Minors Protection

I. Principles Ensuring Safe Relationships Between Hotel Staff and Minors, Especially Prohibited Behaviors Toward Minors

1. Minors have the right to be treated by hotel staff with equal care.
2. Hotel employees are obliged to:
   a) maintain exclusively professional relationships with minors, always considering whether the reaction, communication, or action towards the minor is appropriate to the situation, i.e., safe and justified;
   b) act openly and transparently towards minors and third parties to minimize the possibility of misinterpretation of behavior;
   c) not tolerate behavior that may constitute abuse or bullying of minors by adults.
3. The following behaviors by hotel staff towards minors are prohibited:
   a) behaviors involving physical, psychological, or sexual violence, where physical violence includes actions that risk intentional bodily harm, such as beating, pulling, pushing, slapping, hair pulling, choking;
   psychological violence refers to verbal aggression aimed at causing a sense of threat and fear[1];
   sexual violence refers to references regarding sexual attractiveness, initiating romantic or sexual relationships;
   b) using the image of a minor for the private needs of the employee;
   c) offering minors alcohol, tobacco products, psychoactive substances; in the case of alcohol – selling alcohol and alcoholic beverages from the hotel's offer to minors;
   d) inviting minors to restricted areas and premises of the hotel;
   e) allowing minors without a legal guardian into hotel rooms and other guest-accessible hotel areas;
   f) being alone in a hotel room with a minor except when leaving the minor alone could threaten their well-being, health, or life.
   
   [1] According to: National Centre for Addiction Prevention. Characteristics of domestic violence phenomenon. https://kcpu.gov.pl/przemoc/charakterystyka-zjawiska-przemocy-w-rodzinie/

II. Principles and Procedures for Identifying a Minor Present in the Hotel Facility and Their Relationship to the Adult Accompanying Them

1. Identification of the minor and their relationship to the adult is performed by the Hotel Reception staff.
2. Identification of the minor is done through:
   1) Reviewing a document allowing for identification[1] of the minor;
   2) Accepting a written declaration from another person whose identity has been established based on identity documents[2].
3. Identification of the minor's relationship to the adult is done through:
   a) Asking - during hotel check-in - questions about kinship and relationship,
   b) Reviewing a document indicating kinship, e.g., birth certificate.
4. In case of surname discrepancies between minor and adult - the Receptionist requests the presentation of a document confirming kinship between the adult and the minor, e.g., birth certificate, name change document, etc.
5. If the adult is not the legal guardian of the minor - the Receptionist requires:
   a) a valid court ruling on custody of the minor;
   b) written consent signed by the minor’s legal guardians including: - the minor's full name and address of residence, - contact details of the legal guardian enabling direct contact at any time, - personal data including at least full name, PESEL number, identity document number of the adult entrusted by the legal guardian with care of the minor. The mentioned document must bear notarized signature verification. According to Article 6(1)(f) GDPR: data processing is lawful when it is based on the legitimate interest of the administrator - the Receptionist will copy the document described in point 5.b).
6. In case of inability to provide one of the documents mentioned in point 5, the Receptionist requests the adult to provide the phone number of the minor's legal guardian to directly confirm information obtained from the adult accompanying the minor.
   The Receptionist informs the interlocutor about the processing of their personal data related to protecting the minor's interest, who the data controller is, and where they can review the full privacy notice.
7. If the adult refuses to cooperate in identifying the minor and their relationship to the adult, the Receptionist:
   a) first informs a supervisor or hotel manager - depending on availability,
   b) after consultation with a supervisor or hotel manager - informs the adult about the necessity of reporting the situation to the Police,
   c) notifies the Police about the situation and difficulties identifying the minor and/or relationship with the adult.
   The adult and minor should remain in the hotel until the Police arrive.
   d) After the Police arrive and identify the minor and relationship with the adult, the Receptionist may continue checking in guests.

[1] Establishing identity is not the same as confirming identity. To establish a person's identity, a document marked with number or series containing the person's photo and issuing authority is sufficient.
[2] Article 25. Establishing identity of a person being identified. Act of December 8, 2017 on the State Protection Service (Journal of Laws 2024.325)

III. Principles and Procedures for Responding in Case of Reasonable Suspicion that the Welfare of a Minor Present at the Hotel Facility is Threatened

1. Every hotel employee is obliged to:
   a) pay special attention to situations that may cause concern or reasonable suspicion;
   b) remain vigilant when the relationship between an adult and a minor is not relaxed and caring, when signs of abuse appear, when the minor reports harm or asks for help.
2. If there is a reasonable suspicion that the welfare of a minor staying in the hotel is threatened, every hotel employee is obliged to take appropriate action in response, in particular:
   a) immediately report observed irregularities to a supervisor,
   b) in urgent cases, within the limits of applicable law – notify the Police.

IV. Procedures and Persons Responsible for Filing Notifications of Suspected Crimes Against Minors and Notifying the Guardianship Court

1. Every hotel employee is obliged to report suspected crimes against minors.
2. Reports should be made immediately, first to the hotel manager, while notifying a supervisor. The report to the hotel manager should be verbal, and if requested by the manager, in written form.
3. Through the hotel manager, reports of suspected crimes against minors are promptly submitted to the Police or Prosecutor's Office.
4. The person responsible for submitting reports on behalf of the hotel is the hotel manager.

V. Evaluation of Standards to Ensure Their Adaptation to Current Needs and Compliance with Applicable Regulations

1. At least once every two years, the hotel will evaluate standards to ensure their adaptation to current needs and compliance with applicable regulations.
2. Findings from the conducted evaluation will be documented in writing.

Gudowo, (updated) March 26, 2026