Challenges, Assessment and Recommendations of the Fact-Checkers Regarding Polish Policy of Combating and Counteracting Disinformation 1

: The article presents the results of the research of Polish fact-checkers’ opinions concerning the challenges related to the phenomenon of disinformation, the assessment of Polish policy implemented in this area, and recommendations. Data on this topic were collected using in-depth interviews. Among the most important challenges related to disinformation, Polish fact-checkers mentioned: the 2023 election campaign and the polarisation of Polish society, disinformation about the EU, Russian disinformation, the war in Ukraine and anti-Ukrainian narratives, as well as development of artificial intelligence. The respondents’ assessment of Polish policy of combating and counteracting disinformation was negative. The passivity of the Polish state or illusory actions were also emphasised by the respondents. They pointed out that the state is tackling this problem in a piecemeal manner , focusing on a specific, selected topic. In addition, attention was drawn to the use of disinformation in Poland for political purposes. Fact-checkers would recommend Polish authorities to conduct a clear, fast and coordinated communication policy, to restore trust in public institutions, to increase the level of financing the NGOs’ activity, and to change the approach to media education, which is the best tool for combating disinformation.

Poland has been the target of disinformation activities for many years, primarily those conducted by the Russian Federation (Gasztold, Gasztold, 2022, p. 1260), and -since the COVID-19 pandemic -also by the People's Republic of China (Karásková et al., 2020, p. 25).The increasing scale of this phenomenon forces the Polish authorities to take initiatives aimed at counteracting and combating such trends.Activities are dictated by possible negative political, social or economic consequences of disinformation.It is important to sensitise and immunise society against false content.
Views on the level of Poles' resistance to disinformation are varied.Some researchers consider Poland to be a relatively resistant country (e.g.Zawadzka, 2018); others, on the contrary, assess Poles' susceptibility to disinformation as high (Chałubińska-Jentkiewicz, Soler, Makuch, 2023, p. 104).Some researchers suppose that the susceptibility of Polish society to disinformation depends on the form of the message or the mechanisms used.For example, openly pro-Russian messages do not find supporters among PP 2 '24 the Polish society, but properly masked disinformation, based on narratives about the destruction of Polish identity or negatively portraying migrants is very often taken over and shared (Olech, Dobrowolska, 2022, p. 24).
Natural allies in the activities of states and international organisations aimed at counteracting disinformation are non-governmental organisations, especially those, whose activity is focused on fact-checking.The research problem addressed in this article is the Polish fact-checkers' assessment of Poland's policy towards the phenomenon of disinformation.The article starts with a presentation of methodological assumptions.Then, the actions taken by Poland to counteract and combat disinformation will be discussed.The next parts present the results of research on the Polish fact-checkers' community.The research was carried out in 2023.Data from in-depth interviews were used to analyse the challenges identified by fact-checkers in their opinions, as well as their assessment of Polish policy in the field of combating and counteracting disinformation.The article ends with respondents' recommendations.

Methodological assumptions
The aim of the research was to analyse the opinions, assessments and recommendations of Polish fact-checkers regarding state policy of combating disinformation.The selected research problem determined the choice of interpretivist methodology.This approach allows for the analysis of existing data, but above all, it also allows for research based on the narrative form of explanations (Marsh, Stoker, 2016, pp. 131-133).This principle was reflected in the choice of research methods -legal and institutional analysis, and individual in-depth interviews.The combination of these qualitative research methods allowed for the analysis of the research problem from the perspective of practitioners combating disinformation, as well as provided respondents' opinions, assessments and recommendations (Kvale, 2012, p. 39).The selection of the sample was purposeful.The interviews were conducted in April 2023 on a sample of seven fact-checkers working in Polish fact-checking organisations.The key selection criterion was the employment in fact-checking organisation.The list of respondents was created based on the method of snowball sampling (Babbie, 2013, p. 129-130).The interview script was semi-structured.
The study sought answers to the following questions: -How is the issue of counteracting and combating disinformation regulated in Poland?
Which entities are entrusted with competences in this area?-What challenges do Polish fact-checkers see related to the phenomenon of disinformation?-How do they assess Polish policy of counteracting and combating disinformation?-How would they improve Poland's ability to fight disinformation?

Combating disinformation in Poland
There is no separate regulation in the Polish legal system regarding the issue of disinformation.In criminal law, the dissemination of fake news as such is not penalised, however, to a broad extent, the dissemination of false information is punished under various legal acts, e.g. the Act of 26 January 1984, Press Law (Departament Strategii Biura KRRiT, 2020, p. 54).
Legal and institutional actions related to combating disinformation have been undertaken since 2018, which was related to the intensification of Russian information attacks on Poland.However, a significant part of these activities has not been finalised (Havlíček, Yeliseyeu, 2021, p. 189).Disinformation, as active means of implementing Russia's policy, is mentioned in the Defence Concept of the Republic of Poland from 2017, published by the Ministry of National Defence (Ministerstwo Obrony Narodowej, 2017, p. 24).An important document was also the National Security Strategy of the Republic of Poland from 2020, which emphasised: "In the context of the digital revolution, the specific role of cyberspace and information space should be taken into account.This also creates room for disinformation and manipulation of information, which requires effective strategic communication activities."(Biuro Bezpieczeństwa Narodowego, 2020, p. 8).The strategy's objectives include "ensuring secure functioning of the state and its citizens in the information space" (Biuro Bezpieczeństwa Narodowego, 2020, p. 21).There are four actions to implement it: -creating the ability to protect the information space at the strategic level (including the systemic fight against disinformation), defined as the merging layers of virtual, physical and cognitive space, -creation of the homogenous system of the state's strategic communication; -active counteracting disinformation by creating procedures for "cooperation with the information and social media while ensuring the involvement of citizens and non-governmental organisations"; -striving "to increase public awareness of the threats related to manipulation of information through education in the field of information security" (Biuro Bezpieczeństwa Narodowego, 2020, p. 21).
On 29 September 2021, a draft act on the protection of freedom of speech in online social media was announced, which -according to its authors -would protect freedom of speech, on the one hand, and, on the other hand -create legal procedures for protecting the information space, including against disinformation (Fraser, 2021).However, the project was met with criticism -the fears were related to the fact that new regulations may impede the functioning of the digital single market.Additional attention was drawn to the disproportionate tightening of criminal sanctions or the proposal to establish the Freedom of Speech Council, whose unclear operating framework could pose a risk of prejudice (CyberDefence24, 2022).The Council would be the entity that considers applications regarding the labelling of disinformation content.The draft bill provides for the appointment of "trusted whistleblowing entities", whose task would be to respond to disinformation content in social media, to limit access to content or profiles of the users disseminating illegal content at the request of individuals or organisations-whistleblowers, and to report in this respect to the National Broadcasting Council.Failure to comply with the provisions of the act was to be punished with penalties of up to 50 mln PLN (Ministerstwo Sprawiedliwości, 2022).The act until 2024 has not been passed.
In 2021, the Polish authorities also started work on amending the Act on the national cybersecurity system of 2018 (Ustawa, 2018).One of the main expected changes was the PP 2 '24 restriction of access to the Polish telecommunications market for companies suspected of illegal activities, including espionage and illegal information collection.The plans for the amendment were related to the arrest in 2019 of a Chinese spy, who illegally promoted Huawei's interests in connection with Polish 5G infrastructure projects (Havlíček, Yeliseyeu, 2021, p. 190).However, this act has not been amended by the end of 2023.
The Ministry of Foreign Affairs (MFA) is also involved in combating disinformation in Poland, and its activities include: cooperation with strategic communication units of partners from the European Union (EU) and NATO, building its own institutional capabilities, raising the awareness of state officials, conducting information campaigns or supporting non-governmental organisations.The Ministry of Foreign Affairs also contributes to the development of institutional capabilities to counteract disinformation, and it is the operator of the EU Rapid Alert System.In 2018, the MFA contributed to the establishment of a new inter-ministerial mechanism -the Working Team for Hybrid Threats at the Government Crisis Management Team of the Government Centre for Security.In turn, in 2019 the Ministry of Foreign Affairs established the special unit to identify and counteract disinformation targeting Polish foreign policy (Biuro Rzecznika Prasowego MSZ, 2019, pp. 11-12).
When analysing the competences of Polish institutions in the field of combating disinformation, attention should be paid to: the National Security Bureau, the Department of National Security in the Chancellery of the Prime Minister, the Government Centre for Security, intelligence and counter-intelligence services, as well as the National Broadcasting Council (pl.KRRiT), which is a good example of cooperation of the state authorities within the EU institutions.The National Broadcasting Council is a member of the European Regulators Group of Audiovisual Media Services (ERGA), which cooperates closely with the European Commission (Kupiecki et al., 2021, p. 84).Also noteworthy is the activity of the Ministry of Digitization, in particular the Scientific Academic Computer Network (NASK) subordinated to it, which focused on promoting and implementing the concept of the information society, education -mainly for children and youth, and general activities related to ensuring safety on the Internet (NASK, WWW).
In the context of combating disinformation in Poland, attention should also be paid to the important role of non-governmental organisations, whose activities are focused mainly on the following areas: expert work addressed to decision-makers and interested groups, fact-checking, media education, and promoting quality journalism (Albrycht et al., 2021, p. 27).An example of the organisation whose one of the goals is activities for "cooperation between domestic and foreign academic, expert, journalist, social, business and political circles, including non-governmental organisations, governmental organisations and institutions, countries and nations in the field of counteracting disinformation" is foundation Center for Propaganda and Disinformation Analysis (Centrum Analiz Propagandy i Dezinformacji, WWW).As a part of its activities, it prepares special analyses and reports, runs a series of podcasts and undertakes various educational initiatives.There are also active fact-checking organisations in Poland, which verify information on a daily basis and flag disinformation on their websites and social media channels.Examples of such organisations listed by Reporter's Lab are: AFP Fact Check, association Demagog,FakeNews.pl,Konkret24,OKO.press,Pravda (Reporter's Lab,WWW).Most of the mentioned organisations are also involved in media education, but the association Demagog, which runs the project Fact-Checking Academy, deserves special attention.The project includes workshops on finding and verifying information and how to counteract fake news.In achieving its statutory goals, the association used, among others, EU grants, e.g. the AI4TRUST project (104.5 thousand EUR) (Demagog, WWW).
In turn, organisations such as foundation Panoptykon (Fundacja Panoptykon, WWW) and the Reporters' Foundation (Fundacja Reporterów, WWW) promote quality journalism.Polish research centres, such as the Polish Institute of International Affairs (PISM, WWW) and the Centre for Eastern Studies (OSW, WWW), also made an important contribution to combating disinformation, and in particular to conducting research on it.

Disinformation in Poland -current challenges
When analysing the topic of disinformation and combating it in Poland, we should start by identifying the greatest threats that it currently poses.In the respondents' opinion, the most important of them were: the elections in 2023 and the polarisation of Polish society, disinformation regarding the EU, Russian disinformation, the war in Ukraine and anti-Ukrainian narratives, as well as development of artificial intelligence.
When commenting on the specificity of disinformation in Poland and current trends, most respondents drew attention to the parliamentary elections in 2023, and the related disinformation focusing on political topics (R2).Elections are usually an intensive period in the work of fact-checkers, because apart from strictly political narratives, they also deal with many other topics: "Now we anticipate that there will actually be a lot of work related to general political topics [...], i.e. gender issues, salary inequality, gender inequality" (R3).Respondents emphasised that their concerns about disinformation related to the elections are linked with polarisation of Polish society and Polish political scene.
Divisions and polarisation facilitate the transmission of manipulated information and the evocation of extreme emotions, which in turn facilitate the spread of disinformation.One respondent described this problem as follows: "Disinformation works in topics that are socially important.It very rarely creates completely fictional topics.When I think about Polish society, it is very susceptible to polarisation, mainly due to the political situation [...], but it seems that it is very easy to polarise people around the topics that are socially important, e.g.towards minorities.I am afraid that such growing trend will be used for further topics that attack minorities" (R5).Apart from minorities, mainly migrants, refugees from Ukraine, LGBT+ people, sensitive topics from the point of view of Polish society also include: women's rights, "economics, energy security, climate" (R3) and European integration.When speaking about Polish society, we should also take into account the fact that "we have very limited trust in public institutions at the moment, and government's messages are often not treated as credible due to the fact that there have been situations that undermined the credibility" (R7).Improving trust in the state is one of the challenges facing the next government (R7).
Disinformation about the EU and "the polarisation of people around this topic" (R5) is another "significant trend that is very visible, unfortunately, and at the same time this is a big threat for our country" (R5).Anti-EU narratives were also mentioned by respondents in the context of challenges related to the parliamentary elections.One respondent PP 2 '24 commented this issue as follows: "I am afraid that a negative attitude towards the EU will actually be created, especially in connection with the upcoming political campaign.This is our basic problem in this election year" (R5).Anti-EU disinformation in Poland very often refers to EU policies, in particular in 2023 -"those concerning climate protection" (R5).
Respondents considered also Russia's disinformation activity as an important, although not new, threat: "The activities of Russian agents or pro-Russian apologists, Russian influence operations are the greatest danger at the moment for our region in general, not only for Poland" (R1).In the context of Russian disinformation, the respondents mentioned anti-Ukrainian and anti-refugees narratives as the main current threats: "I am worried about how anti-Ukrainian disinformation will continue to develop [...].We can see the increasing involvement of these movements, various types of anti-war, pacifist ones [...] that it is not our war and all these things" (R3).The war in Ukraine remains a challenge (R4).However, there were different voices, according to which anti-Ukrainian disinformation "failed" (R2) because "almost the entire mainstream is insensitive to it, that is, it does not support these narratives, and even more -the entire television mainstream, some newspapers, websites are combating such disinformation" (R2).However, it should be remembered that anti-Ukrainian and anti-refugees narratives can be used in various contexts, including economic ones, which may still fall on fertile ground in polarised society.
A threat that is only gaining popularity in Poland and which should be addressed, according to respondents, is the development of artificial intelligence.It is associated with unpredictability, which was emphasised in the following statement: "We don't know yet what consequences this phenomenon will have for the spread of disinformation, whether it will be used for evil purposes.The authors of these tools themselves have some doubts, as to how it will be used" (R6).All respondents stated that this type of technology will be slowly popularised in Poland.They also assumed that it could be used in 2023 during the election campaign to create false content, but these would be incidental activities (R1).

Combating disinformation in Poland -current challenges
Respondents were asked to assess the actions that Poland is taking to combat disinformation.Only two people mentioned positive aspects of the state's actions -both of them recalled the role that the war in Ukraine played in this context: "I definitely see positive moves in connection with Russian disinformation.There was at least a partial understanding after 24 February 2022 that something should be done with it" (R1, similarly R3).
According to the respondents' assessment, Poland deals with the issue of disinformation in a piecemeal manner (R7) and focuses on a specific, selected topics.In 2023, such topic was the war in Ukraine, previously it was the COVID-19 pandemic and vaccines -"these are the main topics of disinformation and very important, but on the other hand, disinformation is related to many different aspects.This is not just a vaccine, it is not just a war.These are many paramedical topics, 5G networks, etc., and it is a little bit strange that activity of Polish authorities is limited" (R7).
Each of the respondents assessed the Polish state's policy negatively.Even though the respondents mentioned that "some actions are being taken" (R6), they were not considered as sufficient.There is a lack of "any systemic solutions to combat disinformation in Poland" (R3), and the ideas presented by state institutions do not include a plan "how to realistically counteract disinformation" (R3).Moreover, the respondents emphasised the use of disinformation for political purposes.One respondent referred to this problem in the following way: "If we are talking about disinformation concerning 5G, for example, there is a lot of activity here, because all state institutes, universities, radio and television stations provide reliable information about it.It is not super extensive, but anyone who is interested in this topic knows it and can find information, but for example when it comes to such fake political news...That fake news is a daily occurrence, because, for example, Polish Television is a huge source of disinformation" (R2).
Respondents mentioned negative examples of the state's activities, such as the idea that "our state or the National Broadcasting Council (pl.KRRiT), or NASK will create a platform for the exchange of information for fact-checking organisations.This is a very bad idea, because it interferes with their potential independence" (R5).In turn, another respondent mentioned the following example: "Conferences are organised, from which nothing comes out, or there was a project Fake Hunter organised by Polish Press Agency, which at the same time can put some disinformation into circulation" (R7).The respondents' general assessment of the effectiveness of Polish activities for combating disinformation is reflected in the statement of one respondent: "They are doing something.It is difficult to speak about a state solving the problem of disinformation if the state spreads disinformation and uses these tools for political competition" (R4).
When analysing the topic of combating disinformation in Poland, special attention should also be paid to state support for fact-checking organisations.When asked about how the state supported their work, respondents unanimously stated that "apart from some isolated cases" (R1) it almost did not do so at all.The activities of fact-checking organisations were financed by grants and projects, e.g., the National Centre for Research and Development (R5).However, the level of support was not sufficient, and there was also a lack of coordination of activities in this area, no clear criteria and standards for obtaining funds (R6).Also in this context, the respondents strongly emphasised the political aspect of the state's activities: "Unfortunately, our government chooses the organisation for cooperation to suit its agenda.For example, we -as fact-checkers' community -were very concerned about the transfer of public money, probably from the justice fund, to Ordo Iuris -the website odfejkuj.pl.This website was used to spread false information, but it is pretending to be considered as fact-checking website.It was absolutely terrible, and that's why organisations don't trust state initiatives" (R5).Another respondent, in turn, commented this problem as follows: "Unfortunately, the distribution of grants in Poland is very politicised at the moment.We ourselves noticed that grants were given to expand websites that spread disinformation, for example, regarding COVID-19.This is a strange situation, because non-governmental organisations combating disinformation can count on practically no or very minimal help" (R1).The level of financing of the activities of fact-checking organisations by Poland was so low that they could operate primarily thanks to EU grants, and Polish administration only acted as an intermediary in their allocation (R1).

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In the respondents' opinion, the problem of the Polish policy for counteracting disinformation was the lack of cooperation with non-governmental organisations: "Verbally at various conferences it is always said that everyone is willing to cooperate, but in reality, unfortunately, this is far from the true" (R7).The cooperation of fact-checking organisations with authorities was not permanent, but incidental and "sham", such as cooperation during the pandemic with the Ministry of Digitization, Ministry of Health, Ministry of Climate and Environment as part of the Youth Dialogue Forum initiative.The respondent's assessment of these forms of cooperation were not positive: "I think it was just another thing that could be said to have taken place, and nothing more…" (R7).Most respondents admitted that they did not have the opportunity to receive support from Poland and did not cooperate with state institutions, for example: "Polish institution?No, we didn't cooperate.It happened with the American one, with the British one, but not with Polish institution" (R1).
The lack of cooperation and financial support from the Polish authorities was assessed by respondents in a distant manner.This was primarily due to the fact-checking community's lack of trust in the government: "Some organisations, however, believe that the government is responsible for some disinformation, so maybe they are careful with cooperation" (R5).According to respondents, such cooperation could undermine the independence and reputation of non-governmental organisations.
A significant disadvantage of Polish policy in the area of counteracting disinformation was the way in which media education was perceived and implemented.In the respondents' opinion, it was not a priority for the state (R5), although the state is responsible for media education (R6).

Recommendations for Poland
The solution that the Polish authorities should implement immediately is to conduct a clear and quick communication policy" (R7).The respondent referred to this issue, mentioning a specific case: "when it was happened in Przewodów,2 we were waiting a very long time for state institutions, or rather for the state, to say anything about this matter.There were many possibilities for speculation, and for a long part of that day, actually the entire evening, several hours, we had to wait for the official announcement.This was the field that was used by people who spread conspiracy theories and disinformation" (R7).
Among the recommendations related to the government's information policy, there were also postulates to rebuild the authorities' credibility and depoliticise competitions for positions in institutions such as NASK or public media, which will facilitate the fight against disinformation (R1, R5, R7).The respondents also pointed out the need to introduce transparency and clear financing rules for non-governmental organisations, and, above all, to depoliticise the procedure for granting public funds.
An important position among the recommendations formulated by respondents was that the state should conduct real media education in cooperation with non-governmental organisations.Media education should be included in the core curriculum.In the respondents' opinion, attention should be paid to "the ability to think critically, but also to the basic things related to the verification of information, such as searches, reverse photo searches, such basic verification techniques" (R3) or "googling" (R7).They justified their position by saying that media education would make society more resistant to manipulated information and equip it with such a basic skill as critical thinking (R3, R6, R7).

Conclusion
In recent years, we have observed intensified activity of states and international organisations in the area of combating and counteracting disinformation, and this is also the case in Poland.This is undoubtedly due to the perception of the threats posed by disinformation.Both the outbreak of the COVID-19 pandemic and Russian aggression against Ukraine, which have demonstrated the scale and possibilities of disinformation activities, have and will have an impact on the intensification of work for combating this phenomenon.
There is no separate regulation in the Polish legal system regarding the issue of disinformation.This issue is addressed in the broader context of cybersecurity or the provisions of acts regulating selected issues, such as Press Law.Attempted changes in the area of legislation were observed after 2018.This was due to the intensification of Russian information attacks, but by the end of 2023 a significant part of these activities had not been finalised, such as legal acts containing regulations related to disinformation.It should be noted that active policy of the Polish authorities in this area will be enforced by the EU, which gradually regulates the issues related to counteracting and combating disinformation not only in "soft" but also in binding legal acts.Therefore, it is a matter of time to resume work on the issues that were to be regulated by the provisions of the draft Act on the protection of freedom of speech in online social media and the amendment to the Act on the national cybersecurity system, which were not adopted.
Competences in counteracting and combating disinformation in Poland are dispersed.The institutions dealing with the issue of disinformation include: the National Security Office, the Department of National Security in the Chancellery of the Prime Minister, the Government Centre for Security, intelligence and counter-intelligence services, as well as the National Broadcasting Council (pl.KRRiT).The activities of the Ministry of Digitization, in particular the Scientific Academic Computer Network (NASK) under its supervision, are also noteworthy.However, the most important one is the Ministry of Foreign Affairs, which demonstrates that disinformation is treated primarily as an external threat.
The multiplicity of entities definitely does not favour the synchronisation of taken actions and does not facilitate the development of common goals in the policy of counteracting disinformation.Combating false information due to its scope, the technologies used, and even its widespread presence in the public sphere requires a holistic approach.

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It has not been assured by the end of 2023.Cooperation with non-governmental organisations, especially fact-checking, may be helpful in achieving this goal.
Three research questions were related to the opinions of Polish fact-checkers -i.e. about the challenges concerning the phenomenon of disinformation, assessment of Polish policy in this area, and recommendations.In case of the first question, Polish fact-checkers mentioned the 2023 election campaign and the polarisation of Polish society, disinformation about the EU, Russian disinformation, the war in Ukraine, anti-Ukrainian narratives, and the development of artificial intelligence as the most important challenges.These challenges refer to practical aspects related to the phenomenon of disinformation -most of them are the issues that may become the topics of potential disinformation.This catalogue is complemented by the issue of potential sources and tools of disinformation.The identification of these challenges by respondents demonstrates the specificity of the practical aspects of the work of fact-checking organisations.
The respondents' assessment of the Polish policy in the field of counteracting and combating disinformation was negative.Polish fact-checkers emphasised the passivity of the state or the illusory nature of the taken actions, which were ineffective and insufficient.In their opinion, since the outbreak of the COVID-19 pandemic and Russian aggression against Ukraine, Polish authorities have begun to be more active in the area of combating disinformation, and Polish society has gained some basic awareness on this topic, but this is still not enough to effectively solve the problem.The respondents pointed out that the state treats the issue of disinformation in a piecemeal manner, focusing on a specific, selected topic instead of analysing the entire phenomenon.As a result, the taken actions were reactive and did not prepare society for problems that would arise in the future.
Moreover, there is a lack of systemic solutions for combating disinformation in Poland, and the ideas presented by state institutions did not include a plan on how to actually counteract it.The equally important issue is that most respondents drew attention to the use of disinformation in Poland for political purposes.They assessed this practice negatively.Similarly, the practice of disseminating false information by public institutions in order to achieve political goals was met with disapproval.
Respondents unanimously declared that they did not feel state support for independent fact-checking organisations, and any assistance or financing was largely politicised.A particularly disturbing conclusion is that the community of independent fact-checking organisations in Poland does not trust the state.Moreover, it recognises that cooperation with the state may undermine the independence and reputation of non-governmental organisations.Also in this case, the assessment referred to the practice of non-governmental organisations, hence legal regulations were an almost omitted aspect when assessing the Polish policy in the field of prevention and combating disinformation.
Recommendations regarding the Polish policy of combating and counteracting disinformation are resulted from assessments of its current implementation.The catalogue of recommendations can be reduced to the following issues: 1. Clear, fast and coordinated communication policy -so that Poles can use official sources of information.2. Rebuilding trust in public institutions, which should be perceived as reliable official sources of information.