Preamble, i.e. introduction to the document

The guiding principle of all actions undertaken by the staff of Pankracy Foundation is to act for the welfare of the child and in the child’s best interests. Every staff member treats children with respect, taking into account their needs and rights.
All forms of violence against children are absolutely unacceptable. Staff act in accordance with applicable law, the organisation’s internal regulations, and within the limits of their competences.
We refer to a fundamental principle: “The true measure of any society can be found in how it treats its most vulnerable members.” This quote reminds us of our responsibility towards children who need protection, support, and care.

Legal basis of the Child Protection Policy

• Convention on the Rights of the Child adopted by the United Nations General Assembly on 20 November 1989 (Dz. U. of 1991, No. 120, item 526, as amended)
• Constitution of the Republic of Poland of 2 April 1997 (Dz. U. No. 78, item 483, as amended)
• Act of 25 February 1964 – Family and Guardianship Code (consolidated text: Dz. U. of 2020, item 1359)
• Act of 28 July 2023 amending the Family and Guardianship Code and certain other acts (Dz. U. item 1606).
• Act of 13 May 2016 on Counteracting Threats of Sexual Crime and the Protection of Minors (Dz. U. of 2024, item 560, as amended)
• Act of 29 July 2005 on Counteracting Domestic Violence (consolidated text: Dz. U. of 2021, item 1249).
• Act of 6 June 1997 – Criminal Code (consolidated text: Dz. U. of 2022, item 1138, as amended).
• Act of 6 June 1997 – Code of Criminal Procedure (consolidated text: Dz. U. of 2022, item 1375, as amended).
• Act of 23 April 1964 – Civil Code (consolidated text: Dz. U. of 2022, item 1360, as amended) – Articles 23 and 24
• Act of 17 November 1964 – Code of Civil Procedure (consolidated text: Dz. U. of 2023, item 1550, as amended).

Glossary of terms/explanation of terms used in the Child Protection Policy document

1. **Child** – a person under 18 years of age who is entitled to full rights and protection in accordance with the Convention on the Rights of the Child and applicable national law.
2. **Organisation staff** – persons involved in the activities of the Foundation, including employees, volunteers, trainees, and interns, who perform specific tasks for the organisation and children in accordance with the principles of the Child Protection Policy.
3. **Parent/Legal guardian of the child** – a person exercising parental authority over the child or appointed as the child’s legal guardian, responsible for the child’s welfare and upbringing and making decisions on the child’s behalf.
4. **Consent of the parent/legal guardian** – formal consent given by the child’s parent or legal guardian for activities concerning the child, such as participation in events, therapy sessions, or other activities carried out by the organisation.
5. **Child abuse** – any acts or omissions by adults that lead to physical, emotional, psychological, or sexual suffering of a child or to neglect:
– **Physical violence** – all forms of aggression and use of force against a child that result in bodily injury, pain, or other physical harm.
– **Psychological violence** – actions that cause fear, humiliation, or low self-esteem in a child, such as insults, intimidation, or isolation.
– **Sexual abuse** – all forms of involving a child in sexual activities that are inappropriate for the child’s age or development, or to which the child is unable to give informed consent.
– **Neglect** – failure to provide a child with basic needs such as care, safety, food, clothing, healthcare, and education, leading to the child’s suffering and neglect.
6. **Child’s personal data** – any information that makes it possible to identify a child, such as first name, surname, date of birth, home address, information concerning health, family situation, contacts, or other specific sensitive data.
7. **Person responsible for implementing the Child Protection Policy in the organisation** – a designated person responsible for supervising the implementation of and compliance with the Child Protection Policy and coordinating activities related to its implementation.
8. **Person responsible for children’s safe use of the Internet on the organisation’s premises** – a person designated to supervise and monitor children’s online activities, ensure their safety in the digital environment, and prevent exposure to inappropriate content and risks related to cyberbullying.

Identifying and responding to risk factors for child abuse

To effectively prevent child abuse, it is essential to identify and respond appropriately to risk factors. These factors may coexist with violence against a child or precede it, so early identification makes it possible to take preventive measures that reduce the risk of violence occurring.

Principles for identifying and responding to risk factors:

Staff education
Regular staff training on risk factors for child abuse is essential. It covers the entire team, including employees, volunteers, trainees, and interns.
Types of education: The organisation may use training provided by external institutions, such as psychological and educational counselling centres and non-governmental organisations specialising in child protection, as well as conduct internal educational sessions led by qualified staff members.
Frequency: Training is conducted regularly to ensure continuity of staff knowledge and competences in identifying risk factors.

Monitoring risk factors
The organisation identifies risk factors occurring in various areas of its activities and implements procedures aimed at minimising them.
Examples of risk factors: poor quality of foster care, inadequate housing conditions, child behavioural problems, difficult family financial circumstances, social isolation of the family, domestic violence, emotional and mental health problems of caregivers, alcohol or drug abuse by parents.
Monitoring activities: Staff regularly monitor situations in which risk factors may occur, keep records, and analyse cases of children who may be at risk of abuse.

Responding to identified risk factors
If risk factors are observed, staff are required to report their observations immediately.
Reporting procedure: Information concerning risk factors for child abuse is reported to the person responsible for implementing the Child Protection Policy in the organisation or to the immediate supervisor. In urgent cases, if there is a threat to the child’s life or health, the appropriate services (e.g. police, MOPS) must be contacted immediately.
Further steps: Reported cases are analysed, and the organisation takes intervention or preventive measures, such as psychological support for the family, mediation, or referral of the case to the appropriate institutions.

Staff recruitment principles (employees/volunteers/interns/trainees)

Pankracy Foundation introduces clear and rigorous staff recruitment principles aimed at ensuring that people working with children or cooperating with the organisation are properly verified in terms of their qualifications, experience, and criminal record. The recruitment process applies to all persons who will have direct or indirect contact with children, including employees, volunteers, interns, and trainees.

Recruitment principles:
Information from the National Criminal Register (KRK)
Candidates for positions in the organisation are required to provide information from the National Criminal Register (KRK) confirming that they have no criminal record. In cases where permitted by law, the Foundation obtains this information about the candidate itself.

Declaration of no criminal record
In situations where information from the KRK is not required, the candidate submits a declaration of no criminal record and of no pending criminal or disciplinary proceedings against them. This also applies to any proceedings that may violate child protection principles.
Verification in the Register of Sexual Offenders (RSPTS)
The organisation checks whether the candidate’s details appear in the Register of Sexual Offenders (RSPTS). Persons listed in this register may not work for or cooperate with the Foundation.

References from persons who know the candidate
Each candidate for a position involving work with children must provide references from persons who can confirm their professional experience and competences in working with children or in work that involves contact with children.
These references are verified before an employment decision is made.

Questions concerning child protection
During the recruitment process, candidates are asked questions concerning child protection principles, their knowledge of the subject, and their attitude towards potential situations of abuse. The purpose is to assess the candidate’s awareness of the child protection policy and readiness to respond to situations that threaten children.

Staff monitoring
After employment or cooperation with the organisation begins, staff are regularly monitored for compliance with the Child Protection Policy. Monitoring includes:
periodic reviews of declarations of no criminal record,
observation of staff behaviour and attitudes towards children,
organisation of training to raise awareness of child protection.
Compliance with the above recruitment and monitoring principles ensures that all persons involved in the activities
of the Foundation are competent, responsible, and act in accordance with the organisation’s values, with the welfare of the child as their primary objective.

Principles of safe relationships between the organisation’s staff (employees, volunteers, interns, trainees) and children

The aim of Pankracy Foundation is to ensure children’s full safety and protection in their interactions with staff, including employees, volunteers, interns, and trainees. These principles regulate various aspects of these relationships, ensuring respect for the child’s dignity, privacy, and well-being. Introducing these rules minimises the risk of abuse and promotes appropriate attitudes.

1. Principles of physical contact
Permitted physical contact: Physical contact is permitted only in situations where it is necessary and justified (e.g. assistance in caring for a child, interventions in the event of a threat to health or safety).
It should always take place with the consent of the child and the parent/legal guardian, while respecting the child’s boundaries.
Prohibited physical contact: Any form of physical violence, sexual abuse, inappropriate touching, or touching without the child’s consent is strictly prohibited. Staff may not initiate close physical contact unless it is necessary and required by the situation.

2. Principles of staff communication with children
Form of communication: Staff address children respectfully, use their names, and avoid nicknames.
Any form of humiliation, insulting, threatening, or use of sarcasm towards children is unacceptable.
Language of communication: All staff communications must be adapted to the child’s age and level of understanding and should build a positive relationship based on trust and safety.

3. Equal treatment of children
Respect for diversity: Children should be treated equally and respectfully, regardless of their age, sex, origin, religion, sexual orientation, health condition, or family situation.
Equality and individual needs: Equal treatment does not always mean identical treatment. Staff should adapt their approach to the child’s individual needs and abilities; for example, children with disabilities may require greater support.

4. Rest and overnight stays
Overnight stay rules: During trips or overnight stays organised by the Foundation, staff may not sleep in the same rooms as children. A clear separation of private space between children and staff must be maintained.
Permitted conduct: During overnight stays, staff must maintain a professional and safe relationship with children and avoid any situations that could violate their sense of safety and privacy.

5. Care and hygiene activities, feeding children
Assistance with self-care activities: In the case of younger children or children with disabilities, staff assist with hygiene and care activities only with the consent of the child and their legal guardian. The child’s intimacy and privacy must be fully respected.
Prohibited conduct: Any violation of the child’s privacy is unacceptable, as is neglect of hygiene or use of intimate situations for inappropriate purposes.

6. Disciplining and rewarding children
Rewarding principles: Staff may reward children for positive behaviour, but rewards should be given fairly and transparently.
Discipline: All methods of discipline must be free from violence (both physical and psychological).
Any forms of punishment that humiliate children or violate their dignity are unacceptable.

7. Staff contact with children outside the organisation
Rules for contact outside the organisation: Staff contact with children outside the Foundation’s place of activity (e.g. through social media or by phone) is permitted only for professional purposes and under clearly defined rules.
Communication must be documented, and private communication channels may not be used to contact children.
Prohibited contact: Staff may not send friend requests to children on social media or engage in private phone conversations unrelated to the Foundation’s activities.
These principles are intended to protect children from any abuse and to build a safe, friendly environment within the organisation in which every child feels respected and secure.

Intervention procedures in the event of suspected child abuse

Pankracy Foundation has developed detailed intervention procedures aimed at protecting children from abuse and ensuring an immediate and effective response in the event of suspected violence or other violations of their well-being. The steps below serve as a guide for staff and help them take appropriate action when concerning situations arise.

1. Reporting suspected child abuse
Duty to report: Any staff member who notices concerning signs that may indicate child abuse is obliged to immediately report their suspicions to the person managing the organisation and to the person responsible for the Child Protection Policy.
Warning signs: These may include signs of physical violence, psychological violence, sexual abuse, neglect, peer violence, or other forms of abuse.

2. Documentation of the report
Official note: Each report should be documented in the form of an official note summarising the reporting person’s observations.
Intervention record: The Foundation records every report of suspected child abuse in a special intervention record describing the course of action taken.

3. Conducting interviews
Individual interviews: Depending on the circumstances, the organisation conducts separate interviews with the person suspected of abuse, the child, and the child’s parents/legal guardians.
Scope of interviews: The purpose of the interviews is to establish the facts and identify the risk while ensuring that the child feels safe.
Responsible person: The person/persons designated by the Foundation conduct these interviews and ensure that they are carried out professionally.

4. Intervention steps
Step 1: After gathering information from the interviews, the designated person decides on further action. If the suspicions are confirmed, further steps are taken.
Step 2: If necessary, the organisation reports the suspicion to the appropriate services (police, social welfare centre, family and guardianship court) or notifies supervisory authorities, e.g. a disciplinary officer.
Immediate threat to life or health: If the child’s life is in immediate danger, the person who received the information is obliged to notify the police or emergency medical services immediately.

5. Further action and monitoring
Monitoring the situation: After the intervention, the situation of the child and the other children remaining under the organisation’s care must be monitored regularly.
Designation of a responsible person: A person responsible for monitoring must be designated and held responsible for ensuring that the child’s situation improves and that the risk of abuse is eliminated.

6. Confidentiality of information
Duty of confidentiality: All persons involved in the intervention process are obliged to keep information concerning suspected child abuse confidential, except where such information is provided to authorised institutions as part of intervention activities.
These procedures are intended to ensure a prompt and appropriate response to every suspicion of child abuse, with respect for the child’s dignity and in accordance with applicable law.

Principles for protecting children’s personal data and image within the organisation

At Pankracy Foundation, we take care to protect children’s personal data by applying appropriate principles and procedures in accordance with applicable legal regulations. Below we present the principles concerning the protection of children’s personal data in our organisation:

Personal data processed:
The organisation processes children’s personal data, including: first name, surname, date of birth, home address, contact details of parents/legal guardians, health information, and data concerning participation in programmes organised by the Foundation.

Collection of data:
Personal data are collected directly from parents/legal guardians during the registration process for programme participants, through consent forms, and during other organisational activities (e.g. events, classes).

Data protection measures:
The organisation has implemented technical and organisational data protection measures, such as:
Physical safeguards (e.g. access to rooms in which data are stored),
Data security software (e.g. passwords, encryption),
Restricting access to data only to authorised persons (e.g. administrative staff, educators).

Access to personal data:
Only authorised persons within the organisation, such as staff responsible for educational programmes and administration, have access to children’s personal data.

Disclosure of personal data:
Children’s personal data may be disclosed to third parties or external entities only in legally justified situations, such as:
Legal requirements,
Cooperation with law enforcement authorities,

Activities aimed at ensuring children’s safety.
Data processing period:
A child’s personal data will be processed for the period necessary to fulfil the purposes for which they were collected, after which they will be deleted or anonymised.

Protection of the Child’s Image
Protecting children’s image is equally important to us. Below we present the principles concerning the protection of children’s image within the organisation:

Recording a child’s image:
Recording a child’s image on the organisation’s premises is permitted only in specific situations, such as:
Video surveillance (to ensure safety),
Recording images during events organised by the Foundation (e.g. workshops, fairs).
Only authorised staff (e.g. employees responsible for photographic documentation) have the right to record children’s images.

Consent to record an image:
The consent of a parent/legal guardian is required to record a child’s image in situations involving:
Creation of promotional materials,
Publication of photos or videos on the Foundation’s social media.

Publication of a child’s image:
A recorded image of a child may be made public only with the consent of the parent/legal guardian. Publications may appear on the Foundation’s website, in informational materials, and on social media.

Protection of a child’s image against third parties:
The organisation takes measures to protect a child’s image against unauthorised recording by third parties, such as:
Informing parents about the rules for taking photographs during events,
Prohibiting bystanders from recording children’s images without consent.

Situations in which a child should not be recorded:
Children should not be filmed or photographed in private situations, such as changing clothes, using the toilet, or in situations that may violate their intimacy.

Education of children and parents:
The organisation educates children and parents about the principles of recording the images of other children, emphasising the importance of respecting privacy and consent.

Organisation’s contact with the media:
All contacts between the organisation and the media concerning children must be agreed with the appropriate persons within the Foundation, and the consent of parents/legal guardians should always be respected.
The above principles are intended to ensure children’s safety and protect their personal data and image in the organisation’s activities.

Principles for the safe use of the Internet and electronic media

At Pankracy Foundation, we place particular emphasis on children’s safety on the Internet and when using electronic media. Below we present the principles concerning the safe use of the Internet and electronic media that should be followed by all members of our organisation and by children participating in programmes.

Principles for Safe Internet Use
Person responsible for network security:
The organisation designates a person responsible for network security whose duties include:
Installing and updating security software.
Monitoring computers with Internet access to detect harmful content.
Educating staff and children about online safety.

Procedure for responding to harmful content:
If harmful content is found on computers within the organisation, the following steps should be taken:
Immediately report the incident to the person responsible for network security.
Determine who was using the computer when the harmful content was introduced.
Provide the information to the organisation’s management board, which will take appropriate action.

Education on safe Internet use:
The organisation regularly provides educational materials on safe Internet use, including:
Rules for using the Internet,
How to recognise harmful content,
How to protect privacy online.
Regular online safety classes:
The organisation conducts regular classes and workshops on safe Internet use, including:
Discussions about online threats,
How to avoid dangerous situations (e.g. inappropriate contacts, phishing),
Skills in using tools that help ensure online safety (e.g. privacy settings, blocking inappropriate content).

Rules for using social media:
Children and organisation staff are required to follow social media rules, including:
Not sharing personal data (such as address, phone number, parents’ details).
Limiting friend requests to people they know personally.
Reporting any suspicious or inappropriate messages and contacts.

Monitoring Internet use:
The organisation has the right to monitor children’s Internet use in order to ensure their safety.
All monitoring activities should be carried out with respect for children’s privacy.

Psychological support:
In situations involving cyberbullying, harassment, or other online threats, the organisation provides children with access to psychological support.

Cooperation with parents:
The organisation encourages parents to actively participate in educating children about Internet safety, including jointly establishing rules for Internet use at home.

Monitoring

At Pankracy Foundation, monitoring and evaluation are key elements in ensuring the effectiveness of the Child Protection Policy. Regular review and updating of the document make it possible to identify areas requiring improvement and adapt standards to the changing needs of the organisation and the children in its care.

1. Designation of the person responsible for the Child Protection Policy

Responsible person: The organisation designates one person responsible for implementing, monitoring, and evaluating the Child Protection Policy. This person will act as coordinator and will be the main point of contact for child protection matters.

2. Scope of responsibilities of the responsible person

Scope of responsibilities:
Supervising the implementation of child protection standards within the organisation.
Conducting staff training on the Child Protection Policy.
Organising and coordinating the monitoring survey.
Analysing monitoring results and presenting recommendations for updating the Policy.
Ensuring that all information and activities concerning child protection comply with applicable legal regulations.

3. Frequency of conducting the monitoring survey

Monitoring survey:
A survey assessing the level of implementation of the Policy will be conducted at least once a year.
It may be addressed to all employees, volunteers, interns, trainees, and children in order to obtain a complete picture of the effectiveness of the activities.
The survey results will be used for analysis and to develop further actions and improvements.

4. Procedure for updating the Policy

Policy update:
The Child Protection Policy will be reviewed at least once a year as a result of the monitoring carried out and on the basis of changes in legal regulations, observations from practice, and suggestions submitted by employees and volunteers.
Any changes to the Policy will be documented, and employees and volunteers will be informed about the modifications introduced.
The new version of the Policy will also be publicly available on the organisation’s website.

Final provisions

Entry into force:
This Child Protection Policy of Pankracy Foundation enters into force on the date of its publication.

Method of access:
The Policy will be available to all employees, volunteers, interns, trainees, and children associated with the organisation in electronic form on the internal website of Pankracy Foundation.
A paper version of the Policy will be placed in [location, e.g. office, common room] to ensure easy access for all interested persons.
Information about the Policy and its updates will be regularly communicated by email and during staff training.
New versions of the Policy will be publicly available on the website of Pankracy Foundation.

Final provisions:
Any changes to the Policy will be introduced in accordance with the procedures described in its content and after consultation with employees and other interested parties.
All employees and volunteers are required to familiarise themselves with the content of the Policy and comply with its provisions.