Image Use Policy

Image use policy

This image use policy applies to the use of any film and electronic photographic equipment used in our settings / events. This will include cameras, tablets, CCTV, portable gaming devices with inbuilt cameras, live streaming devices as well as other forms of digital technology and resources for storing and printing images.

As digital cameras and mobile phones have become more advanced and easier to use, it is increasingly likely that children and their families will be using digital photography as part of their everyday family life. It is therefore very important that Haven staff,, the management committee, volunteers, students, visitors to the setting, parents/guardians and children consider the impact such technology may have.

Digital technology has increased the potential for cameras and images to be misused and inevitably there are concerns about the risks to which children may be exposed. However, we understand and are aware that the behaviours of individuals using the technology present the risk, not the technology.

By taking reasonable steps to make certain that a photograph is appropriate and the full name and contact details are protected, then photography for use in our setting and other events by staff, families and the media should be allowed, in accordance with consent gained from parents/guardians.

Policy Statement

This policy seeks to ensure that images and videos taken within and by Haven staff are held legally and the required thought is given to safeguarding all members / volunteer / event attendees. It applies to all images (including still and video content) taken by HAVEN EXPRESSIONS LIMITED (HAVEN).

It applies to all staff, the management committee, volunteers, students, visitors to the setting and other individuals who work for or provide services to us as well as parents/guardians and children.

This policy forms part of our Safeguarding Children procedures and should be read in conjunction with the following policies and procedures:

Safeguarding Policy
Mobile Phones and Recording Devices
Confidentiality

All images taken would be used by HAVEN EXPRESSIONS LIMITED. This would include advertising other events, promotions, flyers, social media campaigns, website development and any other means deemed in the interest of the core values and purpose of HAVEN EXPRESSIONS LTD.

All images taken by the setting will be used in a manner respectful of Article 5 of the General Data Protection Regulations (GDPR). This means that images will be:

Processed lawfully, fairly and in a transparent manner in relation to the data subject
Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes
Accurate and, where necessary, kept up to date
Kept in a form which permits identification of data subjects for no longer than is necessary for the purpose
Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
Compliant with GDPR

The settings Data Protection Officer, Dr. Ade Buluro (ade@havenx.org) responsible for ensuring the acceptable, safe use and storage of all camera technology and images at HAVEN EXPRESSIONS LIMITED.. This includes the management, implementation, monitoring and review of this Image Use Policy. In addition, the DPO has the authority to view any images taken and/or to withdraw or modify a member of staff’s authorisation to take images at any time. All members of staff, students, volunteers, visitors, event attendees and parents should be aware that all images taken within the setting are available for scrutiny and that they must be able to justify any images in their possession.

Where concerns are raised, or disclosures made, regarding suspicious activity relating to the use of images the DPO will discuss this with the Designated Safeguarding Officer who will contact the Multi-Agency Safeguarding Unit (MASH) for advice. The MASH details for our local authority are:

Contacts

Children, Young People and Families

9am – 5.15pm Monday to Friday
01908 691691

Emergency Social Work Team
01908 265545

Civic Offices
1 Saxon Gate East
Central Milton Keynes
MK9 3EJ

Responsibilities

Parental Consent

Written permission from parents/guardians will always be obtained before images/videos of children are taken, used or published. This is usually by way of a form completed on entry to the setting and updated annually.
Written parental consent will always be sought to take and use photographs offsite for professional, marketing and training purposes. This may be in addition to parental permission sought for onsite images.
Written consent from parents/guardians will be kept by the setting where children’s images are used for publicity purposes (such as brochures or publications), until the image is no longer in use.
Parental permission will be sought on a case by case basis for specific events.
A record of all consent details will be kept securely on file. Should permission be withdrawn by parents/guardians at any time, then all relevant images will be removed and disposed of and the record will be updated accordingly.
Unless stated otherwise, attending an event organised by HAVEN EXPRESSIONS LIMITED will be deemed as providing express and implied permission/consent for these images to be taken provided the attendee has been informed of this policy via email/contact prior to the event or if appropriate notices are provided on the day of the event at visible locations around the building.

Safety of Images and Videos

All images taken and processed by or on behalf of the setting will take place using only equipment and devices provided by the setting.
Staff will receive information regarding the safe and appropriate use of images as part of their safeguarding training and responsibilities.
All members of staff (including volunteers) will ensure that all images are available for scrutiny and will be able to justify any images in their possession.
Images will not be kept for longer than is to be considered necessary. All staff are responsible for ensuring that all photographs are permanently wiped from memory cards, computer hard and portable drives or other relevant devices once the images will no longer be of use. This will be monitored by the Data Protection Officer.
All images will remain on site at all times, unless prior explicit consent has been given by both the DPO and the parent/guardian of any child or young person captured in any photograph.
Should permission be given to take any images off site then all relevant details will to be recorded, for example who, what, when and why and data will be kept securely (e.g. with appropriate encryption).
Any memory stick, CD or storage device containing images of children to be taken offsite for further work will be suitably encrypted and will be logged in and out by the DPO and monitored to ensure that it is returned within the expected time scale.
The DPO reserves the right to view any images taken and/or to withdraw or modify a member of staffs’ authorisation to take or make images at any time.
Only official setting owned equipment (e.g. work provided digital or video cameras, tablets, mobile phones, etc) will be used by staff to capture images of children for official purposes. Use of personal cameras and mobile phones by staff is prohibited at all times.
Any apps, websites or third party companies used to share, host or access children’s images will be risk assessed prior to use.
The setting will ensure that images always are held in accordance with the General Data Protection Regulations (GDPR) and suitable child protection requirements (if necessary) are in place.
Photographs will be disposed of should they no longer be required. They will be returned to the parent or carer, deleted and wiped or shredded as appropriate.

Publication and sharing of images and videos

Images or videos that include children will be selected carefully for use e.g. only using images of children who are suitably dressed.
Images or videos that include children will not provide material which could be reused.
Children’s’ full names will not be used on the website or other publication (e.g. newsletters, social media channels) in association with photographs or videos.
The setting will not include any personal information on video, on the website or on any printed publications.
Any parents/guardians and staff members with particular concerns must always be able to withhold their consent for the publication or sharing of images for whatever reason.

Safe Practice when taking images and videos

Careful consideration is given before involving very young or vulnerable children when taking photos or recordings, who may be unable to question why or how activities are taking place.
The setting will discuss the use of images with children in an age appropriate way.
A child’s right not to be photographed is to be respected. Images will not be taken of any child against their wishes.
Photography is not permitted in sensitive areas such as toilets.

Use of Photos/Videos by Parents/Guardians at events

Parents/guardians are permitted to take photographs or video footage of events for private use only.
Parents/guardians who are using photographic equipment must be mindful of others when making and taking images.
The opportunity for parents/guardians to take photographs and make videos can be reserved by the setting on health and safety grounds.
Parents/guardians are only permitted to take or make recording within designated areas of the setting. Photography is not permitted in sensitive areas such as toilets.
The right to withdraw consent will be maintained and any photography or filming on site will be open to scrutiny at any time.
Parents may contact the setting DPO to discuss any concerns regarding the use of images.
Photos and videos taken by the setting and shared with parents should not be shared elsewhere (e.g. posted on social media site), to do so may breach intellectual property rights, data protection legislation and importantly may place members of the community at risk of harm.

Use of Professional Photographers

Professional photographers who are engaged to record any events will be prepared to work according to the terms of HAVEN EXPRESSIONS LIMITED Online Safety policy.
All contractors must comply with the General Data Protection Regulations and that images will only be used for a specific purpose, subject to consent.
Photographers will not have unsupervised access to children.

If all or part of this policy is of concern to you or your proxy and/or you would like to be excluded from any form of image capture, we advise attendees to avoid entry in to the main auditorium of our events. You are welcome to speak to any of the organisers onsite or email ade@havenx.org, as we may be able to provide a separate room with a TV.

This policy was first adopted: 25 June 2019

This policy was reviewed: 22 Feb 2024

Date for next review: 25 June 2025

Signed: Dr, Ade Buluro (ade@havenx.org)