Policies and Protocols

Data Collection and Performance Measurement Protocol

To ensure a coordinated and data-driven response to human trafficking across the Fort Bend County Area, the ATC commits to a standardized process for data collection, reporting, and evaluation. This policy outlines the protocols for collecting, validating, and using data to monitor performance and fulfill grant obligations.

The ATC acknowledges that data collection and analysis are essential to understanding the prevalence of trafficking, assessing program effectiveness, and informing ongoing strategic planning. All participating agencies are required to collect and report data by their respective grant requirements and the procedures outlined below.
 

I. Data Collection Systems

1. Law Enforcement Data – PMT
   Law enforcement partners use the Performance Measurement Tool (PMT) to report data required by the Department of Justice (DOJ).
   
   The following indicators must be reported:
   • New and ongoing investigations
   • Potential victims identified, including trafficking type, age, and nationality
   • Arrests and charges (general and trafficking-specific)
   • Dispositions (e.g., convictions, plea agreements, or prosecutorial declines)
   • Community outreach and training events
      
2. Service Provider Data – TIMS
   Service provider partners use the Trafficking Information Management System (TIMS) to report data required by the Office for Victims of Crime (OVC).
   
   The following indicators must be reported:
   • New potential victims identified, categorized by trafficking type, age, and nationality
   • Victims served from previous reporting periods
   • Services delivered and referrals made
   • Collaborative efforts and outreach/training events conducted
      

II. Interagency Data Sharing Protocols

To ensure consistency across systems and stakeholders, the following procedures are required:

1. The FBCDAO shall provide the Task Force Director with demographic information documented in offense reports.
2. The Task Force Director will input data into an internal spreadsheet. This data will be verified against the FBCDAO Records Management System and submitted quarterly through PMT.
3. UAHT will refer potential victims who consent to law enforcement involvement to the FBCDAO for further action and investigation.
4. Victims who do not consent to follow-up will still be tracked for internal reporting.
5. The FBCDAO and UAHT will conduct quarterly data reconciliation meetings to ensure consistency in biannual progress reporting.
    

III. Responsibilities and Oversight

• The designated program supervisors for each DOJ/OVC grantee agency are responsible for:
  • Ensuring timely and accurate entry of data into PMT and TIMS
  • Coordinating quarterly exports of data for external evaluation
  • Reviewing findings and reporting outcomes to ATC members and respective grantors
     
• The appointed evaluator will:
  • Compile and analyze submitted data on a quarterly basis
  • Prepare summary findings for review and use in strategic decision-making
  • Provide all required reports to the DOJ/OVC in accordance with grant compliance guidelines
     

IV. Reporting Schedule

• Quarterly:
  Data entry and internal validation across agencies; reconciliation meetings held between FBCDAO and UAHT POCs; evaluator compiles data and prepares summary findings.
   
• Biannually:
  Progress reports submitted to DOJ/OVC reflecting PMT and TIMS data.
   

Confidentiality

In alignment with best practices for trauma-informed care and to promote the safety, dignity, and trust of individuals impacted by human trafficking, all members of the ATC are required to uphold strict standards of confidentiality. This policy establishes the framework for responsible communication, data protection, and lawful information-sharing between ATC partner agencies involved in trafficking identification, intervention, and recovery efforts.
 

Core Confidentiality Principles

1. Right to Privacy and Informed Consent
   • All potential victims shall be informed of their right to confidentiality and privacy at the outset of services.
   • Before making any referrals to external service providers or law enforcement, the victim must give informed consent. Informed consent must be voluntary, based on a complete understanding of the process, and documented according to each agency’s protocol.
   • Victims must also be informed of any limitations to confidentiality, including mandatory reporting laws and legal exceptions.
      
2. Agency Roles and Legal Boundaries
   • ATC members must explain the legal limits of confidentiality, including mandated reporting obligations as defined by federal and state law.
   • Each victim shall be informed of which personnel hold legally recognized privilege (e.g., attorneys, licensed psychologists, physicians, licensed social workers, advocates for survivors of sexual assault) and which do not (e.g., government-based victim advocates, law enforcement-based providers).
   • Depending on individual roles, agency members may have differing obligations regarding confidentiality and disclosure, and these distinctions must be clearly communicated to victims.
      
3. Interagency Information Sharing
   • Information regarding investigations and prosecutions will be shared with the task force on a need-to-know basis only to maintain the integrity of those cases.
   • Information shared between agencies must comply with all applicable laws and be coordinated to avoid duplicity and maintain accuracy.
   • UAHT’s Service Navigator will track victim services across partners, and agencies are encouraged to formalize secure information-sharing protocols through Memoranda of Understanding (MOUs).
   • A unique identifier or pseudonym will be used in shared records to protect the identity of victims when communicating across agencies.
   • Non-law enforcement members should collect minimal demographic and service-related data and reinforce the victim’s right to confidentiality throughout service delivery.
   • Task force performance and reporting data, as required by the funders, will be shared with the task force on a quarterly basis.
      
4. Law Enforcement Information Use
   • Law enforcement agencies may share relevant investigative information with other law enforcement bodies to further criminal investigations and prosecutions. This may include contact information, interview notes, and victim statements. The use of this information is restricted to appropriate investigative purposes and must be coordinated to ensure the preservation of victim safety and privacy.
      
5. Written Releases and Documentation
   • All disclosures and releases of information must be documented by each agency’s protocols.
   • Written consent is required for the release of victim information to other agencies, unless otherwise exempt under the law. For minors, consent must be obtained from a legal guardian.
   • Confidentiality acknowledgments and information-sharing agreements must be signed when appropriate and revisited regularly to ensure compliance with evolving policies.
      

ATC Safeguards and Responsibilities

To maintain a unified, trauma-informed, and victim-centered approach, all ATC collaborative partners agree to:

• Review and identify areas for strengthening confidentiality protections.
• Evaluate and enhance the flow of sensitive information between partner agencies.
• Recognize each partner’s unique role and confidentiality obligations.
• Uphold the ATC’s duty to protect confidential victim information.
• Adhere to federal and state laws regarding the release of information.
• Coordinate communication efforts across agencies to ensure accuracy, continuity, and victim protection.

Establishing and maintaining trust with survivors is foundational to the success of intervention and support efforts. Victims of trafficking may be reluctant to share details of their experiences due to fear, stigma, or prior harm caused by institutions. A consistent, transparent approach to confidentiality increases the likelihood of meaningful engagement in services, safety planning, and participation in the criminal justice process. Through this policy, ATC ensures that all partners approach confidentiality with the same rigor and survivor-centered focus, reinforcing our collective commitment to justice, dignity, and healing.
 

Information Sharing Protocol

The ATC Leadership Team (Task Force Director, Fort Bend County District Attorney’s Office, and United Against Human Trafficking), along with the Steering Committee designed this protocol that outlines expectations, boundaries, and procedures for information sharing among members of the ATC in support of coordinated investigations, victim services, outreach, and training efforts.  This protocol outlines the procedures for information sharing regarding ATC referrals received.  The protocol will be reviewed annually by the Steering Committee, with revisions completed by the Task Force Director.

All active members of the ATC, including any individual or agency participating in coordinated response, planning, service delivery, or training, will follow the guidelines of the information sharing protocol.
 

Requirements for Information Sharing

Members of the Anti-Trafficking Collective (ATC) will participate in discussions and information sharing related to ATC referrals. Shared information may include investigative details, case status, and the service needs of identified victims. This collaborative exchange is essential to support coordinated victim identification, individualized service delivery, and effective case investigation and prosecution. Each member’s level of participation will be based on their specific role in the case.

It is understood that all ATC members will operate within the mandates, policies, and procedures of their respective agencies. This agreement does not override or alter any applicable statutes, rules, or regulations governing participating organizations. In the event of any conflict between this agreement and an existing statute, rule, or regulation, the latter shall govern.

Information sharing must comply with federal and state laws, including VOCA, HIPAA, VAWA, FERPA, 42 CFR Part 2, and local statutes. Informed consent is a legal requirement under multiple federal laws (e.g., VOCA, HIPAA, VAWA). This protocol recognizes that legal and ethical obligations to protect survivor confidentiality outweigh informal task force requests.
 

Information to be Shared

ATC members will adhere to confidentiality best practices according to their discipline. ATC VSPs must obtain verbal or written authorization from a victim to share any information with another party involved in the task force. The verbal authorization should then be followed by a written Release of Information (ROI) within a reasonable timeframe, not exceeding two weeks.

All partners are required to use their agency’s formal ROI process when requesting victim-specific information. Providers must offer a clear explanation of the purpose, scope, and duration of the information-sharing request. Survivors must be told they have the right to decline without penalty. Verbal ROIs may be used in emergencies but must be documented. The duration of time for an ROI should not exceed one year and should be revisited yearly.

No personally identifying or trauma-related information about any victim/survivor may be shared across agencies without that person’s informed, time-limited, and voluntary consent, unless legally mandated or required for immediate safety concerns.
 

Consent must be:

• Informed: The person understands what info will be shared, with whom, why, and for how long
• Voluntary: Services or safety cannot be conditioned on saying yes
• Time-Limited: The consent expires after a defined time or event
• Documented: Ideally written; verbal allowed only in emergencies with follow-up documentation
   

ATC Law Enforcement members also need verbal or written consent to refer a victim to ATC community-based members. In some cases, if consent is not obtained from the victim and consultation with another ATC member is necessary, no identifying information should be shared or expected. An example of this situation is when a VSP is working with a victim, and the victim has law enforcement-specific questions.

This protocol confirms that ATC partners may have privileged communication with victims and are restricted in what they can share; therefore, case-specific discussions should only occur within the relevant Committee meetings with a task force focus. ATC members should understand what constitutes privileged information and what constitutes confidential information.

To better understand law enforcement’s role in privileged information and confidentiality, read the National Crime Victim Law Institute’s Law Enforcement-Based Victim Services in Texas:  Privacy, Privilege and Confidentiality [PDF].

Consistent with the Texas Code of Criminal Procedure, Article 58.052, law enforcement and VSPs are mandated reporters (Texas Family Code 261.101).
 

Process for Information Sharing

Information Sharing – Law Enforcement Committee

• Law enforcement Committee meetings shall be utilized to brief on any new, current, and ongoing investigations.
• Members in attendance will include law enforcement and prosecutors from local, state and federal agencies.
• These meetings are limited to law enforcement and prosecutors only to protect and maintain the confidentiality of open investigations, except for the Task Force Director.
   

Areas of focus discussed during meetings include, but are not limited to, the following:

• Current cases, investigative leads, and/or considerations Pending investigative actions
• Prosecution status/upcoming court proceedings Coordination with victim service providers
• Outreach and/or training opportunities
• Data Collection
• Progress on Committee goals/objectives
   

Information Sharing – VSP Committee

• These meetings are limited to victim service providers to ensure care and consideration for a victim’s rights and privacy, except for the Task Force Director.
• All ATC members participating in this Committee have agreed to and signed the ATC Memorandum of Understanding, which includes a confidentiality agreement.
   

Areas of focus discussed during meetings include, but are not limited to the following:

• New, current, and ongoing victim service needs or trends
• Appropriate coordination of services for each victim
• Upcoming victim needs
• Data Collection
• Outreach and/or training opportunities
• Progress on Committee goals/objectives
• VSP Wellness
   

Information Sharing – Case Staffing

• Law enforcement and VSP partners will meet to conduct a case-specific review as needed.
• Law enforcement may share investigative updates internally when appropriate but cannot expect survivor disclosures from VSPs. VSPs may only share client information with informed, written consent. Both parties must respect professional boundaries and clearly define their roles.
   

Case-specific reviews may include the following elements:

• Anticipated victim needs
• Coordination with law enforcement regarding victim services
• Evaluation of collaboration
   

Violations

Violations of consent and confidentiality will be taken seriously and may lead to formal action by the Leadership Team. Partners who pressure others to share survivor information without consent will be educated on legal and ethical boundaries. If this protocol is not followed, the matter will be handled by the ATC's grievance policy. Repeated or serious violations may be escalated to the ATC Leadership Team for review and resolution.
 

Media Policy

Since information released by any other agency could inadvertently compromise parts of the department's investigation and violate the confidentiality and privacy of victims of human trafficking, the lead law enforcement agency will also coordinate responses to media requests for any case or potential case-specific information. The dissemination of criminal justice information or case-related materials will follow all applicable state and federal laws regarding release. Law enforcement may withhold information that would otherwise be public when necessary to prevent compromising an ongoing investigation, especially concerning child victims. To the extent possible, sharing of information will be coordinated with all involved parties to ensure continuity.

Other media requests related to the ATC, including its functions, partners, activities, events, and training, should be directed to the Task Force Director.
 

Language Access

• UAHT provides trained interpreters for hearing-impaired, Spanish-, and Mandarin-speaking victims.
• If additional language support is needed, service providers will leverage OVC-funded language hotlines.
• ATC Leadership will address the translation needs of law enforcement.
   

Decision-Making Policy

This policy outlines the decision-making structure for the ATC to ensure clarity, transparency, and collaboration in all aspects of the initiative.
 

Group-Led Structure:

The Fort Bend Anti-Trafficking Collective operates as a group-led organization. Decision-making authority is shared across its collaborative members, with a focus on inclusive participation and survivor-centered practices.
 

Committees:

FB ATC Committees are established to carry out targeted areas of planning, coordination, and implementation. Each Committee is led by a designated member of the Steering Committee, who is responsible for facilitating meetings, ensuring progress toward goals, and reporting outcomes back to the full Steering Committee.
 

Voting and Consensus in Committees:

• Decisions made within Committees are determined by a majority vote of the members present.
• All members of the Committee have an equal voice in discussions and votes.
• Documentation of decisions will be maintained for transparency and accountability.
   

Conflict Resolution and Final Authority:

If a Committee encounters a disagreement or is unable to reach a majority decision, the issue will be elevated to the full Steering Committee for resolution.

• The Steering Committee serves as the final decision-making body for the FB ATC.
• Decisions by the Steering Committee are binding and will guide the implementation of all ATC activities.