Rules

Photos, consent and children's privacy in school marketing

A photographer reviewing pictures on the screen of a camera

Photos of pupils are the most effective part of most school marketing, and the part with the most risk. The rules depend on the country, but the principles are similar.

Ask, record and respect

Get clear permission from parents before using a child's photo in marketing, and record it. Make it easy to say no, and to withdraw consent later. Check the list before every photo is published.

UK and Europe

In the UK and the EU, photos of identifiable children are personal data under data protection law (the UK GDPR in the UK). The Information Commissioner's Office publishes guidance for schools. Consent for marketing should be specific and freely given, and schools need to be able to show who agreed to what.

United States

In the US, FERPA protects student education records at schools that receive federal funding. Schools can publish some "directory information" unless parents opt out. COPPA applies to online services that collect personal information from children under 13.

Practical habits

Avoid full names next to photos of children.
Check backgrounds for name labels, timetables or screens.
Take care with photos of children who may be at risk, for example because of a custody issue.
Remove photos when consent is withdrawn.

This is a summary for planning only. Ask your school's data protection lead or a legal adviser about your own situation.