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New York Law Requires Human Trafficking Informational Cards in Hotels, Considering Employee Training

12/01/18

Author: ADP Admin/Tuesday, December 4, 2018/Categories: New York

Overview: All hotels in New York with at least five rooms will be required to post human trafficking “informational cards” throughout each hotel’s premises.

Effective Date: October 14, 2018

Details:
The new statute (Ch. 190 of 2018) affords a hotel three options in selecting the “informational card” it will use:
  1. Create its own “informational card”;
  2. Use a card created by the New York State Office of Temporary and Disability Assistance (OTDA) in conjunction with the New York State Interagency Task Force on Human Trafficking; or
  3. Use a card created by the United States Department of Homeland Security (DHS).
Content of Informational Cards
All informational cards, regardless of which entity creates it, must contain the National Human Trafficking Hotline number (1-888-373-7888). If a hotel decides to create its own informational card, the card must contain only information regarding services for human trafficking victims.

However, the law does not require the informational card to contain any other specific information in addition to the National Human Trafficking Hotline number. Further, it does not specify any size requirements for such cards, provide guidelines for their appearance, or require they go through a state approval process.

The law also does not specifically require cards to be affixed in any particular location; therefore, a hotel may choose to stack informational cards in the required locations (discussed below).

Should a hotel not wish to create its own informational card, it may use a card created by New York State or one created by DHS. While New York has yet to release its informational card, it will part of the OTDA’s Refugee Services (RS) webpage when available. DHS has created a series of informational cards containing the National Human Trafficking Hotline number through its “Blue Campaign.” An example of a card can be found  here.

Where Cards Must Be Placed
Once a hotel has selected the informational card it will use, the cards must be placed throughout the hotel (1) in plain view and in a conspicuous location in public rest rooms, (2) in guest rooms, and (3) near the public entrance to the hotel. If a hotel does not want to place a card near the public entrance, it may place the card in another conspicuous location in clear view of the public and its employees where similar information is customarily displayed.

Training Bill
In addition to the new statute, a pending proposal in the legislature would require all hotels in New York with more than five rooms to have all employees likely to interact with guests to undergo a state-created or approved human trafficking recognition training program.

While other states have similar requirements, some believe that the provisions in the New York proposal (including training employees in relief and recovery options for survivors and social and legal services available for victims) would be an onerous, unfunded mandate for New York hotels. This proposal passed the New York State Assembly in 2018, but it did not move in the Senate, and will not be considered again until 2019.

Action Required: Employers in the hotel industry in New York should review the new requirements carefully and ensure compliance with the law. As always, please be sure to contact your HR Business Partner for guidance and if you have any questions.

*Produced in cooperation with Jackson Lewis P.C.

This content provides practical information concerning the subject matter covered and is provided with the understanding that ADP is not rendering legal advice.

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Tags: Compliance CornerState Update12/01/18

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