from July to October, i.e. after the announcement by the Ministry of Education and Science that the quarantine of newly admitted juveniles or those who had escaped and then returned should be an optional solution. Despite this, most of the centres quarantined all such juveniles. In some JECs visited by the NMPT representatives, the practice of "remote" supervision over the juveniles from the quarantine groups was applied. The educators did not stay in the rooms used for the quarantine. They were required to ensure the safety of the juveniles by using CCTV and observing the rooms through the glass doors. If it was necessary, the juveniles could knock on the doors to request the educators’ assistance. In the opinion of the CHR, such supervision does not ensure safety of the juveniles and, in fact, poses a risk to their health and life. The Commissioner was also concerned about the limitations of the rights of the juveniles during the pandemic. In some JECs, juveniles in quarantine had their activities limited. They did not go outdoors, did not take part in activities in the association room, and did not have access to computers or TV. Most JECs suspended the possibility for the juveniles to receive visits, to spend weekends outside the JEC, or to go outside the facility. As the representatives of the NMPT have found during the visits, the number of available staff reduced along with the increase in the number of infections. The JEC directors require urgent support in such situations, in particular when the staff shortages are significant. The replacing personnel should be carefully selected so as to be characterized by maturity, professional integrity, the ability to cope with the work-related challenges and to take proper care of the juveniles. If the number of qualified personnel is insufficient, the juveniles do not have their safety ensured. There is a risk to the life and health of both the juveniles and the staff. It is also of importance to plan and establish the rules of cooperation between the JEC directors of and the authorities responsible for the centres’ operation. Cooperation should be maintained with the Ministry of Education and Science, as well as local institutions (e.g. regional labour inspectorates, poviat i.e. county authorities, and crisis management centres). Without good cooperation, communication and inter-institutional support, the centres have reduced chance of overcoming the pandemic crisis and ensuring security to the juveniles. In view of the above, the Commissioner requested the Minister of Education and Science to look into the problems that translate into the increased risk to the health and life of the juveniles and personnel of the JECs. He also requested to be notified about the position of the ministry and about the actions taken. In his reply41 the Ministry of Education and Science pointed to the Guidelines for public and non-public schools and institutions, which have been in force since 1 September and 28 August 2020. He explained that the guidelines are general enough to provide a basis for effective actions, yet taking into account the diversity and specificity of every facility and its actual organizational possibilities. The minister also emphasized that as a result of the cooperation with the Minister of Health, additional support was provided for JECs in the form of personal protection equipment and non-contact 41 Letter of the Minister of Education and Science of 11 December 2020. 34

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