Information for hotel managers to help prevent or deal with child sexual exploitation
- It's your responsibility
- What does sexual exploitation consist of?
- 'County lines' and sexual exploitation
- What do Hotel Managers need to know?
- How to protect your business?
- What to do if you have concerns
- Safeguarding checklist
Stopping the criminal and sexual exploitation of children - it's your responsibility
Child sexual exploitation happens when anyone under the age of 18 is taken advantage of and is coerceed, manipulated or deceived into sexual activity.
This may incude:
(a) a person offering things the victim believes they need or want in direct exchange for sex
(b) a person arranging sexual activity between the victim and a third party in return for payment
In either of these cases the sexual act may at first appear consensual but it is important to look out for any signs of coercion.
Exploitation is not restricted to physical contact but can also include such things as the sharing of sexual videos or photographs.
Remember that child sexual exploitation is never the victim’s fault, even if there is some form of exchange. All children and young people under the age of 18 have a right to be safe and should be protected from harm.
It's our shared responsibility to look out for the warning signs and take action.
The exploitation of young people can take many forms and can:
• affect any child or young person (male or female) under the age of 18 years, including 16 and 17-year-olds who can legally consent to have sex;
• still be abuse even if the sexual activity appears consensual;
• include both contact (penetrative and non-penetrative acts) and non-contact sexual activity;
• take place in person or via technology, or a combination of both;
• involve force and/or enticement-based methods of compliance and may, or may not, be accompanied by violence or threats of violence;
• occur without the child or young person’s immediate knowledge (through others copying videos or images they have created and posting on social media, for example);
• be perpetrated by individuals or groups, males or females, and children or adults. The abuse can be a one-off occurrence or a series of incidents over time, and range from opportunistic to complex organised abuse
It is typified by some form of power imbalance in favour of those perpetrating the abuse. Whilst age may be the most obvious, this power imbalance can also be due to a range of other factors including gender, sexual identity, cognitive ability, physical strength, status, and access to economic or other resources.
County lines is the police term for urban gangs supplying drugs to suburban areas and market and coastal towns using dedicated mobile phone lines or “deal lines”.
It involves child criminal exploitation (CCE) as gangs use children and vulnerable people to move drugs and money.
Whilst age may be the most obvious power imbalance there can be a range of other factors involved including gender, cognitive ability, physical strength, status, and access to economic or other resources.
One of the key factors found in most cases of county lines exploitation is the presence of some form of exchange (e.g. carrying drugs in return for something).
Where it is the victim who is offered, promised or given something they need or want, the exchange can include both tangible (such as money, drugs or clothes) and intangible rewards (such as status, protection or perceived friendship or affection).
It is important to remember the unequal power dynamic within which this exchange occurs and to remember that the receipt of something by a young person or vulnerable adult does not make them any less of a victim.
It is also important to note that the prevention of something negative can also fulfil the requirement for exchange, for example a young person who engages in county lines activity to stop someone carrying out a threat to harm his/her family.
Hotels and Bed & Breakfasts are often used as places to exploit and abuse victims.
There are a number of criminal offences associated with child exploitation which could have damaging consequences for a hospitality business, and managers should do everything possible to ensure they do not face prosecution, have action being taken against their premises licence or suffer the reputational or financial damage that would be come with being associated with such behaviour in their property.
It is the responsibility of premises license holders and their managers to make sure that suitable control measures are in place at licensed venues for the protection of children from harm.
This is a legal requirement under the Licensing Act 2003 and there are serious implications if you do not have safeguards in place or fail to act if sexual exploitation of children occurs, or is believed to have occurred, on your premises.
Under Section 116 of the Anti-Social Behaviour, Crime and Policing Act 2014 the Police have powers to serve a notice on a hotel owner, operator or manager requiring guest information in connection with child exploitation.
This notice can be served when an officer reasonably believes a hotel premises has been or will be used for the purposes of:-
(a) Child sexual exploitation, or
(b) Conduct that is preparatory to, or otherwise connected with, child sexual exploitation.
You should always as a matter of course accurately record the details of anyone staying within your establishment (name, address, telephone number and date of birth) and check and record a copy of photo identification of guests. If you do not provide accurate records to the Police upon their request you may be prosecuted by the courts and issued with a fine not exceeding £2,500.
In addition to this you should be aware of the following possible signs that could point to a problem:
• Guests accessing an unusual amount of pornography (TV or computer)
• Guests who appear secretive about who they are with and/or activities in their room
• A young person who appears withdrawn, afraid or frightened or under the control or instruction of another person
• High traffic to a guest room
• Repeat visitors to the hotel at irregular hours/during the night
• Young people checking in with an adult or group of adults
• Young people meeting others in public areas/external areas of the hotel
• Young people clearly under the influence of alcohol or drugs
• Lots of male visitors to a room
• Noise complaints
• Evidence of alcohol, drug or substance misuse and/or condom wrappers
• Signs of a ‘party’ being held in the room
• Guests who appear secretive about activities in their room, who don’t want rooms cleaned and/or use the ‘do not disturb’ sign
• Multiple visitors, who are not guests at the hotel, visiting a room
• Signs of sexual activity having taken place in a room where young people have stayed or visited
• Guests who do not have any luggage staying in rooms
• Young people staying in/or visiting rooms on their own
If you think the young person is at immediate risk of harm, call 999 to report your concern.
• Offer support to the young person:
• Ask if they are ok
• Don’t serve them any alcohol or allow anyone to buy them another drink. Check that they are not receiving unwanted attention
• Check whether they know who they are with and if they feel safe being/leaving with them
• Offer to call a licensed taxi for them
• Offer to call a parent/carer
• Ask CCTV to monitor them
Other actions to consider
• Download and secure any CCTV
• Identify methods of payments i.e. cash/credit/debit cards
• Secure any information regarding key card usage for the rooms
• Secure any information regarding items left behind
• Secure the hotel room(s) until police arrive
• Report any relevant registration number plates
Remember you can also give and report information online via Crimestoppershttps:crimestoppers-uk.org/give-information/give-information-online/
Follow these steps to ensure your safeguarding duties are met:-
- Nominate a safeguarding representative
- Keep refusal records
- Maintain an incident log book
- Encourage staff to make eye contact and engage in conversation to inquire about the reason for guests’ visit or stay
- Distribute and display exploitation literature and materials in staff areas
- Undertake age verification checks
- Only accept photo ID
- Undertake patrols ( walk hallways and perimeter)
- Install CCTV monitoring and retain CCTV recordings
- Require visitors to use the main entrance to the premises
- Restrict unregistered persons in guest rooms between 11pm and 7am
- Include child exploitation in your business risk assessment
- Share information and intelligence appropriately
- Report suspicious activity to local police