Guidance for Photographs to be used in Publicity/Promotional Material

These guidance notes cover the provision and receipt of references for both staff and students and should be read in conjunction with the University's Data Protection Policy.  This document is Appendix X to the policy.

General Photographs

If individuals are not readily identifiable from the photograph and it seems unlikely that any damage or distress will result from such processing then it will not be necessary to obtain consent. Therefore, students and staff whose images appear as incidental detail (e.g. general degree day or campus photographs) in publicity photographs will not need to give consent for the use of their image.

Photographs of Group Activities

Where photographs are to be taken of a group activity (e.g. a seminar) then this should be announced in advance so that individuals may leave the room briefly if they do not wish to appear in the photographs.

Photographs of Small Groups/Individuals

Where photographs are to be taken of a single individual, or a small group of individuals, where individuals are the main subject of the photograph (even if they are not identified by name), consent should be sought before any photographs are taken. When gaining consent, it is important to ensure that individuals are informed of what the images will be used for (e.g. where they will be printed and who will have access to them). In most cases, verbal consent is all that will be required although photographers may wish to use a standard release form, to be signed by the subject(s), to ensure that they have appropriate consent.

Publishing Photographs on the Web

If it is intended to make photographs available on the web, wherever possible this should be restricted to the Intranet rather than the Internet. Publishing on the Internet potentially transfers personal data outside of the EEA (the fifteen EU Member States together with Iceland, Liechtenstein and Norway) for which rules on gaining consent from individuals are much stricter. If photographs (except where student/staff images appear as incidental detail) are to be published on the Internet, written consent should be obtained from the subject(s) on a standard release form.

For further guidance, please contact the University's Data Protection Officer.