Contracts
Vendor Indemnification: You must amend Master Services Agreements (MSAs) with third-party staffing agencies (security, janitorial, temporary labor).
- Requirement: Insert specific indemnification clauses for violations of human trafficking laws.
- Requirement: Mandate that vendors certify they perform background checks and verify legal work status. If a vendor traffics workers into your facility, TDLR will investigate *your* license.
Hiring/Training
Inspection Protocol Training: Shift management training from "technical compliance" (sanitation/signage) to "behavioral observation."
- Manager Training: Train on-site managers to handle inspectors who will likely separate employees from management for interviews to detect coercion.
- Staff Preparation: Ensure staff are prepared to provide identification and answer questions regarding their employment terms without management present; obstruction can be grounds for penalties.
Reporting & Record-Keeping
Internal Investigation Privilege: Section 51.553 establishes confidentiality for information regarding trafficking victims.
- Data Handling: If you conduct an internal investigation regarding a potential trafficking issue and submit findings to TDLR, mark all documents as "Confidential under SB610/Sec 51.553" to prevent disclosure under Public Information Act requests.
- Identity Verification: Immediately audit all I-9s and personnel files. You must be able to produce valid identification for every person on the premises during a spot inspection.
Fees & Costs
Budget Impact: While the state anticipates no new licensing fees, allocate budget for legal counsel to review updated inspection rules once proposed. Insurance premiums for Employment Practices Liability (EPLI) may rise for high-risk sectors; verify your policy does not contain broad "criminal acts" exclusions that would void coverage during an investigation.
