1. This Policy
- This Policy is intended to provide guidance to staff and information to pupils and their parents, carers or guardians (referred to in this policy as “parents”) about how images of pupils are normally used by USPA Live (“the School”). It also covers the School’s approach to the use of cameras, video and filming equipment at School events and on School premises by parents and pupils themselves, and the media.
- It applies alongside the individual parent or pupil consent forms provided and should be understood in the context of any other information the School may provide from time to time about a particular use of pupil images; and more general information about use of pupils’ personal data in the School’s Privacy Notice.
- Safeguarding and online safety issues are more specifically dealt with under the School’s relevant safeguarding, AI and data protection policies – https://kingsinterhigh.co.uk/school-policies/.
- Staff will be subject to other School or Group policies in this area, including social media policies, and should have appropriate training in accordance with their role. In particular, the right to store, handle and publish images of pupils is limited only to designated individuals who have received the relevant training and approval from the Central Marketing senior management in this regard.
2. General Principles of Image Use
- Certain uses of images, including pupil images, are necessary for the ordinary running of the School for example, for administration, identification, educational and curricular purposes, and security. It may not be possible for subjects to object to such uses, although any concerns in this regard will be duly considered by the School.
- Other uses are considered to be in the legitimate interests of the School and its community, where these are unlikely to cause any negative impact on children. The School is entitled lawfully to process such images and take decisions about how to use them, although objections may be raised and the School will seek to accommodate any reasonable concerns. Examples are given in this policy.
- External marketing uses of pupil images are managed on a consent basis. We hope parents will feel able to support the School in using pupil images to celebrate the achievements of pupils, sporting and academic, and to promote the work of the School.
- Such consents are obtained from parents via School forms. Staff will additionally seek specific consent from parents and, as appropriate, pupils for any uses of images which might be unexpected or could be more intrusive. Examples of this are set out further in this Policy.
- Parents should also be aware that certain uses of their child’s images will continue to be necessary for example, administration, education or security; and, while reasonable efforts will be made to accommodate particular concerns or circumstances, it may not be feasible to exclude a child’s image from all media content (for example as a part of a large group photograph).
- Any parent who wishes to limit the use of images of a pupil for whom they are responsible should contact marketing@gouspa.org in writing.
3. Use and Publication of Certain Pupil Images
- In accordance with any consents, notices or objections as may be applicable from time to time, the School will use images of its pupils to keep the School community updated on the activities of the School, and for marketing and promotional purposes, including:
- on internal displays and notice boards within the School platforms;
- as part of the School’s email system and intranet, and in appropriate communications by whatever means with the School community (parents, pupils, staff, and alumni) and its Group;
- as part of School curricular activities for example drama or art, or as a teaching aid, as part of official activities using School devices, tablets and applications;
- on the School Group’s public channels such as the School website, prospectus and its social media channels; and
- occasionally, in formal promotional media and marketing campaigns e.g. external advertisements for the School.
- The School’s policy in respect of the above uses is as follows:
- Legitimate interests will be relied upon for any uses which are either essential (for example, , administration and education) or which fall within a scope of purposes to be reasonably expected. These include via internal School or parent communications, on the intranet, School newsletters / emails, class yearbooks, School magazines and similar occasional publications within the School community. It also applies to any uses whereby an individual child cannot reasonably be identified by someone outside the School community: for example, because their face cannot clearly be seen.The key effect of the School relying on legitimate interests is that, while parents and pupils will be entitled to raise objection to such uses, their specific consent will not be sought beforehand. Any objections will be duly considered by the School, but objections can be overridden by other factors: for example, uses which the School considers necessary.
- Consent is relied on for all external marketing uses – including website, prospectus and social media channels as well as other marketing campaigns – where a child may be clearly identifiable. Where appropriate (owing to the pupil’s age or nature of the use) we may also seek the specific consent of particular pupils.
- The School will take reasonable steps following any objection or withdrawal of consent but may not be able to recall or destroy printed materials. Any particular concerns or vulnerabilities relating to a pupil or their family should be drawn to the School’s attention in advance. The safeguarding and best interests of pupils will remain the School’s priorities at all times.
4. Use of Pupil Images by External Media
- Where practicably possible, the School will always notify parents in advance when the media is expected to attend an event or School activity in which pupils are participating, and will make every reasonable effort to ensure that any pupil whose parent or carer has refused permission for images of that pupil, or themselves, to be made in these circumstances are not photographed or filmed by the media, nor such images provided for media purposes.
- The media may ask for the names of the relevant pupils to go alongside the images. It is not the School’s policy to provide full or first names in this scenario, and these will only be provided where parents have been informed about the media’s visit and either parent or pupil has specifically consented to the sharing of their name, for an appropriate and necessary purpose.
5. Security of Pupil Images
- Professional photographers and the media are accompanied at all times by a member of staff when on School premises or systems. The School uses only reputable professional photographers and makes every effort to ensure that any images of pupils are in suitable dress and held by such persons securely, responsibly and in accordance with the School’s instructions.
- The School takes appropriate technical and organisational security measures to ensure that images of pupils held by the School are kept securely on School systems, and protected from loss or misuse. The School will take reasonable steps to ensure that members of staff only have access to images of pupils held by the School where it is necessary for them to do so.
- Any external processors of pupil images are engaged only for lawful purposes consistent with those set out in this policy, and subject to proper due diligence and contractual protections.
6. Use of Cameras and Filming Equipment by Pupils
- All pupils are encouraged to look after each other, and to report any concerns about the misuse of technology, or any worrying issues to a member of the pastoral staff.
- The misuse of images, cameras or filming equipment in a way that breaches this Policy, or the School’s Bullying Policy, IT Acceptable Use Policy, Safeguarding Policy or Disciplinary Policy / School Rules is always taken seriously, and may be the subject of disciplinary procedures or dealt with under the relevant safeguarding policy as appropriate.