CHILD PROTECTION POLICY

Version 1.0, July 2026

Introduction

The protection of a “child”, namely of “every human being below the age of eighteen years unless under the law applicable to the child, majority is attained earlier”[1], is one of the fundamental values of the European Union.

A Child Protection Policy (CPP) is adopted by organizations or institutions in order to ensure “Child safeguarding” which is “the responsibility that organisations have to make sure their staff, operations, and programmes do no harm to children, that is that they do not expose children to the risk of harm and abuse, and that any concerns the organisation has about children’s safety within the communities in which they work, are reported to the appropriate authorities.”.^[2]

Following the guidance on Child Protection Policies issued by the EC^[3], this Policy will describe:

safeguarding measures that are in place to protect children,
the rules on how to behave when working directly with them,
how to protect children from abuse and harm,
who to report to if any issues arise and
how to respond to the situation in an appropriate manner.

The Center for Security Studies (KEMEA) of the Hellenic Ministry of the Citizen Protection (MCP), operating as think tank of innovation and technology in the area of national security policies (cyber and physical) and civil protection, has a leading role in Research and Innovation (R&I). As such, direct or indirect work with children when implementing a European Research Project or a National Programme, is foreseen.

KEMEA ensures child protection during its activities by monitoring the application of this Child Protection Policy in accordance with the EU, international and national legal framework. KEMEA has engaged its research associate in the implementation of this Policy, having conscious that a Child Protection Policy is an ongoing process that encourages self-reflection and review of processes and practices. This CPP has been approved by the Board of Directors of KEMEA, it has been published on the organization’s website (www.kemea.gr) and communicated within the organization.

KEMEA’s CPP is divided into the following sections:

Purpose and aim
Scope

Legal Framework

Supporting documents
Key Principles
Guidelines for conduct

I. Purpose and aim

The Center for Security Studies (KEMEA) is a public body established under the provisions of Law 3387/2005 (GG A 224)[4] as a scientific, consulting and research organization overseen by the Minister of Citizen Protection with principal purpose the conduct of theoretical and applied research and studies, particularly at strategic level, on security topics and policies (art.1,3).

Considering KEMEA’s strong involvement, among others, in the Justice and CERV (Citizens, Equality, Rights and Values) EU-funded Programmes, “direct contact” with children, meaning “being in the physical presence of a child/children (occasionally or regularly, for a short or long-term)”[5], is foreseen. Research activities involving children, including but not limited to, participation in meetings, conferences, workshops, questionnaires, interviews, focus groups, training and testing, are expected.

In addition, “indirect contact” with children is also expected if there will be “access to information on children such as children’s names, addresses, photographs, case studies etc.” while conducting related research projects or in case of “providing funding for organisations that work directly with children which confers upon the donor organisation the responsibility of child protection issues.”[6].

Either when applying for research funding or when implementing a research project or Programme, KEMEA is committed to ensuring child welfare and safety throughout its activities when children are involved.

The purpose of this Policy is to:

outline KEMEA’s commitment to protect children involved in any stage of its research activities,
set the detailed policies, guidelines and procedures that KEMEA follows to keep children safe mainly from abuse and harm of different types and misconducts and
respond to child protection concerns.

II. Scope

This Policy applies to all KEMEA’s employees and research associates, either internals or externals, including its Research Associates despite their seniority grades/levels, as well as to any administrative research associate, member of KEMEA’s governance, contacted third party or volunteer who works, either directly or indirectly, with “children,” namely with “every human being below the age of eighteen years” [7].

III. Legal Framework

In the Universal Declaration of Human Rights (UDHR), the United Nations has proclaimed that childhood is entitled to special care and assistance[8]. Children’s rights have been enshrined within the United Nations Convention on the Rights of the Child (UNCRC)[9], an international human rights treaty dealing with child-specific needs and rights. The Convention has 54 articles that cover all aspects of a child’s life outlining the civil, political, economic, social and cultural rights of every child, regardless of their race, religion or abilities while explaining how adults and governments must work together to make sure all children can enjoy them.

The European Convention on Human Rights (ECHR)[10] as well as the European Social Charter[11] and the Council of Europe Convention on the Protection of Children against Sexual Exploitation and Sexual Abuse^[12]emphasize children’s right to special protection against the physical and moral hazards to which they are exposed and aim to protect children against, among others, negligence, violence or exploitation.

In Greece, the national Constitution stipulates that “[…] childhood, shall be under the protection of the State.”[13] while the UNCRC was ratified under Law 2101/1992 (GG A 192 “Ratification of the International Covenant on the Rights of the Child”)[14] which confirms Greece’s commitment to protect and promote the rights of children, as outlined in the Convention.

IV. Supporting documents

This Policy should be read alongside KEMEA’s organizational policies and procedures as specified in the following documents:

Founding Law 3387/2005 GG A 124 “Center for Security Studies (KEMEA) and other provisions”, as amended and currently in force,
Ministerial Decision GDOES/1/2/414/2019, GG B 197 “Center for Security Studies’ (KEMEA’s) Rules of Procedure”, as amended and currently in force,
KEMEA’s Board of Directors Decision No.X “on the Approval of KEMEA’s Child Protection Policy” issued on X/X/2026,
KEMEA’s President of the Board of Directors Decision No.X “on the Appointment of KEMEA’s Child Protection Officer” issued on X/X/2026,
Proposals for funding of European research projects and national Programmes,
Grant Agreements (GAs) including DoAs (Description of Actions),
Consortium Agreements (CAs),
Non-disclosure Agreements (NDAs), Letters of Intent (LoIs),
Work Contracts or any type of agreement with third parties,
KEMEA’s Data Protection Policy,
KEMEA’s Information Security Policy and
KEMEA’s Gender Equality Plan.

V. Key Principles

KEMEA’s Child Protection Policy is based upon key principles and beliefs which are an integral part of KEMEA’s research culture, including:

Non-discrimination:

KEMEA will give equal priority to keeping all children safe regardless of any kind of discrimination such as their age, disability, gender reassignment, race, religion or belief, sex, or sexual orientation or any other status[15].

Best interests of the child:

All research activities involving children must be conducted in the best interests of the child, who shall enjoy protection and receive appropriate care at all stages of its involvement in the research projects.

Right to life and development:

Children have an inherent right to life and to protection from violence and suicide.

Development should be interpreted in its broadest sense, embracing the child’s physical,

mental, spiritual, moral, psychological and social development.

The right to be heard:

Children must be empowered to understand and enjoy their rights. They must be made aware of what is acceptable and what is not and what they can do if there is a problem or a concern.

Do no harm principle:

KEMEA must minimize any harm, either intentional or unintentional, of different types (such as sexual, physical, emotional, neglect) and misconducts (like sexual harassment, bullying) [16] that may be caused inadvertently because of its research activities.

Transparency and accountability:

Transparency and accountability are KEMEA’s core values that are followed throughout all its activities.

Personal data protection:

KEMEA acknowledges that children merit specific protection with regard to their personal data, as they may be less aware of the risks, consequences and safeguards concerned and their rights in relation to the processing of personal data[17]. Any personal data of children must be processed in compliance with the applicable European and national data protection framework[18].

VI. Guidelines for conduct

KEMEA, being a research organisation,[19] complies with a series of ethical codes and guidelines such as the following:

The European Code of Conduct for Research Integrity (ALLEA)^[20],
The European Charter for Researchers^[21] ,
How to complete your ethics self-assessment[22] ,
Guidelines on serious and complex ethics issues[23],
Guidance note — Research involving dual use items[24],
Guidance note — Potential misuse of research results [25],
Ethics and data protection[26] and
Ethics in Social Science and Humanities[27].

Keeping children safe and protecting them from all forms of harm and abuse is of paramount significance for KEMEA acknowledging that children, as prospective research participants, constitute “vulnerable categories of individuals”[28] and that their involvement in research[29] may have serious ethical dimensions.

To this end, KEMEA strictly follows the following policies and procedures when working with children as prospective research participants:

Recruitment

a) Of KEMEA’s research associates:

ΚΕΜΕΑ recruits research associates to work directly with children after checking their criminal records, receiving a signed Solemn Declaration of Non-pending Criminal Prosecution (ANNEX A) and conducting a personal interview where issues of prior relevant experience are clarified, together with intentions and capacities for this work. The relevant legal and ethical framework as well as KEMEA’s internal Policies are presented and explained to them. Especially, as far as KEMEA’s CPP is concerned, dedicated training is conducted. KEMEA’s Child Protection Officer is introduced to them as the main contact point for any relevant issue.

b) Of children:

Fair and proportionate recruitment, lack of pressure to participate, unbiased presentation of the research activity, respect for privacy and personal data of the children, the right to drop out at any moment without the need to explain, and adequate measures to avoid discrimination and stigmatisation are the core ethical principles and values in which KEMEA’s research is adhered to. KEMEA implements impartial and justifiable selection of children as research participants, who will be free from coercion and influence and allows sufficient time for children, as prospective participants, and their families, to consider whether they are interested in proceeding to the consent process. Children’s recruitment is handled with great discretion considering that some children are additionally vulnerable because of the impact of discrimination, previous experiences, their level of dependency, communication needs or other issues.

Participation in research

Prior to the initiation of children’s involvement, explicit consent for participation in research must be obtained from their parents or legally authorised representatives and it must be ensured that they have sufficient information to enable them to provide this on their behalf and in the best interests of the children. Whenever possible, the assent of the children must be obtained in addition to the consent of the parents or legal representatives. Dissent must be respected, at all events.

Children and their families are provided with detailed information about their involvement in the research activity before its initiation, including information on:

The research project/programme,
Why has the child been asked to take part [Basis of selection of the children],
What will the child be required to do [E.g. talk about experiences, audio/visual recording],
Where will this research activity take place, [Places where children feel safe and comfortable should be selected]
How often will the child have to take part, and for how long [E.g. initial interview, field test(s)],
When will the child discuss their participation [Debriefing],
What type of information will be collected,
Who will be responsible for all the information when this research activity is over,
Who will have access to it,
What will happen to the information when this research activity is over, [How long will raw data be kept for? Will it be passed onto other people or used in other studies?],
How will project/programme use what they find out [Report, publications, presentations],
Whether anyone will be able to connect the child with what is recorded and reported [Statement of confidentiality, details of coding system to protect identity],
How long the whole project/programme is likely to last,
How can the child or its family find out about the results of the activity,
What if the child does not wish to take part [Participation is totally voluntary],
What if the child changes his/her mind during the activity? [Free to withdraw],
KEMEA’s Child Protection Policy and its procedures, highlighting and describing what to do if they have any concern,
KEMEA’s Child Protection Officer and their contact details to be reached in case of any concerns or adverse effects during or after the research activity,
Details on any foreseeable risks, discomfort or disadvantages and their origin that might ensue.

Subsequently, children and their families have a reasonable time to go through the information, ask any questions and raise any potential concerns. KEMEA should encourage children and their families to ask questions and shall be responsible for making this information crystal clear, providing all the required verbal explanations and clarifications and eliminating any concern and misunderstanding.

Following the child’s confirmation that he or she has fully understood the content included in the Information Sheet about the specific research activity, the consent/assent form must be provided.

Children’s personal data

In principle, KEMEA must not collect children’s personal data to implement its research activities but only anonymous information[30]. However, if processing of personal data[31] is deemed absolutely necessary, for instance when files with their names, pictures, video/audio recordings need to be collected etc., KEMEA’s Data Protection Policy[32] should be consulted and the following principles of data protection are strictly followed (GDPR Articles 5ff.):

Lawfulness: a valid legal base should be established e.g. consent,
Purpose specification and purpose limitation: personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes,
Data minimization: personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed,
Accuracy: personal data shall be accurate and, where necessary, kept up to date,
Storage limitation: personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed,
Data subject rights (transparency, access, correction, deletion, portability, objection, withdrawal of consent, lodging a complaint with a national supervisory authority),
Responsibility (role definition: data controllers, joint controllers, processors),
Accountability (demonstration of compliance),
Data security (confidentiality, integrity, availability), and
Supervision by data protection authorities.

Especially, when consent is established as the legal base of the processing, Informed Consent procedures consisting of an Information Sheet and an Informed Consent Form are implemented prior to the start of KEMEA’s research activity.

As the information is addressed to children, the Information Sheet, it is imperative to provide information[33] in a concise, transparent, intelligible and easily accessible form, using clear and plain language that the child can easily understand[34].

It is clarified that, under applicable law[35], consent for the processing of personal data is given by the minor himself/herself where the minor is at least fifteen (15) years old while where the minor is below the age of 15 years, the consent is given by the legal representative of the minor.

At all events, when a child’s personal data needs to be collected, prior consultation with KEMEA’s Data Protection Officer (DPO) is essential. KEMEA’s DPO is available at dpo@kemea-research.gr and at Tel. +30 2107710805 (ext. 384).

Confidentiality

KEMEA’s research associates who are going to work with children shall sign a Non-Disclosure Agreement (NDA), committing to keeping confidential all information relevant to the children and sharing only the necessary information, in the right way, only with the necessary persons or project’s/Programme’s partners or competent authorities.

Security

KEMEA implements horizontal measures to protect any material, consisting of personal information or not, either in digital or in printed format, in accordance with its Information Security Policy[36].

KEMEA’s Child Protection Officer (CPO)

A person with solid knowledge and expertise in child protection aspects has been appointed by the President of the Board of Directors as KEMEA’s Child Protection Officer (CPO)[37]. The appointed CPO‘s criminal record has been checked and a personal declaration for the absence of criminal convictions for specific crimes related to their tasks as well as pending criminal prosecutions, has been signed (ANNEX A). The CPO is available at cpo@kemea-research.gr and at Tel. +30 2107710805 (ext. 326). KEMEA’s CPO is working in close collaboration with and actively support and guide KEMEA’s Associates who work with children.

Child Protection Officer is responsible for:

making sure that all KEMEA’s research associates and employees are fully aware of, understand and can access this Child Protection Policy and its Annexes,
providing practical guidance and continuous training of KEMEA’s associates and employees on how to implement the measures adopted under this Policy,
ensuring that KEMEA’s Associates know about, and follow, the reporting systems,
monitoring any activities which involve children,
keeping records of any potential incidents and complaints (ANNEX B) and their progress,
reporting immediately to KEMEA’s President of the Board of Directors when any complaint or incident occurs and once a year to KEMEA’s Board of Directors by submitting an Annual Activity Report as well as
keeping this Child Protection Policy up to date and annually at least, reviewing it.

Identification of abuse or harm

If, at any stage of the child involvement in a research programme, a “disclosure” is made, meaning that a child starts to share, fully or partially, its experiences of any type of abuse with others, in any way, either directly or indirectly, behaviorally or non-verbally, orally or written, KEMEA’s research associate must recognize the signs, listen to the child and reassure it, ask any necessary questions respecting the child, fill in the Complaint Form (ANNEX B) and inform immediately KEMEA’ s Child Protection Officer. Any concerns must be kept confidential and should not be discussed with anyone other than the Child Protection Officer who will further report the incident in accordance with the CPP.

Complaints Mechanisms

The Complaint Form, as included in ANNEX B, must be filled in, in case of any safeguarding concern, namely in case a child’s disclosure occurs or in case there is an allegation or even a suspicion of a present or imminent risk of harm or abuse.

The types of abuse that a child may have experienced and need to be reported could include but are not limited to[38]:

Physical: Any physical contact that results in discomfort, pain or injury,
Sexual: Coercion or force to take part in sexual acts of any kind,
Emotional/Psychological: Action or inaction that causes mental distress,
Exploitation: Misuse of power or control over another person for financial, social, sexual or other benefit,
Bullying & Harassment: Unwanted behaviour which causes offense, intimidates or humiliates others,
Sexual Harassment: Unwanted verbal, non-verbal or physical conduct of a sexual nature,
Institutional: Systems or culture within an organisation that can result in any kind of harm or failure to prevent harm through acts of omission.

The Complaint Form includes also information on the nature of the Complaint, where a detailed description of the claimed abuse or harm needs to be provided, including information on when, where and what exactly occurred, whether there were any witnesses and who the perpetrator is, if possible.

Reporting Mechanisms

KEMEA operates a low-level concern approach which means that even minor concerns or suspicions of abuse or harm must be reported. Failure to report safeguarding concerns will be considered a serious breach of KEMEA’s safeguarding procedures and may result in disciplinary action.

The following steps must be followed:

Τhe filled in and signed Complaint Form is immediately forwarded to KEMEA’s Child Protection Officer.
The Child Protection Officer, without undue delay, informs KEMEA’s President of the Board of Directors. The Child Protection Officer will store securely the filled-in and signed Complaint Forms and treat them with the strictest confidentiality.
KEMEA’s President of the Board of Directors decides whether:

– more information/clarifications about the Complaint are needed,

– any other internal procedure needs to be activated,

– the relevant authorities need to be informed or

– any further support to the child and its family needs to be provided.

Awareness

This Policy has been approved by KEMEA’s Board of Directors[39] and has been properly communicated to all KEMEA’s Associates and employees. This Policy has also been made available and easily accessible by everyone in KEMEA’s official website (www.kemea.gr), both in the Greek and English language while, a child-friendly version of it, is also available online.

Accountability

The Child Protection Policy’s monitoring lies in the responsibility of the President of the Board of Directors of KEMEA. All KEMEA’s research associates must comply with this Policy, while KEMEA’s CPO must inform KEMEA’s President of the Board of Directors about the implementation of it and any possible concerns that may have arisen and report annually to the Board of Directors of KEMEA when research programmes involving children are implemented.

VII. Updates

KEMEA acknowledges that the CPP is not static or immutable. Several circumstances may lead to the need to adapt this CPP, such as changes in the operation of the organization, the introduction of new legislation or policies that apply to research organizations. KEMEA’s CPO follow such events closely and decide on the need to update the present Policy.

This Policy comes into force on 17 July 2026.

Dr Georgios Kosmidis

KEMEA’s President of the Board of Directors

[1] United Nations Convention on the Rights of the Child (UNCRC), Part I, Article 1. available at: https://www.ohchr.org/en/instruments-mechanisms/instruments/convention-rights-child .

[2] European Commission, “Child protection policies: What they are? Why they are so important? When they are necessary?” 2020, Keeping Children Safe, available at: https://ec.europa.eu/newsroom/just/items/666497/en.

[3] Ibid.

[4] Law 3387/2005 – GG 224/Α/12-9-2005, “Center for Security Studies (KE.ME.A) and other provisions.”, available at: https://www.e-nomothesia.gr/kat-astynomikos-astynomia/idrysi-leitourgia-uperesion/n-3387-2005.html.

[5] European Commission, ppt. “Child Protection Policy, what is it and why is it important?” available at: https://www.cerv.at/dam/jcr:381ba718-a665-47f9-8414-abfa61c1494f/EU_Child_Protection_Policies_.pdf .

[6] Ibid.

[7] United Nations Convention on the Rights of the Child (UNCRC), 1989, Part I, Article 1. available at: https://www.ohchr.org/en/instruments-mechanisms/instruments/convention-rights-child in conjunction with Law 4689/2020 (GG Α 103), “Transposing DIRECTIVE (EU) 2016/800 of the European Parliament and of the Council of 11 May 2016 on procedural safeguards for children who are suspects or accused persons in criminal proceedings.”, Article 3(1) “Definitions”.

[8] Universal Declaration of Human Rights, art. 25, available at: https://www.un.org/sites/un2.un.org/files/2021/03/udhr.pdf .

[9] United Nations Convention on the Rights of the Child (UNCRC), available at: https://www.ohchr.org/en/instruments-mechanisms/instruments/convention-rights-child .

[10] European Convention on Human Rights (ECHR), available at: https://www.echr.coe.int/documents/d/echr/convention_ENG .

[11] European Social Charter, available at: https://rm.coe.int/168007cf93 .

[12] Council of Europe Convention on the Protection of Children against Sexual Exploitation and Sexual Abuse, available at: https://rm.coe.int/1680084822.

[13]The Constitution of Greece, art. 21 available at: https://www.translatum.gr/dictionary/syntagma-tis-elladas-greek-constitution-translation.htm .

[14] Law 2101/1992, Government Gazette A’ 192 “Ratification of the International Covenant on the Rights of the Child”, available at: https://www.e-nomothesia.gr/kat-anilikoi/nomos-2101-1992-phek-192-a-2-12-1992.html#google_vignette .

[15] More guidelines are available at:

[16] More information on the different types of abuse and neglect are available at: https://learning.nspcc.org.uk/child-abuse-and-neglect .

[17] Recital 38 GDPR.

[18] 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), available at: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016R0679 and Law 4624/2019 (GG A 137/29-08-2019), “Hellenic Data Protection Authority (HDPA), measures for implementing 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 transposition of Directive (EU) 2016/680 of the European Parliament and of the Council of 27 April 2016, and other provisions”, available at: Law 4624/2019 Translated by the HDPA.

[19] KEMEA is not included in the list of research organisations obliged to establish an Ethics Committee, according to Greek law and specifically article 13a par. A of the Law 4310/2014 and article 20 par. 1 of the Law 4521/2018.

[20] All European Academies ALLEA. (2017). The European Code of Conduct for Research Integrity ALLEA. (2017). Available at: https://www.allea.org/wp-content/uploads/2017/05/ALLEA-European-Code-of-Conduct-for-Research-Integrity-2017.pdf.

[21] European Commission. (2015), “The European Charter for Researchers”. Available at: https://euraxess.ec.europa.eu/sites/default/files/am509774cee_en_e4.pdf .

[22] European Commission, EU Grants How to complete your ethics self-assessment, Version 2.0 13 July 2021, available at: https://ec.europa.eu/info/funding-tenders/opportunities/docs/2021-2027/common/guidance/how-to-complete-your-ethics-self-assessment_en.pdf .

[23] European Commission, Identifying serious and complex ethics issues in EU-funded research, 05 July 2021, available at: https://ec.europa.eu/info/funding-tenders/opportunities/docs/2021-2027/horizon/guidance/guidelines-on-serious-and-complex-cases_he_en.pdf .

[24] Available at: https://ec.europa.eu/research/participants/data/ref/h2020/other/hi/guide_research-dual-use_en.pdf .

[25] Available at: https://ec.europa.eu/info/funding-tenders/opportunities/docs/2021-2027/horizon/guidance/guidance-note-potential-misuse-of-research-results_he_en.pdf .

[26] Available at: https://ec.europa.eu/research/participants/data/ref/h2020/grants_manual/hi/ethics/h2020_hi_ethics-data-protection_en.pdf .

[27] Available at: https://ec.europa.eu/research/participants/data/ref/h2020/other/hi/h2020_ethics-soc-science-humanities_en.pdf .

[28] European Commission, EU Grants “How to complete your ethics self-assessment”, Version 2.0

13 July 2021, available at: https://ec.europa.eu/info/funding-tenders/opportunities/docs/2021-2027/common/guidance/how-to-complete-your-ethics-self-assessment_en.pdf .

[29] European Commission, “Ethics in Social Science and Humanities” available at: https://ec.europa.eu/info/funding-tenders/opportunities/docs/2021-2027/horizon/guidance/ethics-in-social-science-and-humanities_he_en.pdf .

[30] ”Anonymous information” refers to information which does not relate to an identified or identifiable natural person or to personal data rendered anonymous in such a manner that the data subject is not or no longer identifiable as defined in Recital 26 of the General Data Protection Regulation (GDPR).

[31] Personal data”: means any information relating to an identified or identifiable natural person as defined in Article 4(1) of the General Data Protection Regulation (GDPR).

[32] KEMEA’s Data Protection Policy is available at: https://kemearesearch.sharepoint.com/sites/kemea-dpp-pdpp

[33]Article 12 GDPR “Information to be provided where personal data are collected from the data subject”.

[34]Article 12 in conjunction with Recital 58 GDPR.

[35] Law 4624/2019 (GG A 137/29-08-2019), “Hellenic Data Protection Authority (HDPA), measures for implementing 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 transposition of Directive (EU) 2016/680 of the European Parliament and of the Council of 27 April 2016, and other provisions”, Chapter C “SUPPLEMENTARY MEASURES FOR THE IMPLEMENTATION OF THE GDPR REGARDING THE PROCESSING OF PERSONAL DATA”, Art. 21 “Consent of minors”, available at: Law 4624/2019 Translated by the HDPA

[36] KEMEA’s Information Security Policy is available at: https://kemearesearch.sharepoint.com/sites/kemea-dpp-pdpp

[37] KEMEA Board of Directors’ Decision on the Appointment of KEMEA’s Child Protection Officer issued on 17/07/2026.

[38] Types of abuse and neglect available at: https://learning.nspcc.org.uk/child-abuse-and-neglect.

[39] KEMEA Board of Directors’ Decision on the Approval of KEMEA’s Child Protection Policy issued on 17/07/2026.

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