Administrative Procedure 360: Anti-Sex Trafficking

Legal References

Criminal Code of Canada; Education Act: Section 265 Part XIII Behaviour, Discipline and Safety; Policy/Program Memorandum 166, Keeping Students Safe: Policy Framework for School Board Anti-Sex Trafficking Protocols; Municipal Freedom of Information and Protection of Privacy Act; Ontario Human Rights Code; Accessibility for Ontarians with Disabilities Act; Child, Youth and Family Services Act; Policy/Program Memorandum 9: Duty to Report Children in Need of Protection; Ontario’s Anti-Human Trafficking Strategy 2020-2025

Related References

1. Purpose
Welcoming and engaging school environments lead to positive student experiences, especially when families and communities are intentionally involved in the students’ learning. Safe Schools, both physically and psychologically, are a critical element to successfully nurturing positive student experiences.

Due to almost daily contact with students, teachers and other education staff are well placed to educate on prevention and promote healthy relationships, notice troubling changes in behaviour, and connect with students as caring adults. By training staff to recognize the signs of sex trafficking, they will be better equipped to identify the cues and safely intervene if they suspect a student is being trafficked or involved in trafficking. Education can also serve as a key factor in helping survivors of trafficking heal and rebuild their lives, helping to prevent re-victimization and resetting students on a healing trajectory towards positive outcomes.

2. Definitions
Sex trafficking is a form of sexual exploitation and is a crime under the Criminal Code of Canada. It can include recruiting, harbouring, transporting, obtaining or providing a person for the purpose of sex. It involves the use of force, physical or psychological coercion or deception. Most individuals who are trafficked for the purpose of sexual exploitation are women and girls, but all people may be targeted.

Indigenous and racialized individuals are especially vulnerable to experiencing sex trafficking. The intersections of colonization, intergenerational trauma, systemic discrimination and barriers to accessing service compound, which increases the vulnerability of being targeted by traffickers for Indigenous women and girls – of whom comprise a disproportionate number of trafficked persons for the purpose of sexual exploitation, in Canada.

3. Statement of Principles
A role for parents/guardians/caregivers
Parents, guardians and caregivers are key partners in the development, implementation and review of school board anti-sex trafficking protocols.

Foster student voices
Students are at the centre of this work and should be involved in efforts to develop actions against sex trafficking.

Build multi-sectoral relationships with community organizations
Ongoing consultation and engagement with community groups/agencies that support members of the school community are essential to supporting anti-sex trafficking approaches that are responsive to diverse students and the needs of local school communities.

The development of this protocol and who will continue to provide guidance and support and also educational materials include: Huron Domestic Assault Review Team (DART); Rural Response for Healthy Children, OPP, Stratford Police Services, Victim Services - Huron, Stop Violence Against Women (VAW) - Perth, Optimism Place and Emily Murphy Centre. We continue to establish partnerships with traditionally underrepresented communities to reflect culturally relevant resources including but not limited to Indigenous, black, students of colour, and LGBTQ2S+ students.

Interventions must be safe
Caring adults and students within schools can promote a sense of student belonging, increase protective factors, help to reduce risk factors associated with sex trafficking, and support early intervention through identification and appropriate responses, including connecting impacted persons to supportive services.

Build up school-based prevention
The development of the protocol complements existing prevention efforts in schools, including the teaching of consent, healthy relationships and healthy sexuality. It is important for school staff to understand the historical and social context of sex trafficking and implement prevention strategies that are responsive to the needs of students and members of the local school community.

Respect confidentiality, privacy and informed consent
The development of procedures respects confidentiality and ensures that the student fully understands how their information may be used or with whom it may be shared. It is key to develop referral relationships with community service organizations while adhering to applicable legal requirements, including those under the Municipal Freedom of Information and Protection of Privacy Act; the Ontario Human Rights Code; the Accessibility for Ontarians with Disabilities Act, 2005; the Education Act; and the Child, Youth and Family Services Act, 2017.

Promote equitable and culturally safe responses
Protocols should demonstrate a human rights-based, non-judgemental, culturally responsive, survivor-centered and trauma-informed approach to raising awareness, preventing, identifying and responding to sex trafficking.

4. Responsibilities

Director and Superintendent must ensure that:

4.1 Ensure that the protocol and related procedures and resources are publicly available and accessible on the school board website.

4.2 Develop a process to raise awareness among students, parents and caregivers about:

4.2.1 cyber-safety
4.2.2 the signs that a student is being targeted, lured, groomed, trafficked or is trafficking another student; how to get help safely (for example, through the school board, community providers and/or support hotline)
4.2.3 how they can report concerns to the school board (including anonymous reporting) and the school board's process for responding to concerns
4.2.4 approaches to overcome barriers to participation that Indigenous, Black, newcomer and other parents/guardians may face

4.3 Develop a process to help prevent recruitment of students for sex trafficking, including through curriculum-based learning about healthy relationships, consent, mental health and well-being, coping skills, personal safety and online safety, as well as through work with local community-based organizations and survivors.

4.4 Consider the use of available technology and tools to identify and deter potential situations involving students who could be at risk of sex trafficking and other online threats, while using school board-provided technology.

4.5 The school board protocol must establish procedures for Response that address the needs of, among others:

4.5.1 students with special education needs, mental health needs, social or emotional needs or language/cultural barriers, and international students
4.5.2 students who are in care, receiving care or in customary care arrangements
4.5.3 students who are being trafficked and who may be involved in the recruiting of other victims, including students who are returning to school after they have been involved in a trafficking situation
4.5.4 parents, including those who may live overseas and/or may not speak English or French
4.5.5 students 18 years or older or who are 16 or 17 years old and have withdrawn from parental control

4.6 Designate a contact person at the school board who is familiar with the school board anti-sex trafficking protocol and can support school board employees with response procedures.
4.7 Create response procedures that are trauma-informed and culturally responsive.

4.8 Training will be provided as part of the Board’s annual compliance training, early in the school year for school-based staff, including teachers and administrators. This training will also be provided for any staff member who works directly with students or who support anti-sex trafficking initiatives.

4.9 Completion of training will be tracked as part of the annual compliance training process. New employees who are required to engage in this training will complete it as part of the onboarding process.

4.10 Provide ongoing training for school board employees, including teachers, administrators, and other school staff.

4.11 Collect data, as required by the Ministry of Education, to monitor the effectiveness of training and whether the protocols respond to the needs of students.

4.12 Invite community partners to participate in the reporting process to determine how the protocols have helped children and youth in care.

4.13 Review the Protocol at minimum, every five years as part of the board’s regular policy review cycle.

5. Principals must:

5.1 Respond to concerns brought forward through the school website Reporting Tool

5.2 Promote awareness strategies. These may involve sending letters or emails, providing information in a student handbook, displaying posters, hosting information sessions, posting on the school/school board social media accounts, and/or posting information on the school board website. Ensure that staff supports, families and community resources are engaged to ensure a safety/re-entry plan is developed to meet the individual needs of the student.

5.3 Respond in situations where a student:

5.3.1 may be at risk of or is being sex-trafficked
5.3.2 may be targeting, luring, grooming or recruiting children and youth for the purpose of sex-trafficking
5.3.3 is returning to school after they have been trafficked or involved in trafficking others

5.4 Follow the AMDSB Anti-Sex Trafficking Response Protocol when responding to incidents described above.

5.5 Notify appropriate school/school board contacts and parents/guardians, as applicable.

5.6 Communicate and collaborate with community-based service providers, local police services and local Children's Aid Societies as applicable and/or required by law, in responding to situations of suspected or confirmed sex trafficking of students.

5.7 Monitor and follow-up on incidents reported (for example, check-ins with affected students).

5.8 Document and report suspected or reported sex trafficking situations and response procedures that were implemented.

6. Teachers and Other Board Staff must:

6.1 School board employees must respond in situations where a student:

6.1.1 may be at risk of or is being sex-trafficked
6.1.2 may be targeting, luring, grooming or recruiting children and youth for the purpose of sex-trafficking
6.1.3 is returning to school after they have been trafficked or involved in trafficking others

6.2 School board employees must follow the AMDSB Anti-Sex Trafficking Response Protocol when responding to incidents described above.

6.3 Follow procedures regarding duty to report a child in need of protection under Section 125(1) of the Child, Youth and Family Services Act, 2017 and under Policy/Program Memorandum 9: Duty to Report Children in Need of Protection and AP346 Children in Need of Protection.

6.4 Refer all affected students (including those indirectly affected, as needed) to supports.

6.5 Respond to possible sex trafficking recruitment by a student within the school following the Board’s Anti-Sex Trafficking Protocol.

7. Students must:

7.1 Report any concerns of or involvement in sex trafficking to any staff member they trust. Anonymous complaints may be sent to the Reporting Tool available on each school’s website.

New June 2022