Media consent policy and procedure
Please note this policy covers still images, audio and video content. For brevity, we may refer simply to imagery and photographers.
Images count as personal data under the Data Protection Act 2018 and the General Data Protection Regulations (GDPR). In many cases, they will be ‘special category’ personal data because they provide information about religious affiliation or other special categories under data protection legislation. Some might also contain images of children. Following C of E guidance and best practice, images should only be used with the consent of the person in the image, unless one of the exceptions described in the procedure below applies.
The procedure below should be followed for planning events, obtaining and recording consent, storing imagery, and the procedure for withdrawing consent.
A picture paints a thousand words, and photos play a huge part in sharing our mission to become a more Christ-like Church. However, we all share the responsibility to think carefully before taking any images, to consider what the images will be used for and why, and to properly communicate this to all involved.
Consent for diocesan events
For large, public diocesan events or services – such as ordinations – the following notice is included in the order of service:
This is a public occasion. Please be aware that photography and filming will take place during the service. A ‘no photography’ zone is available; please speak to a sidesperson who can provide further information. No other photography or filming is permitted during the service. For any questions or concerns relating to photography taking place today please speak to the photographer or email communications@oxford.anglican.org.
Where possible, a ‘no photography’ zone should be set up. Responsibility for arranging this lies with the event organiser, and they would be expected to liaise as needed with venue staff. This should be organised before the day of the event. On the day, the event organiser should check in with venue staff and ensure this area has been communicated to sidespeople. Sidespeople should then direct attendees to sit in this area as needed.
The Communications team and/or any freelance photographers should speak to the event organiser(s) or sidespeople prior to the start of the service to ascertain where they can and cannot shoot.
Planning an event
If you are planning an event, think early on about whether you will need photo/videography. Make sure to discuss this in advance with the Communications team to establish need and availability. In the event the Comms team cannot cover your event, they will suggest an appropriate freelancer and obtain quotes.
Where freelancers are used, a copy of this procedure will be shared with them by the Communications team, and they will need to follow this procedure. Consents must, however, be obtained by diocesan colleagues, not the freelancer, where at all possible.
Colleagues should check with Communications before taking photos at any event to ensure it is appropriate to do so (and to ensure they understand and follow this procedure).
You will need to obtain consent from each guest (and, in the case of children and young people, an appropriate guardian) and give them the option to not have their image captured.
Include a section in the Eventbrite Order Form that covers the questions in the consent form at the end of this policy. If a delegate doesn’t give consent for imagery, they need to give permission for themselves to be identified, either with a reference photo or with a sticker or a badge. Event organisers should download and send Communications the consent form responses as an Excel document for them to store alongside imagery. This document should then be deleted from personal files.
At or before the event, any delegates with no consent should either have their reference photo taken or be given an identifying sticker or badge.
At the event, where possible, provide a clearly labelled area in the venue where no filming or photography will take place. Mention this to delegates at registration, and to the Comms team ahead of your event.
At the event, the Comms team will make a reasonable effort not to photograph or video those delegates without consent and those who choose to stay in the No Filming Zone. However, this does not guarantee that this person will not be caught in the background of wide-angle shots. If this does happen, the reference photo and/or identifying stickers will be used to identity that person, and the Comms team will decide if that person shall be blurred out of the background or if that shot will be designated as not to be used.
After the event, the consent information should be stored on the Communications team’s Image Library on Sharepoint in the relevant event folder, alongside the imagery.
Online events
It’s equally important to obtain consent before sharing a Zoom or Teams recording after a call or conference. For best practice, if your event has a registration page, include the consent questions as per the form at end of this policy. Make clear that anyone who does not consent will need to have their camera switched off throughout the call, and may also wish to change their onscreen name.
At the start of your event, remind those present that the event is being recorded, and let them know they should turn their camera off and/or change their onscreen name if they wish.
The Comms team do not have capacity to blur or edit individuals in Zoom or Teams meetings, unless in exceptional circumstances. If someone later withdraws consent for a call being publicly available, sections of or the entire call (depending on visibility throughout) will be removed from the internet.
Photographing or videoing children and vulnerable adults
Imagery of children and young people involved in church activities can be positive and bring useful publicity, but there are some important issues to note.
- Children under the age of 10: consent should be gained from their parents;
- Children aged between 10 and 18: consent should be gained from parents and the children themselves;
- It would be good practice to ask children younger than 10 before you use their photograph where appropriate.
Let parents and children know how, where and in what context an image may be used – i.e. on a public website, through social media and in printed resources. Assume a photo will be used in all these places when explaining consent to those involved in the photos/videos.
Consent is not needed if people, including children, appear in a wide-angle group image in a public space (for instance, a photograph of the church fete). In these circumstances, organisers should make clear to all participants and parents that these kinds of images will be taken, and for what purposes.
For instance, if the event is a church service, nativity play or similar, then a verbal notice can be given out at the beginning for the leader of the service or event, asking that any parent who objects to images being made of their child should either remove their child from view of the camera or approach the leader afterwards to ensure that any image they object to is not used.
Be careful where consent appears to be implied – though someone takes part in a group photo, they may not understand how and where that photo is going to be used. It’s important to be clear.
Complete a parental consent form for use of images of children, ideally as part of the process for registering and consenting the child’s participation in the activity or event.
Leaders of activities have a responsibility to put in place arrangements to ensure that any ‘official’ photographers can identify (or be informed about) which children should not be subject to close-up photography or videography.
Withdrawing consent
By law, anyone can withdraw their consent for an organisation to use any images or videos taken, even if they previously gave consent. To withdraw consent, an individual or guardian must:
- Ideally contact the Communications team at communications@oxford.anglican.org and withdraw consent, naming the individual, in writing. Should the consent withdrawal be given to an alternative member of staff or freelancer, they should then pass this onto the Comms team straight away.
- The Communications team may seek further information, including contact information, details of the event(s) at which they were digitally captured, screenshots of them appearing in any images, and/or a reference photo to help identify the individual.
- The Comms Team will use the reference photo to locate the person in any captured content and will remove any published appearances of their likeness from diocesan-managed social media platforms and websites. This will cause past posts and videos to be taken down from public view. We may use Immich, a self-hosted photo and video management solution, to help identify all images containing the person(s) in question. Immich stores all photos, albums and settings locally on diocesan devices belonging to the Communications team. Immich do not have access to this data, nor do they transmit or store it on any of their own servers.
- The Comms Team will look through the raw footage and images stored on Sharepoint and remove them from the library.
- Once sure that all likenesses of the person have been removed, the Comms team will delete the reference photo and contact the individual to inform them of the completion of their request, outlining the steps taken.
Storing media
Where possible, avoid capturing media on personal devices – use work phones or cameras.
All media should be sent to the Comms team for filing, alongside consent forms. Imagery should be permanently deleted from work phones or cameras and other SharePoint files once they are saved to the Communications image library, to avoid any confusion or issues with consent.
Media will be stored securely on the diocesan Sharepoint image library, and on Immich, a photo and video storage system. Immich stores all photos, albums and settings locally on diocesan devices. Immich do not have access to this data, nor do they transmit or store it on any of their own servers. The full Immich privacy policy can be found here.
Consent for the use of media will last for three years from the date of signing. After this period, your image will no longer be used for publications, displays, or promotional purposes without renewed consent. Imagery may be retained permanently for archiving purposes. If we wish to reuse it after 3 years, we will ask for your consent again before doing so.
Anyone can request that their imagery be permanently deleted at any time by contacting communications@oxford.anglican.org.
Hard copies of photos should be stored in a locked room or drawer by the Communications team.
Copyright
All imagery should be credited (C) Diocese of Oxford unless otherwise stated. Imagery should only be used in diocesan publications. Additional permissions need to be acquired via the Communications team for use externally.
Diocesan staff and senior clergy
Consent for photographs of new starters in Church House Oxford and the Area Offices is recorded as part of the Communications induction. Staff may opt out of website publication and/or photography more generally. Consent for website use remains in place for the duration of employment and can be withdrawn at any time via the procedure above.
Senior clergy, by virtue of their public leadership roles, should expect a higher level of visibility in diocesan and external communications.