§ 1
General Provisions

1. The Standards for the Protection of Minors at Integra Mente Centre for Cognitive-Behavioural Therapy, with its registered office in Kraków, at ul. Kochanowskiego 25/8, 31-127, and Rzemieślnicza 1/212, 30-363 (hereinafter also referred to as: the Centre) have been drawn up in accordance with the legal obligations imposed by the Act of 13 May 2016 on counteracting the risks of sexual offences and the protection of minors.
2. For the purposes of the Standards for the Protection of Minors, the following glossary of terms is established:
   a) harm to a minor – the commission of a prohibited act or a criminal offence (including an indecent act) to the detriment of a minor by any person, including a member of staff, or by endangering the welfare of a minor, including neglect;
   b) physical violence – the deliberate infliction of bodily harm or pain. Physical violence may result in all manner of physical injuries, including: fractures, bruises, cuts, burns and internal injuries;
   c) psychological abuse – any actions that have a negative impact on a minor’s mental well-being, including: repeated humiliation, belittling and ridicule; involving the minor in adult conflicts; manipulating the minor; a lack of adequate support or attention; and placing demands and expectations on the minor that they are unable to meet;
   d) sexual violence – the involvement of a minor in sexual activity by an adult. Sexual abuse refers to behaviours involving physical contact (e.g. touching a child, sexual intercourse with a child) and behaviours without physical contact (e.g. showing a child pornographic material, voyeurism, exhibitionism);
   e) minor – a person who has not reached the age of 18 or has not entered into marriage (as a result of which they have attained the age of majority);
   f) guardian – actual/legal guardian – a person authorised to represent and make decisions on behalf of a minor;
   g) the practice – a business jointly run by Helena Koziec under the name Helena Koziec Psycholog [Tax Identification Number (NIP): 6793013028] and Guillermo Villaescusa Eddy under the name Guillermo Villaescusa Eddy Psycholog [Tax Identification Number (NIP): 6793141476], providing psychological and psychotherapeutic services;
   h) management – the owner of the business, the practice manager, their deputy, the authorised representative and any persons with decision-making powers within the practice, regardless of their job title;
   i) staff – persons employed by, collaborating with or providing services to the Practice who are involved in the provision of healthcare services to minors or who may come into contact with minors or participate in the recruitment process, regardless of their profession and the legal basis for the provision of healthcare services or the performance of their duties;
   j) standards – these Standards in force at the Practice,
   k) employment – entering into a working relationship with any person on the basis of an employment contract or any other civil law contract.
3. Every member of staff and the Clinic’s management is obliged to comply with the Standards.
4. For the purposes of preventing harm to minors, staff and management shall take the actions specified in the Standards also in situations where they observe or receive information about harm being caused to a minor by adult third parties or by other minors.
5. The Head of the Office is responsible for the implementation, monitoring of compliance, evaluation of the implementation of the standards, and other tasks specified in the standards.
6. Before employing any person who will provide healthcare services to minors or assist in the provision of such services, it is necessary to check the Sex Offenders Register to ascertain whether that person is listed in the register.
7. Before employing a person who will provide healthcare services to minors or assist in the provision of such services, they must be required to provide a current certificate from the National Criminal Register regarding offences specified in Chapter XIX (offences against life and health) and XXV (offences against sexual freedom) of the Criminal Code, in Article 189a (trafficking in human beings) and Article 207 (abuse) of the Criminal Code, and in the Act of 29 July 2005 on counteracting drug addiction, or for prohibited acts corresponding to these offences as defined in the laws of foreign states.
8. When employing a foreign national, a check must be carried out to ascertain whether they appear in the criminal records of their country of origin or the country in which they most recently resided, in respect of the offences specified in paragraph 7 or corresponding prohibited acts punishable under the law of that country. The Head of the Office is also authorised to require the foreign national to submit a relevant declaration of no criminal record. Such declarations are made under penalty of criminal liability for making a false statement.
9. Only those individuals who are not listed in the Register of Sex Offenders and who have provided a current certificate from the National Criminal Register confirming that they have not been convicted of the offences referred to in paragraph 7 may be employed by the Clinic.
10. Every member of staff is required to familiarise themselves with the standards and to comply with them. A member of staff confirms that they have familiarised themselves with the standards by submitting a declaration stating that they have read the standards and undertake to comply with them.
11. At least once a year in December, the Clinic Manager shall:
    a) review the Register of Sex Offenders (rps.ms.gov.pl) to ascertain whether any member of staff who provides healthcare services to minors or participates in the provision of such services at the Clinic has been entered in that register;
    b) shall obtain a declaration from any member of staff who provides healthcare services to minors or participates in the provision of such services at the Practice, stating that they have not been entered in the National Criminal Register in respect of the offences specified in paragraph 7 and that no pre-trial or court proceedings are pending against them in relation to those offences.
12. Where information is received regarding:
    a) the initiation or conduct of criminal proceedings against a member of staff in respect of offences specified in paragraph 7, the Head of the Office shall immediately remove that member from all contact with minors;
    b) the conviction of a member of staff for an offence or offences specified in paragraph 7, the Head of the Office shall immediately terminate the contract forming the basis of their employment or remove them from their post.

§ 2
Guidelines for interacting with minors at the Clinic

1. The fundamental principle guiding the actions of the Clinic’s staff and management when dealing with minors is to act in their best interests and to ensure their safety whilst they are at the Clinic.
2. Staff members and management:
   a) treat minors with respect, remaining calm and patient when interacting with them, and show understanding for their difficulties, problems and needs;
   b) treat every child with due respect;
   c) support them in overcoming difficulties;
   d) ensure that their rights as patients are upheld;
   e) respect their right to care from legal representatives or actual carers;
   f) where possible, explain the actions being taken in a manner appropriate to their age, whilst striving to minimise the fear and anxiety arising from the situation, and seek their consent for the healthcare services provided;
   g) give the minor the opportunity to express their opinion and ensure the minor’s right to be heard;
   h) treat all minors equally, regardless of gender, sexual orientation, social, ethnic, cultural or religious status, or worldview.
3. Any member of staff at the Clinic who is aware that a minor has been subjected to physical or psychological abuse or sexual exploitation is required to exercise particular caution and sensitivity when dealing with that minor.
4. If a minor’s behaviour seeks to establish physical contact with a member of staff that is potentially inappropriate or inappropriate in nature, staff shall take appropriate, firm action, sensitively explaining to the minor the need to respect personal boundaries.
5. Consent from a guardian must be obtained for the treatment of a minor patient in accordance with Polish law.
6. During the treatment of a minor patient, they must be provided with a level of privacy appropriate to their age, needs and expectations.
7. The minor should be encouraged to adopt an assertive attitude, express their own opinions and communicate their feelings.
8. The minor and their guardian should be informed of the possibility of reporting any inappropriate behaviour by a member of the Clinic’s staff towards the minor, including any words spoken, gestures made or other conduct that caused a feeling of discomfort or concern, or was offensive or hurtful.
9. The minor and their guardian may report such incidents to any member of the Clinic’s staff, who is obliged to notify the Manager or the person responsible for implementing the Standards.
10. Members of the Clinic’s staff shall be alert to risk factors and signs of harm to minors.

§ 3
Prohibited behaviour

1. It is prohibited to use any form or manifestation of violence against minors – whether physical, psychological or verbal.
2. It is prohibited to exploit a relationship of authority or physical superiority over a minor (e.g. intimidation, coercion, threats).
3. It is prohibited to touch minors in a manner that could be misinterpreted or that goes beyond the legitimate needs of therapy.
4. It is prohibited to show minors content of an erotic, pornographic or violent nature.
5. It is prohibited to mock minors, humiliate them, label them or treat them unequally.
6. It is prohibited to disclose sensitive information concerning a child to unauthorised persons.
7. Physical contact with a minor must never be secret or concealed, nor involve any form of reward, nor arise from a relationship of power or authority.
8. Staff must not contact a minor directly without involving their guardian. As a general rule, any contact between staff and a minor patient should take place exclusively in the consultation room, during working hours, and relate to matters falling within the scope of the staff’s duties.
9. Staff must not establish contact with a minor in any form other than that provided for the provision of psychotherapeutic services, in particular by inviting or accepting invitations from minors on social media, instant messaging platforms or via other private forms of contact.
10. Staff must also not invite a minor to their place of residence or meet with them outside the Clinic’s opening hours.

§ 4
Rules and procedures for intervening in cases of suspected harm to a minor, and the person responsible for receiving reports and notifying the relevant authorities

1. In the event of observing or receiving information regarding:
   a) a situation involving violence or abuse of a minor – every member of the Clinic’s staff or management is obliged to react immediately, with the aim of stopping the prohibited behaviour and ensuring the protection of the minor;
   b) behaviour giving rise to suspicion of violence or abuse of a minor – every member of the Clinic’s staff or management is obliged to report this to the Clinic Manager;
   c) breaches of standards – every member of the Clinic’s staff or management is obliged to report suspected breaches to the Clinic Manager without delay.
2. The management or staff of the Centre shall intervene upon receiving information about harm to a minor or a suspicion of harm to a minor, and shall summon the parents/guardians of the child in respect of whom there is a reasonable suspicion that they may have been or are being harmed, and inform them of the suspicions.
3. Suspected breaches of standards, in particular involving harm to minors, may be reported to Helena Koziec or via the dedicated email address: centrum@integramente.pl
4. The Head of the Office shall endeavour to investigate immediately any report of suspected harm to a minor by a member of staff, taking all necessary measures. The Head of the Office shall document the measures taken.
5. Where a report is made regarding a suspicion that a member of staff has harmed a minor, that member of staff is immediately removed from all contact with minors until the matter has been clarified.
6. If it is observed that a minor’s carer is neglecting their psychological or physical needs, or that the family is failing in their parenting responsibilities, using violence against the minor or condoning its use, or is otherwise harming the minor or unable to cope, measures appropriate to the situation must be taken.
7. In the situation described in paragraph 5, in the case of:
   a) poverty – one may speak to the minor’s carer and inform them of available support, in particular regarding social welfare centres, and draw up a support plan,
   b) neglect – one may inform them of the possibility of psychological support, in particular regarding helplines and specialist counselling centres, and draw up a support plan;
   c) violence – the Blue Card procedure may be initiated and a support plan drawn up.
   The support plan is presented to the child’s parents/legal guardians with a recommendation to cooperate in its implementation.
8. If it becomes apparent from a conversation with the guardian that they are not interested in helping the minor, are ignoring the incident or the minor’s mental or physical condition, or are otherwise failing to support the minor who has suffered harm, the staff or manager of the Centre shall draw up a request for an investigation into the family’s situation, which they shall submit to the competent family court. A note shall be made of the application.
9. Where there is a suspicion that the minor’s health or life is at risk, or where there is reasonable suspicion that a crime has been committed against the minor, the staff/manager of the Centre shall draw up a report of a suspected crime and forward it to the local police or public prosecutor’s office.
10. Information regarding the intervention taken is included in the minor’s records.
11. The facility maintains a Register of incidents threatening the welfare of minors.
12. In the area where psychotherapy involving minors is conducted, information on national helplines for victims of crime and domestic violence is displayed in a space accessible to patients:
    a) national helpline for victims of crime +48 222 309 900;
    b) National Emergency Helpline for Victims of Domestic Violence “Blue Line” 800 120 002;
    c) Helpline for Children and Young People 116 111.

§ 5
Rules for updating the Standards and the scope of responsibilities of those tasked with training staff members in their application

1. The Head of the Clinic shall review the Standards at least once a year to ensure they are adapted to current needs and comply with applicable regulations. The findings of this review must be documented.
2. Staff members, minors or their legal representatives may submit their comments on the Standards to the Practice Manager, including via email to: centrum@integramente.pl
3. The Practice Manager may assess staff members’ knowledge of the Standards and organise training on the Standards.
4. Before commencing therapy, staff shall present the content of the standards to the parents of the minor who is to undergo therapy at the Clinic.

§ 6
Rules governing the provision of the Standards to parents or legal or de facto guardians, and to minors, for their perusal and application

1. The Standards are a publicly available document. The Standards are available:
   a) at the reception or in the waiting room of the Practice,
   b) on the Practice’s website at: integramente.pl
2. Any minor or guardian of a minor may receive a copy of the Standards for inspection. The Standards shall be provided by the Clinic’s staff/manager immediately upon such a request being made.
3. A summary version of the Standards, containing information relevant to minors, has been drawn up based on the Standards. The summary version of the Standards forms an appendix to the Standards.

§ 7
Guidelines for drawing up a support plan for a minor following the disclosure of harm

1. Following the disclosure of harm to a minor, the staff/manager of the Centre shall draw up a support plan in consultation with the minor’s guardian, provided that the guardian is not the perpetrator of the harm.
2. Where possible, once the support plan has been drawn up, the staff/manager of the Centre shall listen to the minor’s views and take them into account.

§ 8
Rules on the protection of minors’ images

1. The personal data of minors is protected in accordance with 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).
2. The image of a minor is protected.
3. The publication of a minor’s image recorded in any form (i.e. photograph, audio-video recording) requires the written consent of the minor’s guardian and the minor themselves.
   If the image of a minor constitutes only a detail of a whole, such as a gathering, a landscape or a public event, the guardian’s consent to the recording of the minor’s image is not required.
4. The image of a minor recorded by CCTV cameras used to record footage for the purpose of ensuring the safety of persons and property within the Office shall not be made public and does not require the consent of the minor’s guardian for the recording of their image. The use of material recorded in this way is limited exclusively to the purposes originally specified for its recording.

§ 9
Final provisions

1. The Standards applicable to persons employed by the Office have the force of internal regulations, which they are obliged to comply with.
2. The Standards shall enter into force on the date of their announcement. The Standards shall be announced by publishing them in the form specified in the Standards.
3. The Head of the Office is authorised to amend the Standards. Amended Standards shall enter into force on the date of their announcement in the manner specified in the Standards.