Minor Protection Standards

Child Protection Standards are procedures and rules designed to ensure the safety and protection of children and young people from abuse, violence and neglect. They prevent all forms of harm to minors and provide for responding when their rights may be violated. Child Protection Standards § 1. Preamble Pursuant to the Act of 13 May 2016 on preventing sexual crime and protecting minors, providers of hotel and tourist services and other collective accommodation facilities must introduce standards necessary to protect minors. Recognising business’s important role in respecting children’s rights, especially their dignity and freedom from all forms of harm, Dune Beach Resort adopts this document as a model of standards, rules and procedures where a child staying at Dune Beach Resort may be at risk, and to prevent such risks. § 2. General provisions

1. Dune Beach Resort Sp. z o.o. conducts its operations with the utmost respect for human rights, especially children’s rights, as they are particularly vulnerable to harm.
2. Dune Beach Resort Sp. z o.o. recognises its role in socially responsible business and promoting desirable social attitudes.
3. Dune Beach Resort Sp. z o.o. stresses the legal and social duty to notify law-enforcement authorities of every suspected offence against a child and undertakes to train its staff accordingly.
4. Dune Beach Resort Sp. z o.o. undertakes to educate staff about circumstances indicating that a child staying at the property may be harmed and how to respond promptly and appropriately.

§ 3. Definitions

1. Child/minor – any person under 18;
2. Harm to a child – committing a prohibited or punishable act against a child by anyone, including a staff member, or endangering the child’s welfare, including neglect. Any offence that may be committed against adults may also harm children; additionally, some offences can be committed only against children (e.g. sexual abuse under Article 200 of the Criminal Code). Given the nature of tourist facilities, where seclusion is easily obtained, the offences most likely to occur there concern sexual freedom and morality, especially rape (Article 197), sexual exploitation of insanity or helplessness (Article 198), sexual exploitation of dependence or a critical situation (Article 199), sexual exploitation of a person under 15 (Article 200), and grooming (enticing a minor through distance communication – Article 200a);
3. Child’s Guardian – a person authorised to represent the child, especially a parent or legal guardian. Under these standards, a foster parent is also a guardian;
4. Staff – a person employed by Dune Beach Resort Sp. z o.o. under an employment or civil-law contract, or a member of the organisation.

§ 4. Information policy

1. To obtain information about minors effectively without causing guests uncertainty or concern, every employee checking in or serving a guest must explain why the information is collected and how such action by the property contributes to children’s safety worldwide.
2. Accordingly:
   a) the law requires rules and procedures for identifying minors staying at hotels. Hotel properties must therefore verify a minor’s personal details and relationship to the guest;
   b) from 15 February 2024, Dune Beach Resort will identify minors;
   c) these identification rules serve to prevent harm to children.
3. A visible notice, preferably at or near reception, must state that the property cares about children’s safety and applies procedures protecting minors from harm.
4. The property also publishes information about the standards on its website and booking portals.

§ 5. Safe staff–child relations

1. Property employees must exercise due care to ensure the minor’s safety.
2. All staff actions must serve the child’s welfare and best interests. Staff treat children respectfully, taking account of their dignity and needs. Violence against a child in any form is prohibited.
3. Staff pursue these aims within applicable law, the institution’s internal rules and their competences. Safe staff–child relationship rules apply to all employees, trainees and volunteers.

§ 6. Identifying a minor

1. Reception staff identify the minor and the relationship with the guest by:
   a) requesting the minor’s identity card or other identity document, or proof of relationship, e.g. birth certificate, school ID or passport;
   b) asking additional questions during check-in where appropriate and the information provided raises staff doubts.
2. If the guest’s and minor’s surnames differ, the guest must additionally provide proof of relationship, such as the minor’s birth certificate or a document confirming a parent’s name change.
3. If the guest is not the minor’s parent, the guest must provide:
   a) a court decision granting custody of the minor,
   b) consent signed by the child’s parents, stating the child’s details and address, the parent’s telephone number, and the identity-document/PESEL number of the person entrusted with the child, or a parent’s notarised consent for that person to travel with the child.
4. If the guest does not provide or refuses to provide the above data and documents, reception staff may request the telephone number of the minor’s parent or legal guardian to contact them and confirm the guest’s information. The caller must be informed that their personal data are processed to protect the minor’s interests and given the controller’s details and information on where to read the full privacy notice.
5. If cooperation is refused, reception staff must inform their supervisor/property Director. Before speaking with the minor, the Director speaks with the adult to obtain the documents needed for identification.
6. The direct supervisor/property Director may also ask the minor about their relationship with the guest and the personal details of the minor and their parents or legal guardians, in a way that does not cause discomfort.
7. If doubts persist, the supervisor/Director notifies the Police. The adult and child should remain under staff observation until the Police arrive.
8. Copies, photographs or scans of the documents listed above are prohibited. Staff should instead make an official note or entry in the system or guest registration card recording the verification and the minor’s identification data obtained.

§ 7. Minor’s personal data collected during identification

1. Identification involves processing the child’s personal data contained in documents shown and provided by the hotel guest or telephone caller.
2. Staff may record and retain the following data:
   a) first name,
   b) surname,
   c) age or date of birth,
   d) PESEL number,
   e) address,
   f) parents’/legal guardians’ details,
   g) relationship with the hotel guest.
3. The minor’s personal data will be recorded on registration cards.
4. If the minor shows signs of disability or special educational needs, the note may also include this information.
5. If an interview with the minor is necessary, its purpose for collecting information must be explained in an age-appropriate, understandable manner.
6. Processing must not exceed the identification data listed above when carried out solely to identify and protect the minor.

§ 8. Procedure where circumstances indicate harm to a child

1. Where there is reasonable suspicion that a child staying at the property is being harmed, the Police must be notified immediately by calling 112 and describing the circumstances.
2. Reasonable suspicion exists when:
   a) the child discloses the harm to an employee,
   b) an employee witnesses the harm,
   c) the child has signs of harm (e.g. scratches or bruises) and, when asked, responds inconsistently and/or incoherently, becomes embarrassed, or other circumstances indicate harm, e.g. pornographic material involving children is found in an adult’s room.
3. In this situation, the child and the person suspected of harming the child must not be allowed to leave the Property.
4. Where justified, a citizen’s arrest of the suspected person may be made.
5. The child’s safety must be ensured in every case. The child should remain under an employee’s care until the police arrive.
6. If there is reasonable suspicion that a crime has been committed involving the child’s contact with the perpetrator’s biological material, the child should, where possible, be prevented from washing, eating or drinking until the police arrive.
7. After the police have taken custody of the child, CCTV footage and other relevant evidence must be secured.

§ 9. Preparing the Property’s employees to apply the procedure

1. The Property Director must train Property employees in applying the Procedure.
2. Training is conducted periodically, at least once per quarter.
3. At least once every two years, Dune Beach Resort Sp. z o.o. will assess the standards.

§ 10. Providing data to the Police If the Police or other authorised services are notified, the applicable provisions on providing personal data to state services shall apply to the provision of Guests’ and Minors’ personal data. § 11. Final provisions

1. The Standards will be assessed at least once every two years.
2. The Standards are available on the website www.dunebeachresort.com and at reception.

Information clause – for contacting the parent/legal guardian of a minor. Pursuant to Article 14 of Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR):

1. The controller of your personal data will be Dune Beach Resort Sp. z o.o., ul. Wojska Polskiego 24-26, 73-712 Koszalin. More information: https://www.dunebeachresort.com/prywatnosc
2. Contact with the Data Protection Officer: rodo@dunebeachresort.pl.
3. Purposes of processing: compliance with legal obligations (Article 6(1)(c) GDPR), protection of the minor’s vital interests (Article 6(1)(d) GDPR), and the controller’s legitimate interests (Article 6(1)(f) GDPR).
4. Data categories: first name, surname, PESEL/passport, address, telephone, email.
5. The full privacy policy is available at: www.dunebeachresort.com/polityka-prywatnosci