POLICY ON THE PROTECTION OF MINORS
IN THE DENTAL SURGERY RUN BY PROMEDICA DENTAL AND MEDICAL CENTRE JOANNA MARKIEWICZ BASED IN BĘDZIN

The development and introduction of this Policy fulfils the legal obligation to introduce standards for the protection of minors in the treatment facility, in accordance with the Act of 13 May 2016 on counteracting the threat of sexual offences and the protection of minors. The guiding principle of all actions taken by the staff and associates of Our facility is to act for the benefit of the child and in his/her best interests. All staff and associates treat the child with respect and take into account the needs of the child, seeking to protect them from violence in any form. We achieve these aims by acting within the framework of the applicable law, internal regulations and our own competences.

Chapter I - Objectives and definitions
§ 1.

The Policy aims to:

• Ensure all children are protected from abuse and establish procedures to support them.
• Ensure that all staff have the necessary information and competencies to enable them to discharge their responsibilities to look after the welfare of the child and protect children from violence.
• Ensure that children and their parents or carers have the necessary information about the entity's policies and how to get support if they suspect that a child is experiencing abuse.

§ 2.

Terms used in this document mean:

1. 1. Facility / treatment provider / Practice - a dental practice run by: CENTRUM DENTYSTYCZNO-LEKARSKIE PROMEDICA JOANNA MARKIEWICZ (NIP 6442865295) based in Będzin, ul. Piłsudskiego 99.
   2. Policy - this document and/or the actions taken pursuant to it;
   3. Employee - a person employed by the organisation under an employment contract, a civil law contract, as well as co-workers and apprentices and volunteers;
   4. Management - the person or body who, in accordance with applicable law and/or internal documents, has the authority to make decisions about the entity's activities.
   5. Minor/Child - any person under the age of 18;
   6. Child's guardian - a person entitled to represent the child, in particular the child's parent or legal guardian, including a foster parent;
   7. Guardian's consent - the agreement of at least one of the child's guardians. However, if there is disagreement between them, the guardians must be informed that the matter must be decided by the family court;
   8. Child abuse - the commission of a criminal act or a criminal act to the detriment of a child by any person, including an Employee, or a threat to the welfare of a child, including neglect of a child. Child abuse is, in particular, physical, emotional or sexual abuse. Neglect is the failure of a parent or legal guardian to meet a child's basic material and emotional needs, i.e. safety, adequate food, clothing, shelter, medical care;
   9. Responsible person - the designated Employee of the organisation who supervises the implementation of this document;
   10. Child's personal information - any information that enables a child to be identified.

Chapter II - Obligations of the organisation prior to engaging an Employee
and during its
§ 3.

1. Before entering into an employment relationship or any other type of cooperation with an Employee in the field related or likely to relate to contact with minors, in particular related to the treatment of minors, the institution shall obtain information on whether the Employee's details appear in the Register of Sexual Offenders, hereinafter referred to as the Register, or in the Register of persons in respect of whom the State Commission for the Prevention of Sexual Exploitation of Minors under 15 years of age has issued a decision on entry in the Register.
2. The employee submits:
   1. information from the National Criminal Register with respect to offences specified in Chapters XIX and XXV of the Penal Code, in Articles 189a and 207 of the Penal Code and in the Act on Counteracting Drug Addiction, or for corresponding offences under foreign law.
   2. An employee with a non-Polish nationality shall submit the criminal record information of the country of nationality obtained for the purposes of activities related to contact with children, or if that country does not provide for such information, the criminal record information, or if the country does not maintain such a record, the statement referred to in Article 21(7) of the Act on Counteracting the Risk of Sexual Offences.
   3. a statement of the countries in which he/she has resided during the last 20 years other than the Republic of Poland and the information from these countries referred to in point b.
3. The declaration under paragraph 2(b) and (c) shall be made under penalty of false declaration.
4. The information in paragraphs 1 and 2 shall be recorded in hard copy in the personnel file or in the records relating to the admission to activities involving contact with minors.
5. The model statements indicated in this paragraph are attached as Appendix 1.
6. In order to monitor safety in the establishment, in addition to fulfilling the obligation set out in the preceding paragraphs, the establishment (responsible person) shall check the Employee's inclusion in the Register each year. It may also collect a declaration of non-registration in the National Criminal Register to the extent indicated above.
7. If you become aware that an Employee has been prosecuted for an offence against sexual liberty or a violent offence committed against children, you should immediately remove them from all contact with children and move them to a job where there is no such contact or consider terminating their contract.

Chapter III
Recognising and responding to risk factors for child abuse.
Principles for safe employee relations with children
§ 4.

1. The worker is knowledgeable and pays attention to risk factors for child abuse as part of her duties.
2. Where risk factors have been identified, Care Workers engage in conversation with the child's Carers, providing information on the support available and motivating them to seek help for themselves.
3. Where risk factors are identified within the organisation, the staff shall communicate this information to the person in charge or to the management of the organisation and, where the risk factors concern the management of the organisation, to the relevant control, local authority or service.

§ 5.

1. Staff are concerned with the safety of the children while in the Cabinet and keep an eye out for any signs of danger or discomfort.
2. Parents are also responsible for ensuring the safety of children and supervising their behaviour in the Cabinet, both during the visit and in the waiting room.
3. When taking action towards children, staff members have only their best interests and the improvement of their health in mind.
4. Staff treat the child with respect and take into account the child's dignity and needs. Violence against a child in any form is not permitted, including shouting, belittling, humiliating and insulting children is prohibited.
5. The staff maintain professionalism, transparency, patience and show understanding in their relationship with the children.
6. Staff ensure that the rights of the patient are respected in relation to the child.
7. All patients are treated fairly. Staff do not divide or discriminate (including on the basis of age, gender, financial status, physical appearance, knowledge, skills, medical condition, including disability) between children coming to the Surgery.
8. For the examination of the child, the consent of the child's Guardian or other person entitled according to Polish law must be obtained.
9. The examination of a minor should be performed in the presence of his/her Guardian and, when this is not possible, in the presence of another Employee Employees are obliged to allow the Guardian to be present during the child's diagnostic and therapeutic activities. This is the most important element that provides the minor patient with the necessary sense of safety and comfort. In addition, it is the persons caring for the minor who are most familiar with the minor's needs and behaviour.
10. Staff should, as far as possible, take into account the reported individual needs of the minor patient to ensure additional comfort in the use of health services, as long as these do not conflict with the proper provision of health services (e.g. the right to bring a small toy, mascot, etc.).
11. Medical staff should allow a minor patient to express his or her opinion on the health care services planned or provided to him or her. A patient over the age of 16 has the right to full medical information and to decide on the diagnostic and therapeutic process.
12. Staff should be understanding in their dealings with minor patients, their Carers bearing in mind that in some situations they may be outside their comfort zone, especially during health services such as tooth extraction or treatment of a patient presenting with increased pain.
13. Any behaviour by staff aimed at causing fear, a sense of threat or coercion in a minor patient during the provision of health services is not allowed. It is not allowed to force a minor patient to behave in a certain way or to cooperate with medical staff by means of shouting. The employee should not allow such methods to be used also in the facility by Caregivers.
14. When interacting with a child who is a victim of Child Abuse, Workers exercise extreme caution and tact.
15. Employees may not capture images of children for private purposes.
16. Staff in physical contact should respect the privacy and intimacy of the child. Physical contact should always be justified, including the type of activity undertaken with ongoing explanation of the need for contact. Wherever possible, contact with the child should be in public.
17. Where a child seeks to engage in physical contact of a potentially inappropriate or inappropriate nature, the Worker shall take firm action to counter this.
18. Staff do not contact children through private communication channels without the knowledge of their Legal Guardians, particularly for purposes other than those related to the activities of the establishment, including the use of social media.
19. If a private conversation including social media is started by the child himself/herself, the member of staff shall not continue the conversation and shall instruct the child to report to the establishment or using official communication channels. This rule does not apply to situations of (even potential) danger to the child's life and health. In such a case, the staff member may continue the conversation, but must at the same time inform the Person in Charge or the management of the establishment of the contact with the child and the reasons for this contact.
20. Employees exercise caution and restraint in welcoming and inviting children to social media contacts.

§ 6.

1. In a situation where there is a risk of accident or injury to a child, the Cabinetry staff have the right:
   1. firmly but not violently move the child away from the source of danger;
   2. take the child out or take the child to a safe place;
   3. If possible, explain to the child the reasons for their actions.
2. In a situation where a child's life is at risk, Cabinet staff have the right:
   1. give the child the necessary assistance;
   2. administer appropriate medication;
   3. take all necessary and reasonable steps to save the life and health of the minor.

Chapter IV
Procedures for intervention in situations of suspected child abuse
§ 7.

1. Each Employee shall pay attention to signs, symptoms and traces of suspected abuse of a minor patient.
2. Every Employee is obliged and entitled to respond if they suspect that a minor patient is being abused.
3. The source of the child's harm can be the behaviour of the parents, legal guardians, another person close to the minor, as well as the behaviour of third parties.
4. Harm to a minor child may manifest itself in particular through:
   - the commission of an offence against a minor (e.g. physical violence, sexual abuse),
   - harm in other ways (e.g. psychological violence, intimidation, humiliation),
   - evident neglect of living, subsistence and hygiene needs (malnutrition, lack of hygienic conditions, failure to provide necessary care, lack of clothing).
   In the case of an intervention by an Employee, an intervention card is drawn up according to the model in Appendix 2.
5. In case of suspicion that a crime has been committed against a minor patient, a report shall be made to the Police or the Public Prosecutor's Office. In case of suspicion that the life or health of a minor patient is endangered due to domestic violence against him/her, the Worker shall immediately report this fact to the Police.
6. Any information concerning suspected abuse of a minor patient shall be reported by the staff of the medical facility to the head of the facility or a person authorised by him/her.
7. It is the responsibility of the head of the medical establishment or a person authorised by him/her to initiate the relevant procedure relating to suspected child abuse and to notify the competent public authorities, with the proviso that the Blue Cards procedure can only be initiated by a medical professional at the medical establishment.
8. In other cases of suspected abuse of a minor patient (e.g. neglect of the child's living, subsistence and hygiene needs), the medical facility may apply to social welfare units for support or to the family court for insight into the child's situation and insight into the family.
9. Further proceedings shall be the responsibility of the institutions and persons referred to in the preceding paragraphs. The procedures described above shall apply mutatis mutandis.

§ 8.

1. Where it has been reported that a child has been abused by a Worker, that person shall be immediately removed from all contact with children until the matter is investigated.
2. Where an Employee has perpetrated a form of abuse against a child other than committing a criminal offence against the child, management should investigate all the circumstances of the case, in particular hearing from the employee suspected of abuse, the child and other witnesses to the incident.
3. Where the violation of a child's welfare is significant, in particular where there has been discrimination or a violation of the child's dignity, consideration should be given to terminating the legal relationship with the abuser. If the staff member who committed the abuse is not directly employed by the establishment, but by a third party, then a recommendation should be made to ban that person from the establishment and, if necessary, terminate the relationship.

Chapter V
Rules on the protection of personal data and the child's image
§ 9.

1. The facility ensures the highest standards of protection of the child's personal data in accordance with the applicable legislation, in particular in accordance with the principles set out in the 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) (OJ EU. L. 2016, No. 119, p. 1, as amended) and the Act of 6 November 2008 on the rights of the patient and the Patient Ombudsman.
2. An employee of the organisation has a duty to maintain the confidentiality of the personal data he/she processes and to keep the means of securing the personal data against unauthorised access confidential. Violation of this duty may lead to immediate (including disciplinary - in the case of employees) termination of the contract.
3. The child's personal data is only made available to persons and entities authorised under separate legislation.
4. Access to the child's personal data, in particular sensitive data, is only granted to Employees for whom this is necessary due to the activities performed.
5. The member of staff shall not provide media representatives with information about the child and their carers, nor shall the member of staff contact media representatives with the child unless the child's carer agrees.

§ 10.

1. The establishment, recognising the child's right to privacy and protection of personal rights, ensures that the child's image is protected.
2. The recording and publicising of a child's image requires the written consent of the child's Guardian.
3. The consent should indicate where the registered image will be placed and in what context it will be used (e.g. for promotional purposes).
4. If the image of the child is only a detail of a whole, such as a gathering, a landscape, a public event, the consent of the parent or legal guardian for the recording of the child's image is not required.
5. The capture and publication of children's images should be done within the following guidelines:
   1. Image enhancement should be linked to the activities of the organisation;
   2. Children should be dressed;
   3. The recorded image should focus on the activities of the facility and, where possible, include other people, including adults.
   4. Only children's first names should be used and details of where they live or their interests should not be revealed;
   5. If possible, ask the child for permission to publish the image.

Chapter VI
Rules on the use of electronic devices with Internet access
§ 11.

1. The establishment does not, as a rule, provide children with access to the Internet from its own resources.
2. Where children are exceptionally provided with internet-enabled devices, the establishment is obliged to provide safeguards to prevent children from accessing content that may pose a risk to their proper development, in particular, malware protection and content filtering software should be installed and updated.
3. In the cases indicated in paragraph 2, the use of the Internet shall only take place under the supervision of a Staff Member, who shall supervise the safe use of the Internet by children.
4. The Child and Carer are prohibited from using internet-connected devices during treatments.
5. The Guardian is responsible for minors' use of private devices with Internet access in the Cabinet waiting room.
6. If Employees observe that a child is viewing adult content or harmful content on a private device, they shall notify the Guardian. If the Guardian does not respond, the Staff member may request the Guardian to leave the Cabinet with the child so as not to expose other minors to harmful content.

Chapter VII
Monitoring the application of the Policy
§ 12

1. The management of the facility shall appoint a person responsible for the application of this document.
2. The Responsible Person is responsible for monitoring the implementation of the Policy, responding to signals of violations of the Standards and for proposing changes to the document, preparing employees to apply the Standards and familiarising them with their content.
3. The fact that employees are familiar with the contents of the Policy and the applicable standards is confirmed by a statement made by the Employees.
4. If necessary, the Responsible Person shall conduct a survey among Employees to monitor the level of application of the Policy. A model questionnaire is attached as Annex 4.
5. The responsible person processes the questionnaires completed by the employees. The responsible person prepares a monitoring report on the basis of the completed questionnaires and submits it to the organisation's management.
6. The organisation's management, after reviewing the report and the comments and proposals for changes to the Policy, makes the necessary changes to the Policy and announces the new wording of the Policy to Employees.

Chapter VIII
Final provisions
§ 13

1. The standards enter into force on the date of publication.
2. The announcement shall be made in a manner that is accessible to the Employees of the establishment, in particular by displaying it in the notice area for Employees and colleagues or by sending it electronically.
3. Every Employee is required to observe and apply the Standards. Every person employed in a medical facility, regardless of the legal form in which he or she is employed, acknowledges in writing that he or she has read these Standards for the Protection of Minors and undertakes to apply them.
4. These Standards for the Protection of Minors are reviewed at least once every two years to assess their relevance to current needs, the type and scale of activity of the medical facility and their compliance with regulations. The conclusions of the analysis will be each time the basis for a possible revision of the Policy. An abridged version of this Policy is also prepared, where the contact numbers at which a child may obtain assistance are also indicated, i.e:
   - national telephone hotline for victims of crime +48 222 309 900;
   - National Emergency Service for Victims of Family Violence "Blue Line" 800 120 002;
   - Helpline for Children and Young People 116 111.
   - police 112
5. This document is available for inspection at the centre's premises and is posted on the centre's website in a way that allows parents, legal or actual guardians of children and children to have free access to the Policy.

Annex 1

Annex 2

Annex 3

Annex 4

POLICY ON THE PROTECTION OF MINORS
IN THE DENTAL SURGERY RUN BY PROMEDICA DENTAL AND MEDICAL CENTRE JOANNA MARKIEWICZ BASED IN BĘDZIN
(ABRIDGED VERSION)

The development and introduction of these protection standards is the fulfilment of the legal obligation to introduce standards for the protection of minors in the treatment facility, in accordance with the Act of 13 May 2016 on counteracting the threat of sexual offences and the protection of minors. The guiding principle of all actions taken by the staff and associates of Our facility is to act for the benefit of the child and in his/her best interest. All staff and co-workers treat the child with respect and take into account his or her needs, trying to protect him or her from violence in any form These goals are pursued by acting within the framework of the applicable law, internal regulations and their competences.

General provisions:
The duty to comply with the Policy on the Protection of Minors rests with each Employee and the management of the Cabinet.
For the purpose of preventing abuse of minors, the Employee l and the management shall also take the actions set out in the standards when they observe or become aware of abuse of a minor by adult third parties or by other minors.
The employer will carry out the vetting of applicants to work with children under the new legislation.

Safe relationships between the minor and staff:
Staff and management:

• treat the minors with respect, remaining calm and patient in their dealings with the minors and showing understanding of their difficulties, problems and needs;
• ensure that their rights as patients are respected; - respect their right to care by their legal representatives or actual guardians;
• explain to them, where possible, the actions taken and seek approval for the health services provided;
• provide an opportunity for the minor to express his or her opinion and ensure the minor's right to be heard.

Filing of reports of offences against a minor:

• Any Employee who suspects child abuse shall report it immediately to the Unit Manager.
• The management of the unit seeks to promptly investigate a report of suspected abuse of a minor by a member of staff, taking all necessary action. The action taken shall be documented.
• In case of suspicion that a crime has been committed against a minor patient, the Police shall be notified. In case of suspicion that the life or health of a minor patient is at risk due to domestic violence against him/her, the Worker shall immediately report this to the Police.

Remember that you are not alone!
If you are being harmed or witness another child being harmed then contact the Cabinet Workers immediately. You can also call for help:
- national telephone hotline for victims of crime +48 222 309 900;
- National Emergency Service for Victims of Family Violence "Blue Line" 800 120 002;
- Helpline for Children and Young People 116 111.
- police 112