Child Protection Standards

Child Protection Standards

Effective June 21, 2024, the Director of the Victoria Cultural Center (hereinafter referred to as “CKV Director”) has implemented these Child Protection Standards (the “Standards”). The primary objective is to ensure the safety and well-being of minors participating in workshops and events organized by the Victoria Cultural Center, prioritizing their needs and acting in their best interests at all times.

STANDARD I: Policy Framework

The Victoria Cultural Center has developed and implemented a comprehensive Child Protection Policy (Appendix No. 1). This policy outlines:

Procedures for Intervention: Response protocols for child welfare risks and reports of abuse.
Code of Conduct: Rules for safe interactions between staff and minors, as well as peer-to-peer interactions among minors, including a list of prohibited behaviors.
Risk Mitigation: Protocols for preventing, identifying, and responding to endangerment risk factors.
Digital Safety: Rules for protecting children from harmful online content and internet hazards, including the protection of image rights and personal data.
Evaluation: Standards for the dissemination and ongoing assessment of these protocols.

The policy is published and communicated to all staff, program participants, and their parents or legal guardians.

STANDARD II: Safe Recruitment

The Victoria Cultural Center adheres to Strict Safe Recruitment Principles. We actively involve all employees, interns, and volunteers in the prevention of harm and the protection of minors.

STANDARD III: Intervention Procedures

The CKV has established clear intervention procedures that are accessible to all personnel.

Reporting: Every employee knows the direct reporting line regarding the endangerment of a minor.
Responsibility: Designated individuals are responsible for managing intervention measures.
Resources: All staff are provided with contact details for local child welfare institutions and emergency intervention services (Chapter 3 of the Child Protection Policy).

STANDARD IV: Monitoring and Review

The CKV monitors the implementation of these Standards at least once every two years. We evaluate and update the policy as necessary, in consultation with staff, program participants, and their parents or legal representatives.

Child Protection Guidelines

Victoria Cultural Center (CKV) in Gliwice

Chapter 1: Definitions

CKV: Refers to the Victoria Cultural Center in Gliwice.
Staff: Includes any person employed under an employment contract or civil law agreement, as well as volunteers and interns.
Minor: Any participant in CKV courses or events who is under the age of 18.
Representative: The minor’s legal guardian or foster parent.
Parental Consent: Consent provided by at least one parent or legal representative.
Personal Data: Any information that allows for the identification of a minor.

Chapter 2: Prevention and Risk Identification

Safe Recruitment: Staff recruitment is conducted according to the principles outlined in Appendix 1.
Vigilance: Staff are trained to recognize risk factors and symptoms of child endangerment within the scope of their duties.
Supportive Communication: If a risk is identified, staff shall consult with the minor’s parents/guardians, provide information on available support services, and encourage them to seek professional help.
Signs of Abuse: Indicators of violence may include visible physical marks, avoidance of body exposure (e.g., during clothing changes in dance classes), wearing inappropriate clothing for the weather (long sleeves/pants in heat), or sudden, disturbing behavioral changes.
Monitoring: Staff shall monitor the minor’s well-being to the best of their ability.
Conduct: Staff must adhere to the rules for safe staff-minor relationships outlined in Appendix 2.

Chapter 3: Intervention Procedures for Child Safety Threats

Procedury interwencji w przypadku zagrożenia bezpieczeństwa małoletniego

Administrative Responsibility: The CKV Director is responsible for reporting suspected crimes against minors to law enforcement and notifying the Family Court. Relevant contact information shall be clearly posted on bulletin boards within CKV buildings, classrooms, and administrative offices.
Trauma-Informed Support: Any minor involved in an incident must be treated with empathy and understanding. Staff must ensure the minor does not feel responsible for the situation and must explicitly communicate that the perpetrator’s behavior is unacceptable.
Mandatory Documentation: If a staff member suspects a risk or receives a report from a minor or guardian, they are obligated to create a formal written note and submit it immediately to the CKV Director (via paper, email, or the internal document system).
Immediate Protection: If a violent incident is ongoing, the minor’s safety is the absolute priority; they must be immediately separated from the aggressive individual.
Intervention Leadership: All interventions are led by the CKV Director. If the Director is the reporting party, the Deputy Director shall lead the measures.
Professional Assistance: Specialists, including psychologists or educators, may be called upon to facilitate sensitive communication with the minor regarding difficult experiences.
Legal Reporting Obligations: If a crime is suspected, the lead intervenor must inform the parents/guardians of their obligation to report the matter to the competent authorities (Public Prosecutor, Police, Family Court, or Social Services) and proceed with filing the report.
Private Prosecution: In cases involving conduct subject to private prosecution, the CKV Director may advise the victim’s representatives on appropriate legal actions.
Standardized Recording: An Intervention Card (Appendix No. 3) shall be completed for every incident and logged in the CKV Intervention Register.
Emergency Situations: If there is a suspicion of an immediate threat to life, serious harm to health, or sexual abuse, staff must immediately call 112. The first staff member aware of the danger is responsible for the call and subsequent completion of the Intervention Card.
Inquiry and Investigation: Upon receiving a report, the Director will interview the minor and any witnesses to establish the facts and assess the impact on the minor’s physical and mental health. All findings will be recorded on the Intervention Card.
Parental Neglect or Abuse: If the inquiry reveals that parents/guardians are neglecting the minor’s needs, using violence, or failing to support the endangered minor, the CKV Director shall submit a formal request for a family situation assessment to the Family Court.
Institutional Cooperation: The CKV Director is obligated to provide necessary information regarding minor participants upon the formal request of authorized institutions (Courts, Police, Social Services).
False Alarms: If an investigation initiated by parents/representatives does not confirm the suspicion of danger, the parties must be informed of the outcome in writing.
Confidentiality: All CKV staff are bound by strict confidentiality regarding any information obtained concerning the endangerment of a minor, except when sharing such data with authorized legal institutions.

Threats Involving Adults:

Immediate Suspension: Any staff member reported for endangering a minor shall be suspended from all contact with minors until the matter is fully clarified.
Third-Party Partners: If the suspect is employed by an external partner, they shall be banned from CKV premises, and the partnership contract may be terminated.
Domestic Violence: If staff suspect a minor is a victim of violence at home or by a close associate, the Director will ensure the minor’s safety on-site and immediately notify the Police.

Peer-on-Peer Violence:

Standard Protocol: If a minor is suspected of endangering another participant:
1. Separate the suspect from the victim immediately and conduct separate interviews.
2. Interview witnesses to establish a timeline and assess the victim’s health
3. Record separate Intervention Cards for both the victim and the suspect.
4. Apply disciplinary measures as outlined in the course regulations.
External Perpetrators: If the aggressor is not a CKV participant, staff will support the victim and coordinate a meeting with parents to discuss professional resources.
Criminal Conduct: If the suspect is a minor over the age of 13 and their behavior constitutes a criminal offense, the Police must be notified.

Chapter 4: Rules for the Safe Use of the Internet and the Protection of Image Rights and Personal Data

Zasady bezpiecznego korzystania z Internetu oraz ochrony wizerunku i danych osobowych

Network Infrastructure: The CKV network infrastructure does not provide participants with direct access to the IT network.
Supervised Internet Use: When using devices with internet access under CKV supervision, staff members shall inform participants of all safety rules and actively monitor their online activity.
Data and Image Protection: The CKV guarantees the comprehensive protection of personal data and the image rights of minors in accordance with all applicable laws.
Consent for Close-ups: Close-up photographs or video recordings are only permitted with the express written consent of the minor’s parents or legal guardians.
Informed Consent: Consent is considered legally binding only if the specific purpose and nature of the intended use of the image are clearly disclosed.
The Minor’s Right of Refusal: If a minor refuses to give their consent to be photographed or recorded, their decision is final and binding, notwithstanding any prior consent provided by their parents or guardians.
Anonymity in Publications: Published photographs shall not be labeled with both the first and last names of the minor (only the first name may be used, where applicable).
Dignity and Context: The publication of any photographs that humiliate or ridicule a minor, portray them in a negative context, or show them unclothed is strictly prohibited.
Group and Event Photography: Preference is given to photographs of groups or events where the individual is merely part of a larger whole, in compliance with Article 81(2) of the Copyright Act.
External Contractors: If the recording of an event or course is commissioned to an external party (photographer/videographer), the following requirements must be met:
1. The contractor must be contractually obligated to comply with these Guidelines.
2. The individual performing the recording is required to wear a visible identification badge (ID badge) for the duration of the event.
3. The contractor is strictly prohibited from being alone with minors without the direct supervision of CKV staff.
Media and Third-Party Recording: Media representatives or any other external parties wishing to record CKV courses or events for publication must report their request in advance and obtain formal consent from the CKV Director. In such cases, it must be verified that parents/guardians have provided written consent for the registration of the minor’s image.
Media Requests and Transparency: When granting media permission to record and publish images, the CKV must obtain the full name and address of the requesting person or editorial office, the specific purpose and nature of the material’s use, and a signed statement confirming that all provided information is accurate.
Data Privacy and External Communication: The CKV does not provide personal data of minors or their parents/guardians to the media or other third parties, except for authorized legal institutions. Staff members must refrain from commenting on such matters, even in situations where they believe their comments are not being officially recorded.
Media Access Control: For the purpose of producing media material, the CKV Director may authorize access to selected premises at the CKV headquarters, provided that the setup makes it impossible to record any minors present on the site.
Identification of Non-Consenting Participants: In cases where parents/guardians or the minors themselves have not consented to the recording of their image, a clear method must be established to allow the person recording the event to identify and exclude them from all materials.
Prohibition of Private Use: Staff members are strictly prohibited from taking photographs or recordings of children for their own private purposes.
Reporting Privacy Breaches: Any information regarding a potential risk or violation of a minor’s privacy must be immediately communicated to the Data Protection Officer (DPO) and the CKV Director. They will take immediate measures to secure the data and restrict any further unauthorized access to confidential information.

Chapter 5: Communication, Implementation, and Periodic Review of the Child Protection Standards

asady i sposób udostępniania personelowi, małoletnim i ich reprezentantom polityki do zaznajomienia i stosowania oraz zasady aktualizacji i przeglądu Standardów

Accessibility of Documentation: All procedures and documents related to the implementation of these Standards shall be made available to staff, minor participants, and their parents/representatives during the initial announcement and commitment phase. Subsequently, they shall remain available upon request at any time. These documents are also published on the CKV website at www.ckvictoria.pl.
Summary for Minors: A simplified summary of the Standards, specifically tailored for minors, is posted on notice boards in the CKV office and in all rooms where regular courses are conducted.
Staff Acknowledgment: Every staff member is required to familiarize themselves with the Standards. Acknowledgment and acceptance of these rules are confirmed by signing a master list in the Personnel Department and submitting a formal declaration to their personnel file.
Parental Notification: Parents and legal guardians of regular course participants shall be briefed on the Standards during organizational meetings at the start of each academic year. The initial notification must occur immediately following the development and introduction of these Standards, and no later than within 30 days. Acknowledgment is confirmed by signing an attendance list or a formal statement submitted to the course instructor.
Participant Orientation: Minor participants shall be briefed on the Standards during one of their scheduled sessions each September. The initial orientation must take place immediately after the Standards are introduced, but no later than within 30 days. Confirmation of this orientation is recorded via the course attendance list or by a signature in the official course log.
Monitoring and Compliance: Employees designated by the CKV Director shall continuously monitor and regularly review all activities to ensure compliance with the adopted child protection rules. A formal assessment of the Standards shall be conducted at least once every two years to adapt them to current needs and evolving legal regulations. Findings from these assessments shall be documented in official file notes. Any amendments to the Standards shall be introduced via appendices, subject to approval by CKV management and consultation with representatives of parents or legal guardians.
Anonymous Surveys: At least once every two years, designated personnel shall conduct anonymous monitoring surveys among staff, parents, and participants regarding the effectiveness and implementation of the Standards. A qualitative and quantitative analysis of these surveys will be performed to create a comprehensive monitoring report for the CKV Director.
Evaluation Criteria: The monitoring and evaluation of these Standards shall be based on an analysis of internal documentation, inter-institutional correspondence, legal provisions, direct observation, and data from reports and survey studies.
Approval of Updates: All updates and changes made to the Standards must be approved by the CKV Director and formally presented to the staff, participants, and their parents/representatives.

Chapter 11: Final Provisions

Effective Date: These Standards shall enter into force on the date the official order is announced.
Public Announcement: The announcement shall be made by publishing the Standards on the CKV website and posting them on notice boards in the CKV secretariat and in rooms where courses for minors are regularly held. This includes the simplified summary version specifically designed for minors.

Appendix No. 1

to the Child Protection Policy

Principles for Safe Personnel Recruitment

at the Victoria Cultural Center in Gliwice

Pre-Employment Verification: Before establishing an employment relationship or admitting any person to activities involving the education, leisure, sports, or care of minors, the CKV must ensure that all personnel (including employees, contractors, volunteers, and interns) possess the appropriate qualifications and do not pose a safety risk to minors. To verify this, the CKV may request data regarding the candidate’s education, professional credentials, and employment history. The CKV must maintain identifying data for all personnel, including: full name(s), date of birth, and current contact details.
References: The CKV Director may request professional references from a candidate’s previous employers or contact details for individuals who can provide such references. Providing this information is subject to the candidate’s consent. In accordance with applicable regulations, a candidate shall not face negative consequences (such as automatic rejection) solely for declining to provide such data. The CKV is prohibited from conducting independent, unauthorized background screenings outside of the established legal framework.
Registry Checks: Before any individual begins duties related to the education, care, or medical treatment of minors, the CKV is legally obligated to verify the person in the National Register of Sex Offenders (restricted access) and the register of persons against whom the State Commission for Combating Sexual Abuse of Minors under 15 Years of Age has issued a decision. A printout of these search results shall be kept in the employee’s personnel file or equivalent documentation for volunteers and contractors.
Criminal Record Certificate: All persons referred to in Paragraph 1 must submit to the CKV Director a certificate from the National Criminal Register (KRK) confirming they have not been convicted of any offenses defined in Chapters XIX and XXV of the Criminal Code, Articles 189a and 207 of the Criminal Code, or the Act on Counteracting Drug Addiction.
Foreign Nationals and Non-Residents: Individuals who are not Polish citizens must present:
a) An official criminal record certificate from their country of nationality, obtained for the purpose of professional or voluntary work involving contact with children.
b) A formal declaration, made under penalty of perjury, listing all countries of residence within the last 20 years (excluding Poland and their country of citizenship).

If a country does not maintain a criminal register or disclose such information, the candidate must submit a formal declaration to that effect under penalty of perjury, affirming they have no prior convictions or court orders prohibiting them from working with minors.
Penalty of Perjury: All declarations made under the threat of criminal liability must include the following statement: “I am aware of the criminal liability for making a false declaration.” This statement replaces any separate instruction regarding the consequences of perjury.
Supplemental Declarations: If it is impossible to obtain the aforementioned official documents, the candidate shall submit a Declaration of Clean Criminal Record and a statement regarding any ongoing investigations, court proceedings, or disciplinary actions.

Appendix No. 2

to the Child Protection Policy

Code of Conduct: Rules for Safe Relationships Between Staff and Minors

§ 1

General Principles

Best Interests of the Minor: The primary rule governing all staff activities within the institution is to act for the benefit of the minor and in their best interests.
Dignity and Respect: Staff shall treat all minors with respect, fully acknowledging their dignity and individual needs.
Legal Framework: Staff must operate within the framework of applicable law, the institution’s internal regulations, and their designated authority.
Prohibited Conduct: Any form of prohibited conduct, as defined in these procedures, is strictly forbidden.
Scope of Application: These rules apply to all employees, contractors, interns, and volunteers.

§ 2

Professionalism and Transparency

Professional Boundaries: All personnel listed in § 1(5) are required to maintain a professional relationship with minors. They must continuously evaluate whether their communication, reactions, or actions are appropriate, safe, justified, and fair.
Transparency: Staff are obligated to act openly and transparently to minimize the risk of their behavior being misinterpreted by others.

§ 3

Communication Rules

When communicating with minors, staff shall:

Provide answers that are age-appropriate and suitable for the situation.
Strict Prohibitions: It is strictly prohibited to shame, humiliate, disrespect, or insult a minor.
Raising Voice: Staff may not raise their voice at a minor, except in situations involving an immediate threat to the safety of the minor or other participants.
Inclusion: When making decisions that affect minors, staff should inform them and attempt to take their expectations into account.
Privacy: The minor’s right to privacy must be respected. The only exception is a situation posing a threat to the minor’s life or health, which must be explained to them as soon as possible.
Empowerment: Staff should reassure minors that they can report any situation, behavior, or language that makes them feel threatened or uncomfortable to a designated person (in accordance with CKV intervention procedures) and expect a supportive response.

§ 4

Unacceptable Behavior Toward Minors

Sensitive Data: It is prohibited to disclose sensitive data as defined by Art. 9(1) of the GDPR. This includes information regarding:
- Racial or ethnic origin.
- Political opinions, religious or philosophical beliefs.
- Genetic or biometric data used for identification.
- Health data, sexuality, or sexual orientation.
Inappropriate Conduct: Unacceptable behavior includes the use of vulgar language, gestures, or jokes; making comments regarding sexual activity or physical attractiveness; and engaging in sexual or romantic relationships with a minor.
Physical Contact: In situations requiring care or hygiene assistance, physical contact must be strictly limited to what is absolutely necessary (e.g., assisting with dressing, eating, or using the restroom).
Abuse of Power: Exploiting a relationship based on power or physical superiority (intimidation, coercion, or threats) is strictly prohibited.
Image Recording: Recording images or audio of minors for private purposes is prohibited. This includes allowing third parties to do so. Exceptions are made for official CKV purposes with parental consent, or under Art. 81(2) of the Copyright Act (where a person is merely a detail of a public event).
Illegal Substances: It is prohibited to offer or consume alcohol, tobacco, or illegal substances in the presence of minors.
Equality: The contributions of minors must be valued. They must be treated equally regardless of gender, origin, social status, creed, religion, or ideology.

§ 5

Online Conduct and Personal Relationships

Social Media: Staff are prohibited from establishing personal contact with CKV participants on social media (e.g., sending or accepting friend requests). Official CKV profiles are the only exception.
Official Channels: Communication with minors and their guardians must occur through official channels (work email, work phone).
Messaging Apps: Communication via official groups (e.g., Messenger or WhatsApp) is permitted only with guardian consent. Disclosure of intimate or sensitive information in such groups is strictly prohibited.
Confidentiality: In social or family settings, staff must maintain strict confidentiality regarding all information concerning minors and their representatives.

§ 6

Liability

Any violation of the rules set forth in this procedure constitutes grounds for disciplinary action or criminal liability.

Appendix No. 3:

to the Child Protection Policy

Child Protection Policy – Intervention Flowchart

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