In fact, the amount of people that their policies have the potential to harm is vastly greater than the amount of sex trafficking victims that could potentially be assisted. As this topic has surged into greater public consciousness, much of the online discourse is focusing on how the training fails to train workers to properly differentiate between victim of sex trafficking and consensual sex workers, thus putting sex workers in danger. However, some observers, such as Phoenix Calida, PhD, have pointed out how this policy harms many others - from domestic violence survivors to homeless queer people to mentally ill people. Essentially, these policies give hotel workers the power to misguidedly or even maliciously assign a label of “potential sex trafficking victim” to a guest based on a wide range of dangerously vague indicators, which in turn justifies the worker under these policies to force marginalized people into unwanted and potentially violent or fatal interactions with police or ICE.
In this post, I will dissect the 50 indicators that I pulled up that are used in industry-standard anti-sex trafficking policies, and then apply them to several groups of people to demonstrate how easily a hotel worker can place this label on a disenfranchised person. For a shorter read, skip to the paragraph beginning with the symbol (§) to read my analysis of how dangerous these policies are due to forced police interactions and a lack of accountability.
The following is a list of examples of what anti-human trafficking training asks hotel workers to look out for while on the clock. While they are based on multiple sources (this article specifically referring to Marriott’s ECPAT-USA-based training [https://www.teenvogue.com/story/how-hotel-employees-are-trained-to-spot-human-trafficking], and this Blue Campaign reference PDF for hotel employees [https://www.dhs.gov/sites/default/files/publications/blue-campaign/toolkits/hospitality-toolkit-eng.pdf]), they are both based on industry-standard training.
“Excessive requests for towels and linens”,
“random people entering and exiting a hotel room”,
“requests for an isolated room”,
“excessive control over another person, such as not letting them speak or move freely”,
“clothing that’s inappropriate to the weather”,
“Individuals show[ing] signs of physical abuse, restraint, and/or confinement”,
“Individuals show[ing] signs of fear, anxiety, tension, submission, and/or nervousness”,
“Individuals exhibit[ing] evidence of verbal threats, emotional abuse, and/or being treated in a demeaning way”,
“Individuals lack[ing] freedom of movement or are constantly being monitored”,
“Individuals show[ing] signs of malnourishment, poor hygiene, fatigue, sleep deprivation, untreated illness, injuries, and/or unusual behaviour”,
“Individuals avoid[ing] eye contact and interaction with others”,
“Individuals hav[ing] no control over or possession of money or ID”,
“Individuals dress[ing] inappropriately for their age or hav[ing] lower quality clothing compared to others in their party”,
“Individuals hav[ing] few or no personal items—such as no luggage or other bags”,
“Individuals appear[ing] to be with a significantly older “boyfriend” or in the company of older males”,
“A group of girls appear[ing] to be traveling with an older female or male”,
“”Do Not Disturb” sign being used constantly”,
“Request[ing] room or housekeeping services (additional towels, new linens, etc.), but [denying] hotel/motel staff entry into room”,
“Refus[ing] cleaning services for multiple days”,
“Excessive amounts of cash in a room”,
“Smell of bodily fluids and musk”,
“Presence of multiple computers, cell phones, pagers, credit card swipes, or other technology”,
“The same person reserving multiple rooms”,
“Individuals leaving room infrequently, not at all, or at odd hours”,
“Children’s items or clothing are present but no child registered with the room”,
“Individuals loitering in hallways or appearing to monitor the area.
“Excessive amounts of alcohol or illegal drugs in rooms”,
“Evidence of pornography”,
“Minors left alone in room for long periods of time”,
“Excessive number of people staying in a room”,
“Extended stay with few or no personal possessions”,
“Provocative clothing and shoes”,
“Constant flow of men into a room at all hours”,
“Excessive amounts of sex paraphernalia in rooms (condoms, lubricant, lotion, etc.)”,
“Rooms stocked with merchandise, luggage, mail packages, and purses/wallets with different names”,
“Patrons checking into room appear[ing] distressed or injured”,
“The same person reserving multiple rooms”,
“Few or no personal items when checking in”,
“Room paid for with cash or pre-loaded credit card”,
“Excessive use of hotel computers for adult oriented or sexually explicit websites”,
“Patrons not forthcoming about full names, home address or vehicle information when registering”,
“Minor taking on adult roles or behaving older than actual age (paying bills, requesting services)”,
“Patron appear[ing] with a minor that he or she did not come with originally”,
“Rentals of pornography when children are staying in the room”,
“Individuals dropped off at the hotel or visit repeatedly over a period of time”,
“Room is rented hourly, less than a day, or for long- term stay that does not appear normal”,
“Room rented has fewer beds than patrons”,
“Individuals enter/exit through the side or rear entrances, instead of the lobby”,
“Car in parking lot regularly parked backward, so the license plate is not visible”,
“A group of males or females with identical tattoos in similar locations. This may indicate “branding” by a trafficker.”
Both sources of these indicators stress that “Each indicator alone may not necessarily mean a person is being trafficked”, so I will not be including a group of people that may be impacted by these policies in this post unless they can be “spotted” possessing more than one indicator.
Phoenix Calida, PhD (@uppittynegress on twitter) points out several groups that can be negatively impacted by being falsely identified as victims of human trafficking. These groups include victims of abusive relationships who are escaping their partner, victims of abusive relationships who are staying in a hotel with their partner, homeless LGBTQ folks, non-American/Western folks (particularly brown/black folks), non-neurotypical folks and people with mental illnesses. I will break this observation down by assessing how the above list of indicators can be applied to each of these groups.
Victims of abusive relationships who are escaping their partners and who are staying in hotels usually leave their homes in a hurry, so they usually don’t have much luggage or personal items (15, 39), and what they are wearing may have been chosen in a hurry so it may not be “weather-appropriate” (5). Another point about clothing is that depending on the depth of abuse, their clothing may have been picked for them and might be “provocative” (32) or not be “age appropriate” or “high quality” (13). In order to avoid being tracked by their partner they may pay in cash (39) and be reluctant about giving their full name, home address or vehicle information (41). If they have recently escaped, there is a decent probability that they are currently or have recently experienced emotional crisis and upheaval, so they may “show signs of fear, anxiety, tension, and/or nervousness” (7), fatigue (10), or distress (36) and they may avoid interaction or eye contact (11). If they are leaving a physically abusive relationship, they may have visible injuries (6, 10, 36). Finally, if the victim suspects that their partner knows where they are seeking shelter and could be monitoring the lobby, they may use the side or rear entrance (48). This brings a total of twelve potential identifiers to our person attempting to escape an abusive relationship.
One might argue that this is a hidden positive, because identifying a victim of an abusive relationship could help the victim access help. Let us briefly unpack this. We can assume that if a hotel employee were to find out that a victim is escaping an abusive relationship, they would likely contact the police, because they are not likely to be equipped with the resources and tools to help the victim themselves. According to healthtalk.org, "The majority of women who had contact with the police felt that police officers’ understanding of domestic violence and abuse was poor, limited to an emphasis on physical abuse and a need for ‘hard evidence’, which was usually difficult to establish". It is also relevant to take into account that between 22 and 41 percent of police officers are perpetuators of domestic violence themselves (Neidig et al., 1992). Another factor is that involving the justice system would likely alert the abuser to the victim’s location. Given these reasons, it would not be helpful for hotel employees to identify potential victims of abusive relationships. It would be more appropriate to allow the victim to have their own choice to contact resources rather than involve a justice system whose policies may work against them.
Calida also brings up that victims of abusive relationships who are staying with their abusive partners are also put into potential danger by this, because if the victim is identified by the metrics used above and it is found that she has a partner, there is no evidence to suggest that the ‘investigation’ wouldn’t simply stop there. After establishing that the victim does, in fact, have a partner, there is less reason to suggest that she is a victim of trafficking. Combining that fact with the victim’s and abuser’s vehement insistence that they are not engaging in sex trafficking, and it would take an exceptionally persistent hotel manager to involve the police beyond that point. Why is this a danger to the victim? because as Calida puts it, “Now all you’ve done is accuse & piss off a dangerous person who’s now alone in a hotel room with their Victim”.
People from non-American and non-Western cultures are at risk from these policies as well. People from Eastern cultures where it is culturally inappropriate to look people in the eye will be targeted due to indicator 11. Women whose religions or cultures specify that they not speak with men that they aren't in a relationship will be targeted as possible victims of sex trafficking thanks to indicators 4, 7, 9, and 11. Combined with the fact that in the United States, there is a possibility (if not a straightforward interest of politically-right-leaning individuals) of Immigrations and Customs Enforcement becoming involved, there is arguably more danger for black and brown people regardless of their country of origin.
I would like to emphasize that women with head coverings would be particularly targeted by these policies, not only due to their falling under specific identifiers, but due more broadly to the cultural beliefs of Western employees. Because of our beliefs about women with head coverings (i.e., the belief that women who wear head coverings do so because they are forced to rather than by choice), hotel employees may ignore the complex reasons they may have for wearing a head covering and label them a victim sooner than they would label others. This misguided stereotyping may put these women at even greater risk in this context, outweighing the fact that they only match four indicators on the above list.
Non-neurotypical (neuroatypical) people and folks with mental illness can be unfairly targeted by these policies as well. Calida asks, “Are you able to communicate “normally”? Do you seem “off” or disoriented sometimes”? If not, indicators 7 and 36 may be used against you and cause you to be reported as a potential sex trafficking victim. Additionally, 25 (children’s items being present with no child registered) can be tallied as well - some anxious and/or autistic people use stim toys as a means of self-care to avoid sensory overload, and these can easily be mistaken for children’s toys to the untrained eye. If a socially anxious guest requests an isolated room (indicator 3), then that too may count as a strike against them.
When considering neuroatypical/mentally ill people in the context of potential forced police interactions, it is important to keep in mind how police routinely mistreat and enact violence upon people with disabilities, a group which for the purposes of this analysis includes neuroatypical people and folks with mental illness. The stories of people with disabilities killed by police are shocking. To provide a couple of examples, here is a story where an unarmed schizophrenic person in a shower in their own home thought that police were hallucinations and was murdered soon after, and another about a person with Bipolar disorder who was shot by a police officer, again in his own home. That second article points out that “in 2015 and 2016 combined, nearly 500 people with mental illness were fatally shot by the police”, and that “for each of those years, one in four police shootings was of a person with mental illness” (The Washington Post, 2015, as cited by Roth, 2018). Given the amount of evidence that police, at least in the United States, lack basic training on how to non-violently assist people with mental illnesses, we can assume that there is a great risk of harm to disabled people whom hotel workers call the police on.
Homeless queer folks are yet another group that Calida brought up that could be affected by these policies. Imagine, for a moment, a young queer person who has just been ousted by their family. The indicators can be similar to those of a fleeing domestic abuse victim: If they left in a hurry or are chronically homeless, they won’t have much luggage or personal items (15, 39), and what they are wearing may have been chosen in a hurry so it may not be “weather-appropriate” (5), or if they’re homeless they may not have much choice over their clothing. I could easily see queer folk’s clothing being deemed “age inappropriate” (or, let’s say it, employees might thing it’s not appropriate to their gender) (13). If they are homeless or not wanting to be tracked by family they will likely pay in cash (39) and be reluctant about giving their full name, home address or vehicle information if any (41). If they have recently been kicked out, there is a high probability that they are currently or have recently experienced emotional crisis and upheaval, so they may “show signs of fear, anxiety, tension, and/or nervousness” (7), fatigue (10), or distress (36) and they may avoid interaction or eye contact (11). And hey, if you have condoms or any other “sex paraphernalia”, that’s an additional strike (34). That is ten indicators that may be counted as strikes against an individual - ten indicators that a hotel employee may use to justify calling the police on you.
(§)The different indicators that hotel workers are trained to look for when spotting potential sex trafficking victims as well as the different groups they can be applied to have been established. So, why do they matter? What’s the problem if a hotel worker mistakenly thinks someone is a victim of sex trafficking? What, exactly, can the harm be? Well, that’s where bigger issues come into play, such as cultural and individual bias, police violence, and accountability.
The most important point that I would like to drive home in this post, and the overarching reason that I wrote it, is that the biggest threat to the safety of marginalized groups is the hotel worker’s potential bias against them. These policies essentially provide another avenue through which malicious hotel workers may enact their bigotry by forcing people they are biased against into uncomfortable, tense, or violent situations. The most unsettling part of seeing these policies enacted is that we are not seeing additional training being mandated to counter hotel workers’ individual and culturally internalized bias. This post would not need to exist if anti-sex trafficking training was taught in tandem with sex work destigmatization training, cultural sensitivity training, and queer positivity training. Myself and many others wouldn’t be so scared for the lives of vulnerable hotel guests if there were thought, care, and sensibility given to how these policies may directly result in instances of police violence and brutality against marginalized people.
As I stated at the beginning of this post, a worker can, after finding a policy-based justification for labelling someone as a potential sex trafficking victim, force that individual into an unwanted and potentially violent or deadly interaction with police. It is, in fact, encouraged for the worker to contact police rather than to help the potential victim on their own: “Do not at any time attempt to confront a suspected trafficker directly or alert a victim to your suspicions”. “Call 9-1-1 for emergency situations”. “[Contact ICE] to report suspicious criminal activity to federal law enforcement”. These quotes are all from the same Blue Campaign document that I sourced the majority of the above indicators from. Workers are directed to not involve themselves, but to immediately involve law enforcement, potentially including hotel management and security as a middleman. This is a fair policy only in that it recognizes that hotel workers likely do not possess adequate training to help a sex trafficking victim. However, it remains a poorly-thought-out policy because it assumes that police or ICE are adequately trained to help a sex trafficking victim. That assumption necessitates evidence, particularly given the current climate where police are increasingly revealed to turn towards aggression, assault, and murder before considering non-violent de-escalation techniques.
The potential occurrence of employee bias impacting a marginalized or vulnerable hotel guest are further increased by the apparent lack of accountability for employees drawing attention to potential sex trafficking victims. While these are, as pointed out above, a huge amount of indicators available for a hotel employee to look out for, and a clearly stated mandate for them to contact police or ICE should they suspect someone being trafficked, I have found no evidence of a section outlining the consequences for an employee falsely claiming that a guest might be a victim of sex trafficking. The lack of accountability for employees is understandable because the document was written without the assumption that employees may falsely accuse a guest of being a sex trafficking victim, whether out of malice or sheer ignorance. However, given what has been pointed out by myself, Dr. Phoenix Calida, and others about how these policies have the potential of being used to put guests in danger via police/ICE interventions, the fact that these policies have no failsafe in case of employee malice is alarming.
In this post, I have drawn attention to the kinds of indicators that hotel employees are trained to look for when attempting to spot sex trafficking victims and how these policies may be used by a hotel employee to manufacture an uncomfortable and potentially deadly interaction between marginalized, vulnerable people and police or ICE. When one is aware of the appallingly low standards that police in North America are held to in terms of lack of training, accountability, and empathy, it becomes clear that any tense situation where police become involved can become a death sentence. Hotel workers who harbor hatred of minorities now possess an additional tool in their toolbelt to force minorities into those potentially tense or deadly interactions with no repercussions.
So what should be done about it?
When I write critical analysis posts, I personally want to focus not only on the severity of the issue, but the potential of creating solutions. I have given some thought to this issue and wish to present my solutions to any employees or managers of a hotel where these types of policies are being implemented.
Remove the damn policy.
I should hope that this is straightforward, but it is clear that these policies harm more people than they help. The sheer number of people that may be negatively affected by these policies outstrips even what I have written about in this lengthy post - I haven’t even touched on how sex workers are harmed by these policies, because others have already written about it. One potential solution for hotel chains is to remove the policy entirely. This may not be viable, however - can you imagine the optics of a hotel chain removing a policy intended to stop sex trafficking? The general public would fail to grasp the importance of such a move, and would likely revolt against the chain. I don’t have any particular love for hotels, but I do want to be realistic with my solutions, which is why I would more likely propose…
Train your workers even more.
As I stated earlier in this post, “This post would not need to exist if anti-sex trafficking training was taught in tandem with sex work destigmatization training, cultural sensitivity training, and queer positivity training”. The harmful impact of these policies would practically evaporate if hotel workers were, in addition to being trained on how to spot sex trafficking victims, trained on how to treat black, Indigenous, disabled, mentally ill, queer, trans, and sex worker communities with respect and dignity. This may sound like a tall order, and I won’t deny that it will take resources to enact. However, the costs of training will be worth it. Not only will regional managers be able to rest easy knowing that their employees will be able to welcome guests regardless of their race, gender, sexuality, ability, or profession, but the potential costs of litigation resulting from discrimination suits will fall sharply, and revenues will be boosted because guests will feel confident that they will be able to stay at a hotel knowing that they will be treated well by staff.
If these policies are to be continued and hotel employees are trained on how to spot sex trafficking victims, it must be taught in tandem with training that increases an employee’s cultural competency and respect for guests whose lives are different than their own. This may be responding to a light swat with a heavy right hook, but why not nip this issue in the bud while also assuring that guests are treated fairly? It is the only ethically responsible way to respond to important criticisms like this en lieu of stripping these policies completely. Be empathic! Treat your guests well! And please don’t neglect them by training your workers to call police or ICE on them just because they think they have a small chance of being a sex trafficking victim.