The Helsinki Foundation for Human Rights posted its comments to the documents as part of the consultations process in May 2011. The HFHR noted that the concept of the migration policy should expressly identify policy goals and instruments for attaining such goals. Yet the presented document is too large, which, consequently, obscures the goals of the policy. “In our opinion, the document, devoid of an expressly stated action plan, is only an analysis of the current law with very general conclusions”, says Karolina Rusiłowicz, a lawyer with the HFHR.
The document contains a detailed description of the current migration situation in Poland but lacks appropriate diagnosis of the role of foreigners staying in Poland or a hypothetical assessment of the country’s economy and social life without the foreigners. The Policy fails to present a number of useful analyses such as that of the share of foreign-owned firms in the restaurant and catering market, statistics on the foreign workers employed in the construction sector or the number of foreigners working seasonally. Contrary to declarations of the document’s authors, solutions suggested in the outline of the migration policy do not follow its stated objective to open Poland for foreigners.
“In our statement we emphasise that the solutions proposed in the document “Poland’s Migration Policy” involve technical aspects related to arrival and residence of foreigners in Poland but fail to address the social aspect”, says Karolina Rusiłowicz. “There’s nothing on the social consequences, for both the host society and the immigrants themselves, of the arrival of migrants to Poland, risk of conflicts between migrants and the host society and ways to resolve such conflicts as well as the social attitude towards the newcomers”, adds Ms Rusiłowicz.