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Sex Trafficking & the Role of PPM 166

Updated: Oct 12, 2022

By: Martin Msowoya

Human trafficking is rapidly increasing and has become one of the most profitable crimes in the world. A form of human trafficking is sex trafficking -- a crime under the Criminal Code of Canada described as a form of sexual exploitation which may include recruiting, harbouring, transporting, and obtaining or providing a person for the purpose of sex. Domestically, between 2009 and 2016, two-thirds of human trafficking cases in Canada were reported in Ontario. Further, in 2019, Ontario had the most police-reported cases of human trafficking, with approximately 6% of the accusers being between the ages of 12 and 17. These statistics highlight the dangers that communities and schools are exposed to, especially for victims, who are often young women, girls, and boys who identify as part of the LGBTQ2S+ community.

The unfortunate reality is that schools have become a prospective breeding ground for recruitment for sex trafficking.

To combat the pervasiveness of sex trafficking, the Ministry of Education introduced Policy/Program Memorandum 166 (“PPM 166”), also known as the Keeping Student Safe Policy, which serves as a starting point that allows Ontario school boards to construct anti-sex trafficking protocols. The Policy will make specific School Boards within the province create a framework that protects students, trains school staff, and ensure that surrounding communities play a vital role in maintaining safety and security.

Purpose of PPM 166

PPM 166 was a response to human trafficking in Ontario. The Ministry of Education’s policy framework builds on current Health and Physical education curriculums for grades 1 to 8. The framework teaches students skills necessary to identify and respond to exploitative and coercive behaviour, determine when a student is in an unsafe situation, and help themselves and other students, whether in person or online. Implementing the framework is crucial as school children are primarily targeted in Canada as early as 13 years old. Teachers, administrators, education assistants, and caretakers play an integral part in the prevention process as they interact daily with students. Through proper training, school staff can spread awareness, educate on prevention, and recognize noticeable changes in students. The increased risks and dangers do not begin and end at school; social media and digital tools such as laptops and cell phones also threaten young people. Instantaneous access to the internet has created a pathway for young children to be lured, groomed, and recruited. By providing the necessary training, PPM 166 equips school staff and students to mitigate the risks of harm.

Policy Direction

PPM 166's anti-sex trafficking protocols include:

  • Staff roles and responsibilities

  • Training, and

  • accountability measures.

These are guided by a statement of principles, strategies to raise awareness and prevent sex trafficking and response procedures. Each element plays a crucial role in students’ prevention, protection, and safety from the dangers of sex trafficking.

Training for school board staff is a crucial component of this policy direction; it addresses the common misconceptions about sex trafficking and provides context about human rights-based approaches to combat sex trafficking through the application of an equity, anti-racism, trauma-informed, gender-based lens. This will equip school boards to appreciate the complex circumstances that may lead to a student becoming a victim of sex trafficking.


Ultimately, the framework created by the Ministry of Education serves as a building block for school boards to develop protocols and responses to the dangers of sex trafficking. The creation of protocols not only protects and brings awareness to students but can also educate school board employees while highlighting the insidious problems persistent within the education system and, more broadly, Ontario.

Martin Msowoya is in his final year of his legal studies at City, University of London. He has been a law student with Battick Legal since March 2022.


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