Photographs of both students and staff are considered personal information under the Data Protection Act and the data protection principles apply to them. When taking or asking for photographs, staff need to keep the following in mind:

  • Photos should only be taken or asked for when necessary.
  • The subject of the photo should be told where the photo will be used.
  • People should be given a chance to opt out when a photograph is taken.



Getting permissions for photographs

Photographs are not sensitive personal data as defined by the Data Protection Act, but they are a very easy means by which to identify a person. Photographs of students and staff are required for two purposes: administration and publicity. Permission for each purpose can be indicated in two ways.

Administrative purposes could include:

  • proof of identification, for example, the production of the student card or staff card
  • processing of applications for entry to the School
  • showing students their classmates on photo boards within a department
  • showing students their classmates in Web CT, the School's Virtual Learning Environment (password protected)  

In general, once a student has given their photograph to the School as part of  their application, it can be used for any of the above purposes. 

Publicity purposes could include:

  • the School's official publications
  • on the website, to show potential students what life is like at the School
  • in departmental publications and newsletters  

Unlike photographs used for administrative purposes, those used for publicity purposes tend to be taken  for a particular publication or web site. As such, it is best to use the following verbal script to ensure that people know where the photograph will appear. This gives someone the chance to refuse to have the photo taken or to move out of the frame of a group photograph. The verbal script that should be used follows. Choose the option within the square brackets that most suits your situation.

        "I'm taking this photo which will appear [in publication/on photo board/on the web site]. If you don't want to be in this photo, please [say so/leave the room/move to the side] now. By staying within the frame of the picture, you are giving consent for the photo to be used [in publication/on photo board/on the web site]."




Once the photo is taken and put up somewhere public, the subject of the photo still retains the right to ask for it to be taken down. Should a request be received for a photo to be removed from the web site, a photo board or other public place, we have 21 days to respond and remove the photograph. If you are in the position of wanting to have a photograph removed from a public place, please contact the School's Data Protection Officer at

It is much harder to opt out of a print publication, particularly one with a large print run. Use the script above for any photographs likely to appear in a print publication and make it clear it will be fairly impossible to remove the photograph once the printing has been done.