Contact with Unsafe Persons Commentary

Essential StandardYour agency has policies in place to prevent or deter clients from having contact with unsafe persons — this may include (but not limited to) limiting access to cell phones, setting internet filters, developing safety plans with clients

Survivors are a diverse group of people, not just by race, gender, sexual orientation, etc, but also with their preferences, needs, and personalities. Just as with any group of people, they will naturally respond differently to different program structures. Therefore, until there is overwhelming evidence-based research supporting a specific level of restrictions for all survivors, we will not promote one philosophy, whether that be low-barrier or program-centered, over another. Rather, we hope to see all agencies provide their model with trauma-informed practices which recognize that there are survivors who feel comfortable with and in need of more structure, and there are survivors who are uncomfortable with those restrictions and need a more independent program.

This table specifies both required and recommended attributes that are evaluated during the accreditation process. Those attributes labeled as required must be present for accreditation. Attributes labeled as recommended could be reviewed, but are not necessarily required, during the accreditation process. Each requirement and recommendation is further explained in the sections below.


  • Be transparent about any/all policies that involve restrictions, including access for phones or computers or leaving the premises
  • For programs that incorporate restrictions, must show a transition to more independence as part of the programming, with clearly described and defined perimeters 


  • Utilize Motivational Interviewing to explore what each client is willing to do, with importance placed on client choice wherever possible
  • Provide assessment & education for clients on knowing who is safe/unsafe
  • For programs that incorporate restrictions, ask for feedback on the policies from residents

Trauma-Informed Care & Contact with Unsafe Persons Policy

While research on residential programs and restrictions is limited, there is a plethora of research on the importance of trauma-informed care. SAMHSA has identified six guiding principles to providing trauma-informed care: 1) Safety 2) Trustworthiness and Transparency 3) Peer Support 4) Collaboration and Mutuality 5) Empowerment, Voice and Choice 6) Cultural, Historical, and Gender Issues. Four of these core principles are particularly relevant to creating policies regarding client contact with unsafe persons:


Safety for clients should always consider both psychological and physical aspects, including safety within the space that clients live and with those they interact with. In Trauma and Recovery, Judith Herman identifies that the first stage of trauma treatment is establishing safety and stabilization: establishing bodily safety, a safe environment, and emotional stability. This promotes creation of a safe and stable life for the client in the here and now and the ability for the client to learn to utilize the Thinking Brain or Wise Mind (Prefrontal Cortex/Frontal Lobes) versus the Emotional Brain (Limbic System). 

On one hand, for some survivors, restrictions practically limit opportunities for being triggered and feeling unsafe, while for other survivors, restrictions themselves can trigger a feeling of being controlled by others and therefore not in control themselves. Some survivors report that having certain restrictions within a residential program can make them feel secure and safe, without feeling constricted by those limitations. Avoiding people, situations, and conversations related to their trauma, by limiting phone use and external exposure, is considered a normal self-protection mechanism for survivors and can be healing and helpful for coping with trauma; however, programs must be intentional and attentive that these restrictions do not result in a general feeling of detachment or disconnection for their clients. 

In contrast, some survivors may be triggered or retraumatized by program restrictions that remind them of the constraints and controls placed on them while being trafficked. For example, it is very common for traffickers to control and monitor the phones of the people they are exploiting and thus, restrictions on phone access in a residential program, without their desire for such restrictions, may trigger survivors. By not providing clients with a say in how they address unsafe persons and external communications, they may not feel safer because of the restrictions but instead feel their voice, agency, and choice within the program and within their healing process is diminished. Thus, some survivors may feel more comfortable and safe in a program without restrictions. Those programs without restrictions regarding contact with unsafe persons must ensure that they are providing clients with the tools and skills to respond to external triggers, including situations, people, and conversations related to their trauma. Programs without restrictions can teach clients to identify their triggers, catch triggers early, talk through them though with professionals/staff, and find positive experiences to calm them down. 

The difference in what feels safe and stable, including restrictions or no restrictions, may vary for each individual survivor and should be considered when assessing whether your program is the right fit for a survivor.

Transparency & Trustworthiness

In order for a survivor to assess if your program is the right fit for them, regarding safety practices and restrictions, they first need to be aware of those policies and practices. A part of providing trauma-informed care is being transparent about your agency’s organizational operations, policies, and decisions, which serve to build and maintain trust with the clients you are serving, as well as staff and all those involved with your organization and its mission. 

This must include being transparent about any/all policies that limit the personal freedoms of clients, including restricting access for phones or computers or leaving the premises. Your policies regarding contact with unsafe persons should be clear and a part of the intake process with any potential new residents. Both prospective resident and director (or intake staff person) should sign that the potential resident has read, understood, and agrees to the policy. This ensures that all clients are not only aware of the policies and practices within the environment they will be living, including any and all restrictions, but acknowledge that this policy is what they want from their service provider. 

Additionally, if your program does include restrictions, you must be transparent in your intake process how and when these restrictions will be lifted. You should clearly define the support and steps taken to ensure the resident remains safe, as they receive increased autonomy and access to persons and activities outside of the program

Empowerment & Independence

An essential part of trauma-informed care and the healing process for survivors is empowerment, through both voice and choice. This entails recognizing/building on client strengths and utilizing shared decision making and goal setting to determine the client’s course of recovery. Your agency should seek to empower each client and recognize the importance of fostering a client’s own agency within their experiences, healing, and recovery. Survivors, through their experiences of exploitation and abuse, can often feel like their voice and choice have been diminished so much that they do not feel in control over their own lives. Survivors can feel empowered when they are supported in cultivating self-advocacy and independence, where they feel in control of their lives through choice and developed skills.  

A part of empowering clients and helping them to develop skills that work towards independence is educating them on how to assess who is safe versus unsafe. Your agency can provide psychoeducation to increase client confidence in identifying and differentiating between physically and emotionally safe and unsafe individuals and relationships. This may take the form of formal curriculum and training or periodic check-ins to educate and equip residents to self regulate who is safe vs unsafe and how to maintain safe practices for themselves. This education should include relevant topics, such as smart internet use, current triggering relationships, and dating after the program (See Survivor Questionnaire Tool in Commentary Sources). 

While there can be value in having restrictions within your program, seeking to prevent or deter clients from having contact with unsafe persons, there is a need to recognize that the time in a program for a survivor is temporary and short-term, relative to life out of the program. A part of program success is providing and empowering clients with the tools and confidence to enter independence, after the program. This requires clients to know how to handle triggers related to phones, computers, leaving premises, and being in public without supervision. This is why it is essential for programs that incorporate restrictions to help clients transition to be more independent, as a part of their programming. Programs should seek to empower survivors to recognize that gaining independence and confidence includes the experience of learning from mistakes, rather than being punished for failures. Transitioning to independence within the program can provide clients with adequate safety and community to fall back on if they experience setbacks, as opposed to after the program, when they may not have the same level of support. If the program begins with restrictions, your agency can periodically utilize an assessment tool that can be conducted with a case manager, alongside the survivor, to help decide when the survivor is ready for more access and independence.

Collaboration and Mutuality

Building trust and empowering clients can also be fostered through collaboration and mutuality within your program. This means placing importance on the partnership between staff and clients in the decision-making and recovery process for survivors. Trauma-informed care emphasizes that survivors should not just feel like the recipients of your agency’s services and policies, but rather clients should feel like they have an active role and voice within their own healing and recovery.

This collaboration and mutuality can come from the use of Motivational Interviewing that explores what the client is willing to do and includes choice whenever possible. For example, after receiving an explanation on how restrictions can promote safety and healing from trauma, your agency can provide clients with choice and input, such as “what would they (the client) be willing to restrict?” Through mutual conversations with the client, your agency can establish what restrictions or practices would best fit the client’s needs with consideration for their choices. This may take the form of week-to-week or daily check-ins with the resident on what they are willing to do, regarding contact with unsafe persons and restrictions. Your agency should expect that some clients may be ambivalent or resistant to restrictions and thus, using motivational interviewing and meeting the client where they are can help them to feel empowered and heard within the program. 

Your agency can additionally increase collaboration and mutuality by valuing client feedback on unsafe persons policies and any and all restrictions within the program. By reviewing and discussing the policy with clients, your agency can better understand if it clearly communicates the restrictions and limitations of contact via electronic means or in-person opportunities.

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