardianship, etc.). If the victim is a foreign national, they will be referred to a legal immigration service provider who can assist them in legal matters. The assigned case manager should provide data to the Regional Case Coordinator on the victim’s location, progress, and services recommended and received on at least a monthly basis.
If any victim/client referrals to non-HOTHTC member service providers are warranted, such referrals will be made in a way as to preserve confidential victim information. For example, referrals to member and non-member providers can be made by giving the victim the contact information of the provider so he/she can contact the agency directly.
IDENTIFICATION, SCREENING, AND INTERVIEWING OF VICTIMS
Coalition best practices encourage a coordinated effort between law enforcement and victim service providers to serve potential or identified victims of human trafficking.
All victim service provider coalition partners are encouraged to notify the Regional Care Coordinator when a potential victim comes into their care or is identified for the purpose of data collection. Victim service provider coalition members should follow the terms of their MOUs in sharing information. Victim service providers will contact law enforcement when a potential victim is referred for screening if 1) the potential victim is a minor, 2) the potential victim is a danger to themselves or others, or 3) the potential victim agrees to speak with law enforcement, along with all applicable reporting laws. Victim service providers should encourage potential and confirmed victims to cooperate with investigations.
If agencies are unsure of a client’s eligibility for human trafficking services, a consultation from a victim service provider can be requested. The case manager will conduct intake and eligibility assessments to determine if an individual is a victim of a severe form of trafficking (under TVPA definition). Victims will be offered resources based on the eligibility assessment. Law enforcement victim designation is not necessary for access to resources and services.
Law enforcement are encouraged to make a reasonable effort to interview victims in a trauma-informed and victim-centered way. Language access should be provided through translators or language line, where applicable. Members should work to build support and should not discount victimization if a victim does not cooperate or make an outcry. Special consideration should be given to the unique vulnerabilities and impact of trauma on child victims in the interview process, such as use of a forensic interview through the Advocacy Center for Crimes against Victims and Children.
SERVICES NEEDED FOR IDENTIFIED VICTIMS
The HOTHTC victim service providers will deliver a comprehensive array of services for victims of all forms of human trafficking that may be identified within Bosque, Falls, Freestone, Hill, Limestone and McLennan Counties. Services will be made available to victims of all ages and sexes, foreign nationals (those with immigration documents and those who are undocumented), U.S. citizens, and individuals who identify as lesbian, gay, bisexual, pansexual, transgender, genderqueer, queer, questioning, intersex, asexuals or other sexuality or gender identifications (LGBTQIA+).
When assigned by the Coalition Regional Care Coordinator, case managers will first ensure that emergency medical needs and basic needs such as safety, shelter, and sustenance are met. Case managers will then assess client needs and develop individualized service plans, including activities such as assessing eligibility for other public or community-based programs, assisting victims in accessing publicly funded programs, documenting safety planning, assisting with crime victim compensation claims when possible, giving information and referral, documenting services provided, and routinely following up to ensure that the victim’s needs are being addressed through project partners. The HOTHTC is committed to helping victims find resources to meet their unique and individualized support needs, beyond what could be anticipated or spelled out in a plan for delivery of comprehensive services.
Comprehensive services include shelter and housing, mental health needs, medical health needs, legal needs, education, and job training/placement. Due to the availability and collaboration of multiple agencies within HOTHTC, many of the services will be provided through MOU providers, with other community-based or public agencies, pro bono services, or other state or government subsidized programs.
INTERPRETER/LANGUAGE POLICY
Unbound will provide interpreters for hearing-impaired, Spanish- and Mandarin speaking victims and potential victims. All Unbound interpreters will receive training for this role. All interpreters will abide by the HOTHTC policy on confidentiality and will attempt to provide all available services in that survivor’s native language.
If an interpreter is not available or another language source is needed, the Advocacy Center for Crime Victims and Children or Unbound will use OVC funding to leverage a language hotline.
VICTIM PROTECTION AND REQUESTS FOR CONTINUED PRESENCE (CP)
HOTHTC members should look to federal and state legislation to assist victims with protection under the law. Relevant legislation includes: United States Code, the Trafficking Victim Protection Act of 2000, the William Wilberforce Trafficking Victim Protection Rehabilitation Act of 2008, the Office for Victims of Crime, the Bureau of Consular Affairs regarding Workers’ Rights.
HOTHTC members are encouraged to share information and work in unison to identify which laws best afford identified victims the assistance and protection they need. HOTHTC law enforcement and prosecutors should be familiar with the Continued Presence and relevant paperwork and process to support victims that qualify for CP.
If found eligible, this provides victims access to many federally funded public benefits and employment authorization. The victim's cooperation with law enforcement is not a requirement for receipt of Continued Presence status, however, enough information must have been collected to determine their eligibility.
For Long-Term Immigration Status, victims may qualify for other forms of immigration benefits depending on their unique circumstances. Law enforcement officials are encouraged to work with coalition victim service providers and legal service providers for further assistance.
HANDLING CASES WITH A LARGE NUMBER OF VICTIMS
HOTHTC law enforcement and prosecutors are encouraged to jointly assist one another with cases in which large numbers of victims are identified.
Although individual and personal contact with victims is recommended whenever reasonably feasible, there may be situations where it benefits the victim and/or the case to proceed jointly where multiple victims have been identified.
Law enforcement and prosecutors are encouraged to implement higher and more frequent oversight and monitoring in order to provide victims in large cases with the same rights and services as victims in smaller cases.
POLICIES AND PROCEDURES REGARDING PREVENTION & OUTREACH
OUTREACH TO RURAL AND UNENGAGED AREAS
The HOTHTC will endeavor to engage rural communities in Bosque, Hill, Falls, Freestone, Limestone and McLennan Counties. Coalition member agencies will collaborate with agency associates working with rural areas and unengaged sectors to encourage involvement in the coalition’s efforts. Representatives from each county will be identified and trained to provide training and resources within their communities. Coalition awareness materials and other relevant resource materials will be made available to rural areas and unengaged sectors.
PREVENTION & AWARENESS MATERIALS
The Heart of Texas Human Trafficking Coalition aims to increase community awareness for the prevention and identification of human trafficking victims throughout the Heart of Texas Region. To accomplish this goal, HOTHTC creates and distributes prevention and awareness materials to coalition partners and community members at community events, trainings, and coalition roundtables. Requests for materials can be made to the Task Force Coordinator.
Digital files of the materials may be shared with coalition partners but may not be altered without the permission of the Task Force Coordinator.
SHARING HOTHTC STATS & TRAININGS
When a coalition partner is asked to present, train or provide statistics or information about the Heart of Texas Human Trafficking Coalition, it is requested that the partner communicates with the Task Force Coordinator before the training to ensure the most accurate and up-tp-date information is shared. Partners are encouraged to share about the work of the coalition in their trainings.
POLICIES AND PROCEDURES REGARDING REPORTING & PROGRAM EVALUATION
DATA COLLECTION & REPORTING
The Heart of Texas Human Trafficking Coalition (HOTHTC) will gather, share and analyzing law enforcement and victim service data, in order to evaluate coalition efforts and develop a comprehensive understanding of the root problem of human trafficking within the Heart of Texas region, as well as identify any factors that may be leading to human trafficking activities.
All agencies funded through the coalition grant are required to submit victim data. According to coalition best practices, HOTHTC partnering victim service providers and other partnering community organizations are requested to report victim data to help achieve this goal. Coalition partner agencies can contact the Task Force Coordinator for access and training to use the regional case management system.
In addition to collection of victim service data, HOTHTC partners are requested to submit information on training and public awareness initiatives on human trafficking to help capture an accurate account of community awareness. This data will be submitted to the HOTHTC Task Force Coordinator. All HOTHTC members will send information on training and public awareness to the Task Force Coordinator, who will provide that information to the Advocacy Center for Crime Victims and Children (ACCVC).
All HOTHTC member victim service providers and other member community organizations will report victim data in accordance with the MOUs established for the purpose of collecting data in the region.
Additionally, all HOTHTC law enforcement agencies are encouraged to provide data on identification of human trafficking victims and investigation and prosecutions of sex and labor trafficking crimes in order to capture accurate information on the numbers of investigations, prosecutions and identifications occurring across the region. This data should be provided to the Regional Care Coordinator who is responsible for the collection of this information.
The Regional Care Coordinator and the Task Force Coordinator will make reasonable efforts to collect data from non-member agencies within the Heart of Texas Region to provide a comprehensive understanding of human trafficking and efforts to combat it within the region.
Confidentiality and information sharing policies will be observed in collection and sharing of data.