STANDARDS FOR THE PROTECTION OF MINORS

“STANDARDS FOR THE PROTECTION OF MINORS” I LIKE ENGLISH DOROTA OSTROWSKA ul. 27 GRUDNIA 17/19 LOK. 508, 61-737 POZNAŃ, Poland NIP (Tax Identification) No.: 782 232 96 81

Introduction

The document “Standards for the Protection of Minors” introduced at I LIKE ENGLISH DOROTA OSTROWSKA („Establishment”) has been prepared in accordance with the Act of 28 July 2023 amending the Act on Family and Guardianship Code (Journal of Laws of 2023, item 1606).

This document aims to ensure the highest level of protection of minors against abuse, which encompasses child neglect, physical or psychological violence, and exploitation.

The employees of the Establishment have been acquainted with the contents of this document.

All actions taken by employees prioritise the well-being and safety of minors.

The “Standards for the Protection of Minors” are available in two formats: a complete version and an abbreviated version for minors.

Section I – Basic terms

  1. Organiser of activities – Dorota Ostrowska, owner of the Establishment.
  2. Employee of the Establishment – an individual employed at the Establishment through a mandate contract, an employment contract, or a B2B contract.
  3. Minor – any individual under 18 years of age who uses the services offered by I LIKE ENGLISH.
  4. Guardian – an individual authorised to represent a minor, including a parent, legal guardian, or foster parent.
  5. Harm to a minor – a criminal act or any wrongdoing detrimental to a minor committed by any individual, including employees of the Establishment, or a threat to the welfare of a minor, including neglect. Specifically, harm to a minor encompasses psychological abuse, physical abuse, sexual abuse, and neglect.
  6. Consent of the minor’s guardian – approval granted by at least one of the minor’s legal guardians. If a child’s guardians cannot reach an agreement, they should be informed that the matter needs to be resolved by the family court.
  7. Child’s personal data – any information that enables the identification of a minor.
  8. SPM – this document (“Standards for the Protection of Minors”).

Section II – Guidelines to maintain a safe relationship between minors and staff

Positive behaviours

  1. When communicating with minors, always be patient and respectful.
  2. When communicating with minors, listen attentively and provide responses that are suitable for their age and circumstances.
  3. When communicating with minors, try to keep your face at their face level.
  4. Assure minors that if they feel uncomfortable with a certain behaviour, situation, or words, they can tell you about it and expect support or assistance.
  5. Value and respect the contributions of all minors, regardless of their gender, sexual orientation, ability/disability, social status, or ethnic, cultural, or religious background.
  6. Respect the right of minors to privacy. If you must depart from this rule, explain the reasons clearly.
  7. When making decisions that affect minors, keep them informed and consider their expectations.
  8. Exercise additional caution when working with minors who have experienced any form of abuse or harm (including sexual, physical) or neglect. Such experiences may lead a child to seek inappropriate or inadequate physical contact with adults. In such situations, it is important to respond with sensitivity and firmness, guiding the minor to understand the significance of personal boundaries.

Negative behaviours

  1. Never embarrass, humiliate, disrespect, or insult a minor.
  2. Never raise your voice at a minor except when it is necessary for their safety or the safety of other minors.
  3. Never hit, poke, push, or otherwise compromise the physical integrity of a minor.
  4. Never engage in any type of intimate or sexual relationship with a minor (including sexual jokes, comments, gestures, or sharing of erotic or pornographic content in any form). Any risky situations involving an employee’s infatuation with a minor or a minor’s infatuation with an employee must be reported to the Owner of the Establishment. If you witness any such incidents, respond with respect and consideration for the dignity of everyone involved.
  5. Never record any images of minors for personal use. This also includes allowing third parties to record images of children without the Owner’s knowledge and explicit consent.
  6. Never invite minors to your home or apartment, nor meet with them outside of working hours. If it is necessary to meet with minors outside of working hours, the Owner must be informed, and both the guardians and minors must consent to this contact.
  7. Never contact minors through private communication channels, such as personal phone calls, email, instant messaging, or social media, for any purposes unrelated to the lessons. Never contact minors through private communication channels or media that have not been authorised/made available by the minor’s guardian.
  8. Never offer minors alcohol, tobacco products, or illegal substances, nor use them in their presence.
  9. If you witness any of the above behaviours or situations involving other adults or children, always report them to the Owner.
  10. If you have a social or family relationship with the minor’s guardians (for example, if the minor and guardians are relatives of the employee), you are required to keep all information about other children and their guardians confidential.
  11. Refrain from any physical contact with minors that is not strictly necessary. However, there are situations where physical contact with a child may be appropriate and align with the principles of safe contact, such as when responding to the child’s immediate needs while considering their age and developmental stage.
  12. Always exercise professional judgement by listening, observing, and noting the child’s reactions. Seek the child’s permission for any physical contact, such as hugging, and remain mindful that even with good intentions, such contact may be misinterpreted by the minor or others.
  13. Physical contact with a child must never be secretive, involve any form of gratification, or arise from a power dynamic.
  14. Never share sensitive information about a minor with any unauthorised individuals, including other minors. This includes the child’s image, as well as details regarding their family, economic status, medical history, care circumstances, and legal situation.
  15. Always maintain appropriate behaviour in the presence of minors. This means avoiding vulgar language, gestures, and jokes, refraining from making offensive remarks, not discussing sexual activity or attractiveness, and never using the position of power or physical advantage to intimidate, coerce, or threaten a minor.
  16. Do not touch a minor in any manner that could be perceived as indecent or inappropriate.
  17. If you observe any of the aforementioned behaviours or situations involving other adults or minors, promptly inform the Owner and complete the intervention card (Appendix 3).

Section III – Taking action against child abuse: recognising and responding to risk factors

Employees of the Establishment, in the course of their duties, are required to pay special attention to risk factors for the abuse of minors, such as:

  • Physical marks (bruises, bites, wounds) with no clear explanation for their origin. The injuries are in various stages of healing.
  • The explanations provided by the child regarding the injuries appear unbelievable, implausible, or inconsistent, and the child frequently changes them.
  • The child feels fear towards their parent or guardian and is scared to go back home.
  • There has been a sudden and marked change in the child’s behaviour during play, or the child’s creative work contains disturbing elements.
  • The child discusses instances of violence and describes the harm they are experiencing.
  • The child displays concerning behaviours such as withdrawal, fear, depression, aggression, rebellion, or self-harm. Also, note any instances of bed-wetting, particularly if it seems unrelated to a medical condition or occurs in specific situations or around certain individuals.
  1. When specific behaviours of parents or guardians coincide with a minor’s symptoms, it strongly suggests the possibility of child abuse. Such behaviours include, for example, refusing to explain the causes of the child’s injuries, offering unconvincing or contradictory explanations for the child’s injuries or behaviours, exhibiting aggressive behaviour as a guardian, and subjecting the minor to harsh discipline or humiliation.

 Section IV – Steps to take when there is suspicion or information about harm to a minor by an employee, third party, another child, or a guardian

  1. Threats to the safety of minors can manifest in various ways, using different methods of contact and communication.
  2. For the purpose of the SPM, the following classification of threats to children’s safety has been established:
  • a criminal act has been perpetrated against a child, such as sexual abuse, rape, or child maltreatment;
  • there has been another form of non-criminal harm to a minor, such as shouting, physical punishment, or humiliation;
  • the essential needs of the child, such as those concerning nutrition, hygiene, or health, have not been adequately met.
  1. In the event that an employee of the Establishment takes suspicion that a child is being abused, the employee must report this to the Owner and prepare an official note.
  2. The employee is required to contact the child’s guardian if they suspect harm has occurred and inform them of their concerns.
  3. The child’s support plan should include recommendations for:
  • actions to be taken by the Establishment to ensure the child’s safety, including reporting suspected abuse to the relevant authorities (for example to initiate the “Blue Card” procedure designed to protect victims of domestic violence and take action against perpetrators).
  • If you suspect that a child’s life is in danger or they are at risk of serious harm to their health, immediately notify the appropriate authorities (police, ambulance) by calling 112. Appropriate services are notified either by a staff member (following prior communication with the Owner) or directly by the Owner of the Establishment.
  1. For the purpose of documenting an intervention, an Intervention Card should be prepared (using the template included in Appendix 3 to this document).
  2. All employees and individuals who, in the course of their duties, acquire information about child abuse or related matters, are required to maintain the confidentiality of this information. This obligation excludes the sharing of information with authorised institutions as part of intervention activities.

Section V – Rules for children’s access to the Internet

  1. The Establishment provides access to WiFi Internet.
  2. Minors should use the Internet under the supervision of a guardian. If a guardian is absent and an employee of the Establishment observes a child accessing inappropriate online content, the employee must intervene by addressing the child and informing the child’s guardian.
  3. Staff at the Establishment may use Internet-enabled programmes and applications during classes with minors to support their educational objectives.

Section VI – Rules for the protection of personal data of minors

  1. The personal data of minors are protected in accordance with the provisions of the Act of 10 May 2018 on the Protection of Personal Data, as well as Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

Section VIII –  Rules for the protection of children’s images

  1. The publication of a child’s image, whether in the form of a photograph or an audio-video recording, requires the written consent of the child’s guardian.
  2. The written consent should specify where the recorded image will be used and the context in which it will appear, such as for promotional, educational, or therapeutic purposes.

Section VIII – Rules for safe staff recruitment

  1. It is standard practice to recruit employees in accordance with the principles of safe recruitment, with the employer making every effort to thoroughly verify the candidate’s qualifications
  2. In each case, I LIKE ENGLISH DOROTA OSTROWSKA must have data enabling the identification of the employed person, regardless of the basis of employment. This includes the first name(s), last name, PESEL number, and contact details of prospective employees.
  3. Pursuant to Article 21 of the Law on Countering the Threat of Sexual Offences, the hiring person must check the candidate against the Sex Offender Registry (restricted access registry) before entering into a contract. A background check of the Offender Registry is documented by a printout of the feedback generated from the Registry. Being listed in the Registry disqualifies a candidate from being hired.

Section IX – Rules for reviewing and updating the Standards for the Protection of Minors

  1. The person responsible for overseeing the SPM is the Owner. The Owner’s duties include monitoring the implementation of the Standards (Appendix 4), addressing any violations or providing necessary updates, ensuring that all employees are familiar with the SPM, and collecting signed declarations from each employee confirming their acknowledgement of the Standards in place at the Establishment.
  2. The Standards will be updated at least every two years and whenever there is an amendment to the regulations that form their legal basis.