Safe Use of Children's Photographs Policy
St Michael’s Kingsteignton & St Peter & St Paul's Teigngrace
Parochial Church Councils
Policy for the Safe Use of Children’s Photographs
Churches enjoy and welcome publicity. Children’s photographs add colour, vibrancy, life and interest to articles promoting church activities, events and initiatives. Making use of photographs for publicity materials and to promote the church in the press can encourage and attract engagement with the church and celebrate the church’s achievements. Photographs must however be used in a responsible way. As a PCC we need to respect children’s and parents’ rights of privacy and be aware of potential child protection issues.
St Michael's and St Peter & St Paul's PCCs will take every reasonable effort to minimise risk by following the guidelines detailed in this document and by securing parental consent for the use of photographs.
This policy applies to the use of photographs in church publicity materials, on its website, Social Media and in the press. Its implementation is the responsibility of all church officers, activity leaders and volunteers. Parents and visitors will be made aware of this policy.
2. Child Protection
There may be a risk when individual children can be identified in photographs. For that reason the PCCs for St Michael's and St Peter & St Paul's Churches have developed this policy to make every effort to minimise risk. In the event of the inappropriate use of children’s photographs the PCC will follow the appropriate safeguarding procedures
3. Data Protection Act 1998
Photographs and video images of pupils and staff are classed as personal data under the terms of the Data Protection Act 1998. Therefore, using such images for church publicity purposes requires the consent of either the individual concerned or in the case of children, their legal guardians.
St Michael's and St Peter & St Paul's PCCs will not display images of children on websites, in publications or in a public place without such consent. The definition of a public place includes areas where visitors to the church have access.
Where photographs are taken at an event attended by large crowds, this is regarded as a public area so it is not necessary to get permission of everyone in a crowd shot. The Data Protection Act does not apply to photographs or films taken for personal use by family and friends.
4. Appropriate Use of Images in Church Publicity Materials
St Michael's and St Peter & St Paul's PCCs will:
• Ensure that images are stored securely and used only by those authorised to do so;
• ensure that electronic images are stored on a secure computer or device to which members of the public have no access;
• not use an image of any child who is subject to a court order;
• secure parental consent for the use of children’s photographs;
• not use photographs of children who have left the church without their consent; and
• Ensure that children are appropriately dressed – a minimum of a vest/shirt and shorts (PE kit).
5. Church Website
The advice for using photographs on a website is no different from their use in any other kind of publication or publicity material. However, St Michael's and St Peter & St Paul's PCCs are aware of the potential risk of inappropriate use of images because of the lack of control over who might see the image and the wide extent of the misuse of the Internet by certain people. The PCCs will seek the consent of parents regarding the use of images on the Internet. Children’s names will not be included in photographs of children published on the church website or in social media unless agreed beforehand by parents of the children concerned.
6. The Press
The use of photographs in newspapers and magazines is already subject to strict guidelines. The Press Complaints Commission’s Code of Practice states that:
• Journalists must not interview or photograph a child under the age of 16 on subjects involving the welfare of the child in the absence of or without the consent of a parent or other adult who is responsible for the children.
• Children must not be approached or photographed while at church without the permission of the church authorities.
• There is no breach of the Data Protection Act 1998 in passing on a child’s name to a journalist as long as parental consent has been secured.
St Michael's and St Peter & St Paul's PCCs will provide names of children to accompany photographs published in newspapers and magazines only where the parent or guardian have provided their consent.
7. Filming Events
St Michael's and St Peter & St Paul's PCCs do not want to prevent parents from filming their children during special events such as church productions, services and festivals. However to ensure children are not identified individually we must insist that at no time are children identified by name during filming or in post-production. We insist also that videos are not shared on media such as Facebook and other social media platforms. Any breach of these two terms will result in our church having to review this policy to fall in line with current guidance on there being no recording at these events. Please support us as a church to follow this guidance to enable us to sensibly protect the children in our care.
On occasions, video films may be made of children on outings, activities or events and performing in church productions. The church will inform parents where arrangements have been made for a commercial photographer to film such an event.
Where a commercial photographer is used, the church will follow the NSPCC guidelines which are as follows:
• Churches should provide a clear brief about what is considered appropriate in terms of content and behaviour;
• Churches should issue the photographer with identification which must be worn at all times;
• Churches should let parents and children know that a photographer will be in attendance at an event and ensure they consent to both the taking and publication of films and photographs;
• Churches should not allow unsupervised access to children or one-to-one photo sessions at home;
• Churches should not approve / allow photo sessions outside the event or at a child’s home.
If children or parents have any concerns about inappropriate or intrusive photography, they should report them to the PCC Safeguarding Representative or other church officer who would report them in the same manner as any other child protection concern.
8. Parental Consent
St Michael's and St Peter & St Paul's PCCs will seek the consent of parents / guardians regarding the use of photographs of children. The consent will include agreement on:
• how and where the photographs will be used and;
• the period of consent.
Date policy adopted:
St Michael's Kingsteignton
15th March 2018
St Peter & St Paul's Teigngrace
5th April 2018
CHILD PHOTOGRAPH CONSENT FORM
Location of photograph:
To the parent or guardian of:
Name of child : ___________________________________________________________
Church/PCC : ____________________________________________________________
St Michael's and St Peter & St Paul's PCCs occasionally take photographs of children in its services or activities for promotional purposes. We would like to use a photograph of your child for our publications or website*.
To comply with the General Data Protection Regulation, we need your permission before we use any photographs we have taken. Please complete the declaration below and return it to us.
I give permission for my child’s photograph to be used by the church/Parish:
For general use
For this single purpose only
I have read and understood the conditions of use on the back of this form.
Signed : ________________________________________________________________
Name (in capitals) _______________________________________________________
*Please note that websites can be seen throughout the world and not just in the United Kingdom where UK law applies.
Conditions of use
1. This form is valid for *four years from the date of signing/*for this project only. Your consent will automatically expire after this time. We will not re-use any images *after this time/*after the project is completed.
2. During this four-year period, the photos will be kept in a secure location and only authorised staff will have access to them. After this period the photos will be privately destroyed.
3. We will only include a child’s full name as photo captions for press releases if the child is not easily identifiable by a member of the public, eg not identified by a school uniform. Addresses will not be disclosed in detail, but we may state eg ‘John Smith from Newark’. Personal email, telephone numbers or social media identities will not be disclosed.
4. If we use an image of an individual child who is identifiable by their apparel, we will not use the name of that child in the accompanying text or photo caption without good reason.
5. If a child is named in the text of a publication, we will not use a photograph of that child to accompany the article unless we have specific consent. For example, we might want to include a picture and a full name of a competition prize winner. However, we will not include a picture and full name of a child in promotional literature.
6. We may use group or class images with very general labels, such as ‘our youth group outing’ or ‘children exploring the Bible’.
7. We will only use images of children who are suitably dressed, to reduce the risk of such images being used inappropriately.