Hotel Regulations
Hotel DAL Kielce
Information Clause on the Protection of Personal Data
Pursuant to Article 13(1) and (2) of 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 (hereinafter the “GDPR”), Dekom Sp. z o.o. provides the following information:
1. Controller of personal data
The Controller of your personal data is Dekom Sp. z o.o., with its registered office in Gdańsk at ul. Wały Piastowskie 24, 80-855 Gdańsk (hereinafter: Dekom).
Inspector for the Protection of Personal Data
Correspondence concerning matters related to the protection of personal data should be addressed to the Inspector for the Protection of Personal Data appointed by Dekom:
• by post to Dekom’s registered office address,
• by email to: iod@auraco.pl
2. Purposes and legal bases for the processing of personal data
Personal data will be processed for the purpose of carrying out the recruitment process, on the following legal bases:
• pursuant to Article 6(1)(c) of the GDPR, with regard to the personal data listed in Article 22¹ of the Labour Code (first name and surname, date of birth, contact details provided by the job applicant, education, employment history, professional qualifications);
• pursuant to Article 6(1)(a) of the GDPR, with regard to data voluntarily provided by the applicant that goes beyond the above-mentioned scope, as well as where personal data is processed as part of future recruitment processes;
• pursuant to Article 6(1)(f) of the GDPR, for the purposes of pursuing the legitimate interests of the Controller, including determining the job applicant’s expectations, verifying skills and qualifications, and demonstrating Dekom’s performance of its obligations should a legal necessity arise.
3. Recipients of personal data
The personal data obtained from you may be transferred to:
• other entities to which Dekom has entrusted the processing of personal data;
• public authorities or entities authorised to obtain data under applicable law, e.g. courts, law enforcement authorities or state institutions, when they submit a request based on an appropriate legal basis;
4. Period of processing of personal data
Your personal data will be processed until the end of the recruitment process, and if you consent to the processing of personal data for the purposes of future recruitment processes, until you withdraw your consent or 12 months have elapsed from the date on which it was given.
5. Rights of data subjects:
Under the GDPR, you have the right to:
• access your personal data
• request the rectification of your personal data that is inaccurate and the completion of incomplete personal data
• request the erasure of your personal data
• request the restriction of the processing of your personal data
• object to the processing of your data on grounds relating to your particular situation, where we process your data on the basis of our legitimate interest or for direct marketing purposes
• data portability
• lodge a complaint with the supervisory authority responsible for the protection of personal data, i.e. the President of the Personal Data Protection Office, with its registered office in Warsaw at ul. Stawki 2.
To the extent that your data is processed on the basis of consent, you have the right to withdraw your consent to the processing of your data at any time. Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of your consent before its withdrawal. You may withdraw your consent by sending a declaration of withdrawal of consent to our correspondence address or email address.
6. Information on the requirement/voluntary nature of providing personal data
With regard to data processed pursuant to Article 6(1)(c) of the GDPR, providing personal data is a condition for participation in the recruitment process. In all other respects, providing data is voluntary.
7. Automated decision-making
Dekom will not make automated decisions concerning you based on your personal data, including decisions resulting from profiling. Dekom does not transfer your personal data to a third country (i.e. a country that is not part of the European Economic Area, comprising the European Union, Norway, Liechtenstein and Iceland) or to international organisations.
INFORMATION ON THE PROCESSING OF PERSONAL DATA FOR PURPOSES RELATED TO THE PROVISION OF SERVICES, INCLUDING HOTEL, CATERING, CULTURAL AND ENTERTAINMENT SERVICES, RENTAL OF EQUIPMENT AND RESERVATION OF PARKING SPACES
The administrator of your personal data is Dekom Sp. z o. o. with its registered office in Gdańsk, address: ul. Wały Piastowskie 24, 80-855 Gdańsk (hereinafter: DEKOM, the Company).
For what purpose and on what basis will DEKOM process personal data?
Your personal data will be processed for the purpose of:
a) providing hotel and catering services, equipment rental services, and parking space reservations – on the basis of Article 6(1)(b) of the GDPR (data processing is necessary for entering into and performing a contract) and Article 6(1)(c) of the GDPR in connection with the provisions of the Accounting Act;
b) providing entertainment services, including admission to conference rooms, reading rooms, and children’s playrooms – on the basis of Article 6(1)(b) of the GDPR (data processing is necessary for entering into and performing a contract) and Article 6(1)(c) of the GDPR in connection with the provisions of the Accounting Act;
c) in the case of payment with the Polish Tourist Voucher (Polski Bon Turystyczny) in accordance with the Act of 15 July 2020 on the Polish Tourist Voucher – information about eligibility for providing the service will be processed for the purpose of executing and verifying the payment on the basis of Article 6(1)(f) of the GDPR, where the Company’s legitimate interest is settling the payment with the Social Insurance Institution (Zakład Ubezpieczeń Społecznych) and obtaining a reimbursement of amounts due.
d) pursuing any claims by DEKOM related to harm sustained by the Company caused by the Hotel guest, or defending against the guest’s claims against the Hotel – on the basis of Article 6(1)(f) of the GDPR;
DEKOM will share your personal data with other entities entrusted with processing personal data on behalf of and for the Company, in particular with providers of teleinformatics solutions.
For the purpose of reservation handling, DEKOM may share data and obtain data from entities operating the following portals: booking.com, hrs.com, expedia.com, noclegi.pl, ptqv.pl, triverna.pl, eTravel.pl, nocowanie.pl.
DEKOM will make personal data available to other recipients if such an obligation results from applicable legal provisions.
Your personal data will not be transferred to third countries or international organizations.
How long will DEKOM process data?
Personal data will be processed for a period of 6 years from the date of completion of the stay/service.
What rights do you have as the data subject?
You have the right to:
• access your personal data and obtain a copy of the personal data being processed;
• rectification of your inaccurate personal data;
• request deletion of your data (the right to be forgotten) in the event of circumstances provided for in Article 17 of the GDPR;
• request restriction of processing of personal data in cases specified in Article 18 of the GDPR;
• object to the processing of personal data in cases specified in Article 21 of the GDPR;
• portability of the provided data, processed in an automated manner.
If you believe that your personal data is processed unlawfully, you may lodge a complaint with the supervisory authority (Office for Personal Data Protection, ul. Stawki 2, Warsaw).
Contact
If you need additional information related to personal data protection or wish to exercise your rights, please contact our Data Protection Officer by email:
Łukasz Onysyk
email address: iod@auraco.pl
INFORMATION ON THE PROCESSING OF PERSONAL DATA FOR THE PURPOSES OF CONDUCTING CORRESPONDENCE
The administrator of your personal data is Dekom Sp. z o.o. with its registered office in Gdańsk, address: ul. Wały Piastowskie 24, 80-855 Gdańsk (hereinafter: DEKOM, the Company).
For what purpose and on what basis will DEKOM process personal data?
Your personal data will be processed for the purpose of conducting correspondence. The legal basis for processing your personal data for the aforementioned purpose is art. 6 sec. 1 lit. f) GDPR, where the legitimate interest of the controller is the promotion of its products and services and encouraging cooperation.
DEKOM will transfer your personal data to other entities entrusted with personal data processing on behalf of and for the Company. DEKOM will make personal data available to other recipients if such obligation results from legal regulations.
Your data will not be transferred to third countries or international organizations.
How long will DEKOM process the data?
Your personal data will be processed for a period of one year from the moment of last contact.
What rights does the data subject have?
You have the right to:
• access your personal data and receive a copy of the personal data being processed;
• rectify your inaccurate data;
• request the deletion of data (the right to be forgotten) in the cases specified in art. 17 GDPR;
• request restriction of data processing in cases indicated in art. 18 GDPR;
• object to data processing in cases indicated in art. 21 GDPR;
• data portability of supplied data processed in an automated manner.
If you believe that personal data are processed unlawfully, you may lodge a complaint with the supervisory authority (Personal Data Protection Office, ul. Stawki 2, Warsaw).
Contact
If you need additional information related to personal data protection or wish to exercise your rights, please contact our Data Protection Officer by email:
Łukasz Onysyk
email address: iod@auraco.pl
INFORMATION ON THE PROCESSING OF PERSONAL DATA FOR PURPOSES RELATED TO THE PROTECTION OF PEOPLE AND PROPERTY USING A VIDEO SURVEILLANCE SYSTEM
The administrator of your personal data is Dekom Sp. z o.o. headquartered in Gdańsk, address: ul. Wały Piastowskie 24, 80-855 Gdańsk (hereinafter: DEKOM, the Company).
For what purpose and on what basis will DEKOM process personal data?
DEKOM processes personal data in the form of images recorded by video surveillance. The legal basis for processing the aforementioned data is Article 6(1)(f) of the GDPR, where the legitimate interest of the administrator is the protection of people and property.
DEKOM will transfer your personal data to other entities entrusted with processing personal data on behalf of and for the Company. DEKOM will disclose personal data to other recipients if such obligation arises from legal provisions.
Your data will not be transferred to third countries or international organizations.
How long will DEKOM process the data?
Data recorded by video surveillance will be processed for a period of 1 month from the date the recording was made.
What rights does the data subject have?
You have the right to:
• access your personal data and receive a copy of the personal data being processed;
• rectify your inaccurate data;
• request erasure of data (the right to be forgotten) in cases provided for in Article 17 of the GDPR;
• request restriction of data processing in cases indicated in Article 18 of the GDPR;
• object to data processing in cases indicated in Article 21 of the GDPR;
• data portability of the provided data processed in an automated manner.
If you believe that your personal data is processed unlawfully, you may file a complaint with the supervisory authority (Personal Data Protection Office, ul. Stawki 2, Warsaw).
Contact
If you need additional information related to personal data protection or want to exercise your rights, please contact our Data Protection Officer by email:
Łukasz Onysyk
email address: iod@auraco.pl
INFORMATION ON THE PROCESSING OF PERSONAL DATA FOR DIRECT MARKETING PURPOSES
The controller of your personal data is Dekom Sp. z o. o. with its registered office in Gdańsk, address: ul. Wały Piastowskie 24, 80-855 Gdańsk (hereinafter: DEKOM, the Company).
For what purpose and on what basis will DEKOM process personal data?
Your personal data will be processed for the purpose of:
a) conducting direct marketing – on the basis of Article 6(1)(f) of the GDPR, where the legitimate interest of the controller is to promote its own services and products,
b) sending commercial information by electronic means in accordance with Article 10(2) of the Act of 18 July 2002 on the provision of services by electronic means (Journal of Laws 2019.123 as amended) – on the basis of separately granted consent,
c) using terminal telecommunications devices and automatic calling systems for the purposes of direct marketing in accordance with Article 172 of the Telecommunications Law Act of 16 July 2004 (Journal of Laws 2018.1954 as amended) – on the basis of separately granted consent.
DEKOM will disclose your personal data to other entities that have been entrusted with processing personal data on behalf of and for the benefit of the Company. DEKOM will make personal data available to other recipients where such an obligation results from applicable legal provisions.
Your personal data will not be transferred to third countries or international organizations.
How long will DEKOM process the data?
- within the scope indicated in point A, your data will be processed until you object to the processing,
- within the scope indicated in points B and C, your data will be processed until you withdraw your consent to the processing.
What rights do the data subject have?
You are entitled to:
- access to your personal data and receiving a copy of your personal data being processed;
- rectification of your inaccurate personal data;
- requesting erasure of data (right to be forgotten) in the event that circumstances provided for in Article 17 of the GDPR apply;
- requesting restriction of data processing in cases indicated in Article 18 of the GDPR; hoteldal.pl
- objecting to the processing of personal data in cases indicated in Article 21 of the GDPR;
- portability of the provided data processed in an automated manner.
If you believe that your personal data are being processed unlawfully, you may lodge a complaint with the supervisory authority (Office for Personal Data Protection, ul. Stawki 2, Warsaw).
Contact
If you need additional information related to personal data protection or wish to exercise the rights to which you are entitled, please contact our Data Protection Inspector by email:
Łukasz Onysyk
email address: iod@auraco.pl
INFORMATION ON THE PROCESSING OF PERSONAL DATA FOR PURPOSES RELATED TO THE OPERATION OF COMPANY PROFILES ON THE FACEBOOK AND INSTAGRAM PORTALS
The controller of your personal data is Dekom Sp. z o. o., with its registered office in Gdańsk, address: ul. Wały Piastowskie 24, 80-855 Gdańsk (hereinafter: DEKOM, the Company, Hotel DAL in Kielce).
For what purpose and on what legal basis will DEKOM process personal data?
a) administering and managing the company profile of Hotel DAL in Kielce, including responding to posts and comments posted by you and supervising content published by users – pursuant to Article 6(1)(f) of the GDPR (the Company’s legitimate interest is to promote its own events, services and products by operating and managing the company profile);
b) responding to enquiries and conducting correspondence via private messages through the Facebook and Instagram portals – pursuant to Article 6(1)(f) of the GDPR (the Company’s legitimate interest is the possibility of responding to persons contacting the Company);
c) conducting statistical and analytical research covering the products and services offered by the Company, including examining their quality, assessing customer satisfaction, etc. – pursuant to Article 6(1)(f) of the GDPR (the Company’s legitimate interest is to improve the quality of service and profile its offer);
d) pursuing other legitimate interests of the Company, which include in particular the possibility of pursuing and defending claims, preventing fraud and economic crime, and ensuring the security of the ICT environment
We also inform you that the administrator of the Facebook and Instagram portals (Facebook Ireland Ltd.) is a separate controller of the data of persons visiting and interacting with the company profile of Hotel DAL in Kielce, and may process their data for its own purposes on the basis of other legal grounds.
In particular, the administrator of the Facebook and Instagram portals may, on the basis of its own provisions and regulations, collect and process information contained in cookies stored on the devices of persons visiting the profile. In addition, the administrator of the Facebook and Instagram portals may, based on the data collected in this way, create anonymous summaries and statistics (concerning, for example, the number or profile of visitors), which may subsequently be made available to DEKOM as the entity operating the profile.
Additional information on the processing of personal data by the administrator of the Facebook and Instagram portals is available at https://pl-pl.facebook.com/privacy/explanation oraz https://help.instagram.com/519522125107875?helpref=page_content.
DEKOM may disclose personal data to other recipients if such an obligation arises from applicable law.
How long will DEKOM process the data?
Your personal data will be processed for the period necessary to achieve the processing purposes indicated above, in particular for the period during which you are an active user of the profile or until you object to the processing of your data.
Data contained in posts or comments may be processed until they are deleted.
Data contained in your profile may be processed until you stop following the profiles of Hotel DAL in Kielce and delete all content (comments, reactions to posts) posted by you on the company profiles of Hotel DAL in Kielce.
Irrespective of the storage of data by DEKOM, the administrator of the Facebook and Instagram portals may apply its own data retention periods.
What rights does the data subject have?
You have the right to:
• access your personal data and receive a copy of the personal data being processed;
• rectify your inaccurate data;
• request the deletion of data (the right to be forgotten) where the circumstances provided for in Article 17 of the GDPR apply;
• request restriction of data processing in the cases indicated in Article 18 of the GDPR;
• object to data processing in the cases indicated in Article 21 of the GDPR;
• data portability with respect to data provided and processed by automated means.
If you believe that your personal data is being processed unlawfully, you may lodge a complaint with the supervisory authority (Personal Data Protection Office, ul. Stawki 2, Warsaw).
Contact
If you need additional information related to the protection of personal data or wish to exercise your rights, please contact our Data Protection Officer by email:
Łukasz Onysyk
email address: iod@auraco.pl
INFORMATION ON THE PROCESSING OF PERSONAL DATA FOR PURPOSES RELATED TO THE PERFORMANCE OF THE AGREEMENT WITH THE CONTRACTOR
The controller of your personal data is Dekom Sp. z o. o., with its registered office in Gdańsk, address: ul. Wały Piastowskie 24, 80-855 Gdańsk (hereinafter: DEKOM, the Company).
For what purpose and on what legal basis will DEKOM process personal data?
I. If you are an employee/associate of a DEKOM Contractor:
Your personal data were provided (disclosed) to us by your employer or by the person (company) with whom you cooperate in connection with entering into an agreement with us, and will be processed for the purpose of:
a. entering into, performing and monitoring the performance of agreements concluded between DEKOM and your employer – pursuant to Article 6(1)(f) of the GDPR, where the controller’s legitimate interest is the performance of the agreement with the Contractor;
b. archiving to the extent necessary to fulfil legal obligations, in particular tax and accounting regulations – pursuant to Article 6(1)(c) of the GDPR (fulfilment of an obligation imposed on the controller by law);
c. pursuing or defending against potential claims – pursuant to Article 6(1)(f) of the GDPR;
d. preparing analyses of the results of our business activities for internal purposes – pursuant to Article 6(1)(f) of the GDPR, where the controller’s legitimate interest is to improve the quality of services provided and optimise its business activities.
II. If you are a DEKOM Contractor (a natural person conducting business activity or a partner in a civil-law partnership), your data will be processed for the purpose of:
a. entering into, performing and monitoring the performance of the agreement concluded between you and DEKOM, including in connection with your participation in the process of collecting bids or another procedure related to entering into agreements or selecting contractors – pursuant to Article 6(1)(b) of the GDPR;
b. archiving to the extent necessary to fulfil legal obligations, in particular tax and accounting regulations – pursuant to Article 6(1)(c) of the GDPR (fulfilment of an obligation imposed on the controller by law);
c. pursuing or defending against potential claims – pursuant to Article 6(1)(f) of the GDPR;
d. preparing analyses of the results of our business activities for internal purposes – pursuant to Article 6(1)(f) of the GDPR, where the controller’s legitimate interest is to improve the quality of services provided and optimise its business activities;
e. verifying the credibility of the client/contractor, i.e. carrying out the necessary activities in the form of assessing risks (legal, financial, image-related and reputational) before entering into an agreement, after its conclusion, during its performance, or when extending the scope of the agreement; for this purpose, we may additionally obtain your data from business information registers, business intelligence agencies and other publicly available information sources; the personal data referred to in the preceding sentence will concern the settlement of your liabilities and the business activity conducted by you – pursuant to Article 6(1)(f) of the GDPR.
DEKOM will transfer your personal data to other entities entrusted with processing personal data on behalf of and for the benefit of the Company. DEKOM will disclose personal data to other recipients where such obligation arises from legal provisions.
Your data will not be transferred to third countries or international organisations.
How long will DEKOM process the data?
- with regard to the scope indicated in points Ia and IIa – for the period preceding the conclusion of the agreement and for the period necessary to perform the agreement;
- with regard to the scope indicated in points Ib and IIb – for the period resulting from the provisions of the Accounting Act of 29 September 1994 and the Tax Ordinance Act of 29 August 1997;
- with regard to the scope indicated in points Ic and IIc – for the duration of proceedings and the limitation period for potential claims;
- with regard to the scope indicated in points Id and IId – for a period no longer than that indicated for points Ib and IIb;
- with regard to the scope indicated in point IIe – for the period necessary to carry out such assessment.
What rights does the data subject have?
You have the right to:
- access your personal data and receive a copy of the personal data being processed;
- rectify your inaccurate data;
- request the erasure of your data (the right to be forgotten) where the circumstances provided for in Article 17 of the GDPR apply;
- request restriction of processing in the cases specified in Article 18 of the GDPR;
- object to the processing of your data in the cases specified in Article 21 of the GDPR;
- data portability with regard to data provided and processed by automated means.
If you believe that your personal data are being processed unlawfully, you may lodge a complaint with the supervisory authority (the Personal Data Protection Office, ul. Stawki 2, Warsaw).
Contact
If you need additional information related to the protection of personal data or wish to exercise your rights, please contact our Data Protection Officer by email:
Łukasz Onysyk
email address: iod@auraco.pl
INFORMATION ON THE PROCESSING OF PERSONAL DATA FOR PURPOSES RELATED TO THE EXECUTION OF ROOM RENTAL AGREEMENTS
The administrator of your personal data is Dekom Sp. z o.o. with its registered office in Gdańsk, address: ul. Wały Piastowskie 24, 80-855 Gdańsk (hereinafter: DEKOM, the Company).
For what purpose and on what basis will DEKOM process personal data?
Your personal data will be processed for the purpose of performing the room rental agreement, conference room rental – based on Article 6(1)(b) of the GDPR (processing of data is necessary for the conclusion and performance of a contract) and Article 6(1)(c) of the GDPR in connection with the provisions of the Accounting Act. Personal data will also be processed for the purpose of pursuing any claims related to damage suffered by the Company caused by the Client or defending against claims from the Client towards the Hotel – based on Article 6(1)(f) of the GDPR.
DEKOM will transfer your personal data to other entities entrusted with processing personal data on behalf and for the benefit of the Company, in particular IT solution providers and entities providing legal services to the Company. DEKOM will disclose personal data to other recipients if such obligation arises from legal provisions.
Your data will not be transferred to third countries or international organizations.
How long will DEKOM process the data?
Personal data will be processed for a period of 6 years from the day of completion of the service.
What rights does the data subject have?
You have the right to:
• access your personal data and receive a copy of the processed personal data;
• rectify your inaccurate data;
• request the deletion of data (right to be forgotten) in the circumstances provided for in Article 17 of the GDPR;
• request restriction of data processing in the cases indicated in Article 18 of the GDPR;
• object to data processing in the cases indicated in Article 21 of the GDPR;
• data portability of provided data processed in an automated manner.
If you believe that personal data is processed unlawfully, you may file a complaint with the supervisory authority (The Personal Data Protection Office, ul. Stawki 2, Warsaw).
Contact
If you need additional information related to data protection or wish to exercise your rights, please contact our Data Protection Officer by e-mail:
Łukasz Onysyk
e-mail address: iod@auraco.pl
INFORMATION ON THE PROCESSING OF PERSONAL DATA FOR THE PURPOSES RELATED TO THE PROVISION OF SERVICES, INCLUDING HOTEL, CATERING, CULTURAL/ENTERTAINMENT SERVICES, RENTAL OF EQUIPMENT AND PARKING SPACE RESERVATIONS
The controller of your personal data is Dekom Sp. z o. o. with its registered office in Gdańsk, address: ul. Wały Piastowskie 24, 80-855 Gdańsk (hereinafter: DEKOM, the Company).
For what purpose and on what basis will DEKOM process personal data?
Your personal data will be processed for the purpose of:
a) carrying out the recruitment process, on the basis of the employer’s authority resulting from Article 22¹ of the Polish Labour Code. The legal basis for the processing of the above-mentioned personal data is a legal obligation (legal basis: Article 6(1)(c) of the GDPR in conjunction with the provisions of labour law),
b) carrying out the recruitment process, on the basis of your consent to the processing of your personal data, i.e. personal data other than that indicated in point above, provided in your CV, application form, cover letter and other documents. The basis for processing is the above-mentioned consent (legal basis: Article 6(1)(a) of the GDPR),
c) pursuing the legitimate interest of the controller in respect of the data obtained from you during the recruitment process, in connection with verifying your skills and abilities required for work in the position specified in the job advertisement. The basis for processing this data is our legitimate interest (legal basis: Article 6(1)(f) of the GDPR),
d) pursuing the controller’s legitimate interest in the event of a legal need to establish facts or demonstrate performance of obligations (legal basis: Article 6(1)(f) of the GDPR),
e) conducting future recruitment processes on the basis of your consent to the processing of personal data provided in your CV, application form, cover letter and other documents. The basis for processing is this consent (legal basis: Article 6(1)(a) of the GDPR).
DEKOM will disclose your personal data to other entities that have been entrusted with the processing of personal data on behalf of and for the benefit of the Company. The Company will make personal data available to other recipients if such an obligation results from applicable law.
Your data will not be transferred to third countries or international organisations.
How long will DEKOM process the data?
• in the scope indicated in points a, b, c, your data will be processed for the period necessary to carry out the recruitment process,
• in the scope indicated in point d, your data will be processed for the period of limitation of claims arising from legal provisions, as well as for the period during which the regulations require us to store the data,
• in the scope indicated in point e, your personal data will be processed until consent is withdrawn, but no longer than for a period of 12 months from the date consent is given. hoteldal.pl What rights do individuals whose data are processed have? You have the right to:
• access your personal data and obtain a copy of the personal data being processed;
• rectification of your inaccurate personal data;
• request erasure of data (the right to be forgotten) in the event that the circumstances provided for in Article 17 of the GDPR apply;
• request restriction of processing of personal data in cases specified in Article 18 of the GDPR;
• object to the processing of personal data in cases specified in Article 21 of the GDPR;
• portability of the provided data, processed in an automated manner.
If you believe that your personal data are processed unlawfully, you may lodge a complaint with the supervisory authority (Office for Personal Data Protection, ul. Stawki 2, Warsaw).
Contact
If you need additional information related to the protection of personal data or wish to exercise your rights, please contact our Data Protection Officer by email:
Łukasz Onysyk
email address: iod@auraco.pl
CHILD PROTECTION PROCEDURE
for trainees undertaking internships at Hotel Dal in Kielce
ENSURING SAFE RELATIONSHIPS BETWEEN CHILDREN AND STAFF AND PROHIBITED BEHAVIOUR TOWARDS CHILDREN.
Internships – Hotel Dal Kielce
The fundamental principle governing all activities undertaken by staff is to act in the best interests of children. Staff treat children with respect and take their dignity and needs into account. The use of violence against a child in any form is unacceptable.
The rules for safe relationships with children apply to all employees, interns, persons cooperating on the premises and performing work for DEKOM, as well as persons employed by another employer.
Knowledge and acceptance of the rules are confirmed by signing an acknowledgement of having read the procedures.
Explanation of terms
• A company employee is a person employed under an employment contract or a contract of mandate, as well as a person cooperating on a long-term basis in other forms.
• A child – trainee is any person under 18 years of age.
• A child’s guardian is a person authorised to represent the child, in particular the child’s parent or legal guardian.
• Child abuse means the commission of a prohibited or punishable act to the detriment of a child by any person, including a company employee, or the endangerment of the child’s welfare, including neglect.
• The person responsible for the procedure is an employee appointed by the company’s management board who supervises the implementation of the procedure within the company.
• The internship supervisor is a person designated in an agreement with the educational institution referring a trainee for an internship and responsible for supervising children undertaking the internship.
• A child’s personal data means all information enabling the child to be identified.
Recognising and responding to risk factors for child abuse
• Company employees have the necessary knowledge and, in the course of their duties, pay attention to risk factors and symptoms of child abuse.
• If a company employee obtains information or suspects that a child is being abused or neglected, the employee is obliged to report the information to the person responsible for the procedure.
• If risk factors are identified, the employee responsible for the procedure talks to the child’s guardian or the internship supervisor – a school employee. In justified cases, the employee immediately calls an ambulance and/or the police.
• Employees monitor the child’s situation and well-being.
• Employees know and apply the rules for safe staff–child and child–child relationships established within the company.
• The recruitment of company employees is conducted in accordance with the rules for safe staff recruitment. The HR department in Gdańsk is responsible for safe staff recruitment. After receiving information about the employment of a new employee whose duties will include responsibility for children referred for internships at Hotel Dal, it verifies whether the employee is safe for children and verifies the employee’s data in the Register of Sex Offenders.
Staff relationships with children
An employee is obliged to maintain a professional relationship with the child and to consider each time whether a reaction, message or action towards the child is appropriate to the situation, safe, justified and fair. Actions are undertaken openly and transparently for others so as to minimise the risk of misinterpreting the behaviour.
Communication with children
• Patience and respect must be maintained when communicating with a child.
• Listen carefully and provide answers appropriate to the child’s age and the given situation.
• Do not shame, humiliate, disregard or insult the child. Do not shout at the child except in a situation involving a threat to the child’s safety.
• Do not disclose sensitive information concerning the child to unauthorised persons. This includes the child’s image and information about the child’s family, financial, care and legal situation.
• The child’s right to privacy must be respected. If it is necessary to depart from the principle of confidentiality in order to protect the child, this must be explained as soon as possible.
• If it becomes necessary to talk to the child in private, leave the door to the room ajar and ensure that you remain within sight of others. You may also ask another employee to be present during such a conversation. Do not behave inappropriately in the presence of a child. This includes using vulgar words, gestures and jokes, coercion, making offensive remarks, referring in statements to sexual activity, or taking advantage of a position of authority or physical superiority over the child. Reassure the child that if they feel uncomfortable in any situation, they can always tell you about it.
All possible abuses must be reported immediately to a reception employee or management.
Activities with children
• Appreciate and respect the child’s contribution to activities undertaken, actively involve the child and treat everyone equally regardless of gender, orientation sexual, ability/disability, social, ethnic or religious status or worldview.
• Do not establish any romantic or sexual relationships with a child or make propositions of an inappropriate nature. This also includes sexual comments, jokes and gestures, as well as sharing erotic or pornographic content, regardless of its form.
• Do not offer alcohol, tobacco products or illegal substances, or use them in the presence of a child.
• Do not record the child’s image (filming, voice recording, photographing) unless management has been informed, has given its consent and has obtained the consent of the parents/legal guardians and the children themselves.
• All risky situations involving an employee developing feelings for a child or a minor developing feelings for an employee must be reported to management. If you witness such a situation, respond firmly but tactfully in order to preserve the dignity of the persons concerned.
• In situations requiring hygiene or care activities, physical contact with the child should be avoided, particularly when helping the child dress and undress, wash or use the toilet. If an employee’s presence during such activities is necessary, contact must be kept to a minimum, the employee must act discreetly and ensure that another person is present to witness the course of the event.
All possible abuses must be reported immediately to a reception employee or management.
Physical contact with a child
• Any violent action towards a child is unacceptable.
• Do not hit, poke, push or otherwise violate the child’s physical integrity.
• Do not touch a child in a way that may be considered indecent or inappropriate.
• Do not engage in activities such as tickling or hugging.
• Physical contact with a child must never be secret or concealed, involve any form of gratification or result from a position of authority. If you witness any of the behaviours and/or situations described above on the part of others, always inform the person responsible.
All possible abuses must be reported immediately to a reception employee or management.
Contact outside internship hours
• As a rule, contact with a child should take place exclusively during working hours and concern educational purposes.
• Do not invite children to your place of residence or meet them outside working hours. This also includes contacting children through communication channels (private telephone, e-mail, social media profiles).
• If necessary, the appropriate form of communication with the child and their parents or guardians is through official channels (business telephone/secretariat, secretariat e-mail address).
Guidelines for employees
• Read the above-mentioned procedure for responding to difficult or aggressive behaviour or violence by a minor.
• Cooperate with the person designated to undertake the intervention procedure at the facility and follow their instructions during the incident.
• Have the telephone numbers of persons responsible for interventions at the facility and decision-makers: 41/336 10 00 – any reception employee on duty at a given time, 609 304 905 – Hotel Director.
• Improve competencies to the extent necessary to undertake the actions specified in the above-mentioned procedure.
The persons supervising the preparation of the CHILD PROTECTION PROCEDURE for trainees undertaking internships at Hotel Dal in Kielce, ENSURING SAFE RELATIONSHIPS BETWEEN CHILDREN AND STAFF AND PROHIBITED BEHAVIOUR TOWARDS CHILDREN, at the Office-Service-Hotel Building in Kielce, ul. Piotrkowska 12, 25-510 Kielce, and supervising the above-mentioned process:
- Hotel Director/Administrator – Urszula Stachura
- Senior Receptionist, SOM Coordinator – Anna Justyniarska
Kielce, 15 November 2024.
INTERNAL REPORTING PROCEDURE
Dekom Sp. z o.o.
§ 1 Purpose of the procedure
The purpose of adopting this procedure is to:
1. Fulfil the obligations set out in the Act of 14 June 2024 on the protection of whistleblowers.
2. Protect whistleblowers against any retaliatory actions.
3. Create a safe working environment by ensuring the possibility of safe contact with the employer in situations requiring the employer’s response.
4. Detect violations of the law and other irregularities in order to protect the public interest, the interests of injured persons, and the interests and good reputation of the employer.
§ 2 Glossary of terms
Follow-up actions – actions taken by the employer to assess the truthfulness of the information contained in a report and to counteract the violation of the law that is the subject of the report.
1. Retaliatory actions – direct or indirect acts or omissions, in a work-related context, caused by a report and violating or potentially violating the whistleblower’s rights, causing or potentially causing harm to the whistleblower.
2. Feedback – information provided to the whistleblower concerning planned or undertaken follow-up actions.
3. Coordinator - a person appointed by the employer to verify reports, conduct explanatory proceedings, and undertake and coordinate follow-up actions. Magdalena Celej-Gołębiewska is appointed as the first Coordinator. A change of Coordinator shall take place by resolution of the employer’s Management Board.
4. Report Recipient – a person appointed by the employer responsible for receiving an Internal Report and forwarding it to the Coordinator. Ewelina Linoż is appointed as the first Report Recipient. A change of Report Recipient shall take place by resolution of the employer’s Management Board.
5. Internal Report – a report submitted in accordance with the principles and in the form described in this procedure.
6. External Report – a report submitted to the Commissioner for Human Rights or another public authority.
7. Whistleblower – a person submitting an internal report under the conditions specified in this procedure, or an external report or public disclosure.
8. Public disclosure – making information about a violation of the law publicly available.
§ 3 Personal scope
A whistleblower may be a natural person who reports or publicly discloses information about a violation of the law obtained in a work-related context, including:
1. An employee,
2. A temporary employee,
3. A person performing work on a basis other than an employment relationship, including under a civil-law contract,
4. Persons who have already ceased to perform work,
5. Job applicants,
6. A trainee, volunteer or intern,
7. A commercial proxy,
8. A member of a management or supervisory body,
9. An entrepreneur – a service provider or supplier with whom the employer has entered into an agreement,
10. Persons performing work under the supervision and direction of an entrepreneur.
§ 4 Material scope
The procedure applies in the event of violations of the law concerning:
1. Corruption,
2. Public procurement,
3. Financial services, products and markets,
4. Counteracting money laundering and terrorist financing,
5. Product safety and compliance with requirements,
6. Transport safety,
7. Environmental protection,
8. Radiological protection and nuclear safety,
9. Food and feed safety,
10. Animal health and welfare,
11. Public health,
12. Consumer protection,
13. Protection of privacy and personal data,
14. Security of networks and information systems,
15. The financial interests of the Treasury of the Republic of Poland, local government units and the European Union,
16. The internal market of the European Union, including public-law competition and state aid rules and the taxation of legal persons,
17. Constitutional freedoms and rights of humans and citizens – occurring in relations between an individual and public authorities and unrelated to the areas indicated above.
§ 5 Methods of submitting reports
1. To submit an Internal Report in writing, a letter should be sent to: S.U. Bałtyk ul. Rodziewiczówny 1, 78-100 Kołobrzeg, marked “Dekom - internal report” (written report in paper form), or an e-mail should be sent to: zgloszenia@dekom.com.pl, with the subject line marked: “Dekom – internal report” (written report in electronic form).
2. Adding the note “Dekom - internal report” to the envelope or e-mail subject line will guarantee that the correspondence reaches the Report Recipient. Failure to include the note carries the risk that the letter will be classified as a measure other than an internal report and, consequently, will not reach the Report Recipient.
3. To submit an Internal Report orally, call the Report Recipient at 519 538 356. At the beginning of the conversation, the caller must clearly state that they intend to submit an Internal Report.
4. Oral Internal Reports are not recorded.
5. An Internal Report submitted orally is documented in the form of a conversation report reproducing its exact course, prepared by the Report Recipient. The whistleblower may review, correct and approve the conversation report by signing it.
6. At the whistleblower’s request, an oral report may be submitted during a direct meeting organised within 14 days of receipt of such request. The provisions of paragraphs 3–5 above shall apply accordingly.
7. The Report Recipient forwards Internal Reports to the Coordinator. In the case of oral reports, the Report Recipient forwards the conversation report to the Coordinator.
8. The whistleblower should provide their contact details in the Internal Report, which may be used by the Coordinator in proceedings initiated by the Internal Report.
9. Anonymous reports will not be considered.
§ 6 Requirements concerning a report
1. The whistleblower is protected from the moment the report or public disclosure is made, provided that they had reasonable grounds to believe that the information constituting the subject of the report or public disclosure was true at the time of making the report or public disclosure and constituted information about a violation of the law.
2. Whistleblowers are required to submit reports in good faith, i.e. with the aim of promoting the proper functioning and activities of the employer, rather than seeking personal gain, harassing anyone, etc.
3. Submitting a report in bad faith will result in disciplinary and civil-law consequences, and in justified cases – also criminal-law consequences. This does not exclude the application of other sanctions provided for by law.
4. The whistleblower should ensure that the most valuable information possible is provided, allowing the explanatory proceedings to be conducted effectively.
§ 7 Coordinators and confidentiality
1. The Coordinator guarantees that all reports will be treated with due seriousness and diligence, and that they will be considered in accordance with the principles of impartiality and objectivity. Respect for the dignity and good name of all persons concerned by the report shall be the overriding principle throughout the explanatory proceedings.
2. The Coordinator, as well as all other participants in the explanatory proceedings, are required to exercise due diligence to ensure that all decisions and follow-up actions are taken on the basis of facts and evidence collected, rather than slander and unfounded accusations.
3. The organisation of the process for submitting, receiving and handling reports is intended to prevent any unauthorised persons from gaining access to the information contained in a report.
4. The organisation of the process ensures the confidentiality and protection of the identity of the person submitting the report, the person concerned by the report, and all other persons whose data appear in the report.
5. Access to the whistleblower’s data and the information contained in the report is granted by the Coordinator only to persons essential for conducting effective explanatory proceedings, after they have provided a written undertaking to keep confidential all information obtained during the explanatory proceedings.
6. In any other case, the whistleblower’s identity may be disclosed only with their express consent.
7. The whistleblower’s data may also be disclosed where this is a necessary and proportionate obligation arising from legal provisions in connection with explanatory proceedings conducted by public authorities or preparatory or court proceedings conducted by courts, including in order to guarantee the right of defence of the person concerned by the report.
§ 8 Prohibition of retaliatory actions
1. An absolute prohibition applies to retaliatory actions and unfavourable treatment, as well as threats and attempts to take retaliatory actions against a whistleblower.
2. The full catalogue of retaliatory actions and measures for protecting whistleblowers is described in Chapter 2 of the Act on the Protection of Whistleblowers. Examples of prohibited retaliatory actions:
a. Termination of an employment contract,
b. Reduction of remuneration,
c. Withholding or omission from promotion,
d. Unfavourable and unfair treatment.
3. A whistleblower who has become the target of retaliatory actions or fears that they may become their target should immediately report this fact to the Coordinator, who is obliged to take the necessary actions in such a situation.
§ 9 Follow-up actions
Stages of proceedings after receiving a report:
1. Registration of the report,
2. Acknowledgement – within 7 days of receiving the report, the Coordinator will confirm to the whistleblower that the report has been received,
3. Verification of the report:
- deeming the report justified and compliant with the procedure and informing the whistleblower about the subsequent stages of the proceedings,
- deeming the report unjustified or non-compliant with the procedure,
4. Feedback – within 3 months, the Coordinator will provide the whistleblower with feedback on whether or not a breach of the law has been identified and on the planned or taken follow-up actions and the reasons for such actions,
5. Closing the case in the reports register.
§ 10 external reports
Whistleblowers may submit an external report. Detailed information on the procedure, rules and form for submitting external reports is set out in Chapter 4 of the Whistleblower Protection Act.
An external report may be submitted to:
1. The Commissioner for Human Rights,
2. Other public authorities accepting external reports concerning breaches in areas falling within the scope of activities of those authorities,
3. Institutions, bodies or organisational units of the European Union.
§ 11 liability for breaches of the law
1. A person found to have committed a breach of the law or other irregularities shall be subject to disciplinary, criminal or civil liability.
2. A person who prevents or significantly obstructs a whistleblower from submitting a report shall be subject to disciplinary, criminal or civil liability.
3. A whistleblower who submits a report knowing that no breach of the law has occurred shall be subject to disciplinary, criminal or civil liability.
4. A whistleblower who is also the perpetrator of the reported abuses and irregularities or is involved in them to some extent does not have immunity excluding liability. However, the employer shall take into account the fact that the report was submitted and the whistleblower’s assistance as a mitigating circumstance to the extent to which it has an impact.
§ 12 processing of personal data
1. Upon receiving a report, the employer processes personal data to the extent necessary to accept the report or take any follow-up action.
2. Personal data that are irrelevant to the examination of the report are not collected, and if collected accidentally, are immediately deleted. Such data shall be deleted within 14 days from the time it is determined that they are irrelevant to the case.
3. Personal data processed in connection with accepting a report or taking follow-up actions shall be stored by the employer for a period of 3 years after the end of the calendar year in which the follow-up actions were completed
4. The provisions of point 3 shall not apply where documents related to the report form part of the files of preparatory proceedings or court cases or administrative court proceedings.
§ 13 validity of the procedure
1. This procedure shall enter into force 7 days after the date on which it is made known to persons performing work in the manner adopted by the employer.
2. The procedure applies to all employees, regardless of their position and the type of contract forming the basis of their employment.
3. Matters not regulated by the provisions of this procedure shall be governed by the provisions of Polish law, including the provisions of the Whistleblower Protection Act.