Introduction
The Act of May 13, 2016, on Counteracting Threats of Sexual Crime and the Protection of Minors (Journal of Laws 2016, item 862) imposes an obligation on hotels, as entities providing hotel services, to implement protection standards.

Therefore, whenever the following terms are used:

a) Hotel – this refers to Hotel Pavco in Gorzów Wielkopolski, located at Targowa 2 Street.
b) Employee – this refers to a natural person who has an agreement with the operator of Hotel Pavco in Gorzów Wielkopolski – FutureInvest sp. z o.o. s.k., headquartered in Warsaw at Poznańska 21/48 Street, under which the natural person provides work for remuneration.
c) Personnel – this refers to the employees of the hotel.

#1
Rules Ensuring Safe Relationships Between Hotel Personnel and Minors, and Prohibited Conduct Towards Minors
  1. Minors have the right to be treated with equal care and respect by hotel personnel.
  2. Hotel employees are required to:
    a) Maintain a strictly professional relationship with minors, always ensuring that their reactions, communication, or actions towards minors are appropriate to the situation, i.e., safe and justified;
    b) Act in an open and transparent manner towards minors and third parties to minimize the risk of misinterpretation of their behavior;
    c) Not tolerate any behavior that may constitute bullying or mistreatment of minors by adults.
  3. The following behaviors by hotel employees towards minors are strictly prohibited:
    a) Any form of physical, psychological, or sexual violence, where:
    • Physical violence includes behaviors that pose a risk of non-accidental bodily harm, such as hitting, pulling, pushing, slapping, hair-pulling, or choking;
    • Psychological violence includes verbal aggression intended to cause fear and anxiety;
    • Sexual violence includes making references to sexual attractiveness, engaging in romantic or sexual relationships with minors.
      b) Taking or storing images of minors for personal purposes;
      c) Offering minors alcohol, tobacco products, or psychoactive substances, including selling them alcohol or alcoholic beverages from the hotel's offerings;
      d) Inviting minors into hotel staff-only areas or back-office spaces;
      e) Bringing minors into hotel rooms or guest-accessible hotel areas without a legal guardian;
      f) Being alone with a minor in a hotel room or other enclosed space, except in situations where leaving the minor alone could endanger their well-being, health, or life.
#2
Rules and Procedures for Identifying a Minor Staying in the Hotel
  1. The identification of a minor is carried out by the Hotel Reception staff.
  2. The identification process is conducted by:
    • Reviewing a document that allows for the determination of the minor’s identity[1];
    • Accepting a written statement from another person whose identity has been verified based on identification documents[2].
[1]Determining identity is not the same as verifying identity. To determine a person’s identity, it is sufficient to present a document marked with a number or series, containing the person’s photograph and the name of the issuing authority.
[2]Article 25 - Determination of the Identity of a Person Undergoing Identification. Act of December 8, 2017, on the State Protection Service (Journal of Laws 2024, item 325).

 

#3
Rules and Procedures for Identifying the Relationship Between a Minor and an Accompanying Adult in a Hotel
  1. The identification of the relationship between a minor and an accompanying adult is conducted by:
    a) Asking, during hotel check-in, about the nature of the relationship or kinship;
    b) Reviewing a document proving kinship, such as a birth certificate.
  2. If the minor’s last name differs from that of the accompanying adult, the receptionist must request a document confirming their relationship, such as a birth certificate or a name change document.
  3. If the accompanying adult is not the minor’s legal guardian, the receptionist must request:
    a) A valid court ruling granting guardianship over the minor;
    b) A written consent signed by the minor’s legal guardians, containing:
    • The minor’s full name and home address,
    • Contact details of the legal guardian for direct communication at any time,
    • Personal details of the accompanying adult, including at least their full name, PESEL number (or equivalent), and ID document number.

The above document must have a notarized signature confirmation.

In accordance with Article 6(1)(f) of the GDPR, data processing is lawful when it is based on the legitimate interests of the administrator. Therefore, the receptionist will make a copy of the document specified in point 3(b).

  1. If the accompanying adult cannot present one of the required documents listed in point 2, the receptionist must request a phone number for the minor’s legal guardian in order to verify the provided information directly.

The receptionist must inform the legal guardian about the processing of their personal data, the purpose of this processing (the minor’s protection), the data administrator, and where the full privacy policy can be accessed.

  1. If the accompanying adult refuses to cooperate in identifying the minor and their relationship, the receptionist must:
    a) First, notify a supervisor or the hotel director (if available);
    b) After consulting with the supervisor or director, inform the accompanying adult that the situation must be reported to the police;
    c) Contact the police to report the difficulty in identifying the minor and/or their relationship with the adult. The adult and minor must remain at the hotel until the police arrive.
    d) After the police arrive and verify the minor’s identity and relationship with the adult, the receptionist may proceed with the hotel check-in.

 

#4
Rules and Procedures for Responding to a Reasonable Suspicion That the Well-being of a Minor in the Hotel is at Risk
  1. Every hotel employee is required to:
    a) Pay special attention to situations that may raise concern or reasonable suspicion;
    b) Remain vigilant when the relationship between an adult and a minor does not appear to be natural and caring, when there are signs of violence towards the minor, or when the minor reports harm or asks for help.
  2. If there is a reasonable suspicion that the well-being of a minor staying at the hotel is at risk, every hotel employee must take appropriate action, including:
    a) Immediately notifying a supervisor of any observed irregularities;
    b) In urgent cases, and within the limits of applicable law, notifying the police.
#5
Procedures and Responsible Persons for Reporting Suspected Crimes Against Minors and Notifying the Guardianship Court
  1. Every hotel employee is obligated to report any suspicion of a crime committed against a minor.

  2. The report must be made immediately, first and foremost, to the hotel director, with notification to the employee’s direct supervisor.

  3. The report to the hotel director should be made verbally and, upon the director’s request, in writing.

  4. Through the hotel director, the report of suspected crimes against a minor must be promptly submitted to the Police or the Prosecutor's Office.

  5. The person responsible for submitting official reports on behalf of the hotel is the hotel director.

#6
Evaluation of Standards to Ensure Compliance with Current Needs and Regulations
  1. At least once every two years, the hotel will conduct an assessment of its standards to ensure their alignment with current needs and compliance with applicable regulations.

  2. The findings from the assessment will be documented in writing.