Diocese of Chichester Safeguarding

Photographs and children.

Photography of children and young people involved in church activities can be very positive and bring useful publicity, but there are some important issues to note. The issues are the same for still photographs, digital images or films. For convenience they are all referred to as images.

Images count as sensitive personal data under the Data Protection Act 2018 and the General Data Protection Regulations (GDPR). As with all such data, they should only be used with the consent of the person in the image.

The list below provides a simple point of reference for gaining consent regarding the use of images of children

  • Children under the age of 13: consent should be gained from their parents;
  • Children aged between 13 and 16: consent should be gained from parents and the children themselves;
  • Children aged 17: consent should be gained from the children themselves.

Please note that the above list shows ‘all you need to do’, rather than ‘all you might want to do’. It would be good practice to ask a child younger than 13 before you use their photograph, and to inform the parents of a 17 year that their child has agreed to the use of their image.

Let parents (and children over 13: see above) know how, where and in what context an image may be used – for example, on a public website, through social media or in a printed resource.

Consent is not needed if children appear in a wide-angle group photograph in a public space (for instance, a photograph of the church fete). A church is not a public place in this sense but there may still be occasions when it would not be reasonable, practical or proportionate to secure consent for every individual child who appears in the photograph. In these circumstances, organisers should make clear to all participants and parents that these kinds of images will be taken, and for what purposes.

For instance , if the event is a church service, nativity play or similar, then a verbal notice can be given out at the beginning for the leader of the service or event, asking that any parent who objects to images being made of their child should either remove their child from view of the camera or approach the leader afterwards to ensure that any image they object to is not used. Consent can also be implied; if an activity leader invites people to be part of a group photograph, then those who gather for the photograph have given their consent by virtue of having done so.

Complete a parental consent form for use of images of children, possibly as part of the process for registering and consenting the child’s participation in the activity or event. See model registration template.

Leaders of activities have a responsibility to put in place arrangements to ensure that any ‘official’ photographers can identify (or be informed about) which children should not be subject to close-up photography.

Best Practice with Photography:

  • Think carefully before taking any images showing children and young people on your website, social media or other publications. Consider what the images will be used for and whether consent will be required (see below);
  • oDo not supply full names of children along with the images, unless:
  • oIt is considered necessary e.g. celebrating a performance or achievement;
  • othe child and parent(s) or carer(s) have consented;
  • Only use images of children in suitable dress or kit, being particularly mindful of some activities (e.g. swimming) which involve partial states of dress. Additionally, avoid pictures of children in school uniform where the name of the school is visible;
  • Keep images of children securely:
  • Hard copies of images should be kept in a locked drawer;
  • Electronic images should be in a protected folder with restricted access;
  • Images should not be stored on unencrypted portable equipment such as laptops, memory sticks or mobile phones. If such storage is unavoidable, the images should be kept in a password protected folder or on a device protected with a code or some other secure method of access such as fingerprint identification.
  • Avoid, if possible, using any personal equipment to take photos and recordings of children on behalf of the church – use only cameras or devices belonging to your organisation. This may not always be achievable but it is best practice. If personal equipment has to be used for church purposes, delete the photographs of individual children once they have been used for the purpose for which they were taken;

For guidance on the Data Protection Act and other privacy regulations, visit the Information commissioner's office (ICO) website.

Photography/filming by parents and others at activities/events.

There will be circumstances in which parents and other attendees at activities want to take photographs, for instance concerts, plays, and choirs. For youth events in particular, many young people will have a camera on their mobile phone and will regularly post images of themselves and their friends on social media. It will be important in the planning stages of events to:

  • Decide on the activity approach to photographs/filming for ‘attendees’; This does not apply when, for instance, parents are taking photographs of children’s events for their own use.
  • Clarify and promote the photography rules for the event to all church to all participants;
  • Warn parents, attendees and young people that there can be negative consequences to sharing images linked to information about their own or other people’s children on social media – and care should be taken about ‘tagging’;
  • Children who are in care should not be photographed as this could put them at risk;
  • Make sure that there are procedures to respond to and manage any concerns arising, including a named person to report any concerns to.
  • For young people, you may wish to consider a discussion amongst your group regarding how they wish the images they take of each other to be used, and what restrictions they feel should be observed. This will be more meaningful and effective with young people than a set of rules imposed by adult leaders.