Children & Young People Event Photography Policy

1. Purpose

This policy sets additional protections for photographs and videos of children and young people appearing in SNOVA event galleries or proposed social posts. For this policy, a child means a person under 18.

2. Core principles

Best interests and safety of children take priority over engagement, marketing or convenience.
Use the least amount of child personal data needed.
Private/unlisted event settings should be the default for child-accessible events.
Do not encourage children to make information more public.
Do not use child photographs for SNOVA marketing without separate, specific authorisation.
Make reporting/removal tools easy to find.

3. Age and access

Organiser accounts and social connections: 18+ only.
Age 13-17: may use guest capture features where permitted by the organiser and appropriate to the event.
Under 13: use only with parent/guardian supervision or authorisation where required; no independent organiser account or social connection.
SNOVA should avoid asking children for exact date of birth unless needed; prefer age-range or adult-confirmation mechanisms where proportionate.

4. Photographs containing children

The event organiser is responsible for assessing photography permissions and the lawful basis for an event. At schools, clubs, nurseries, youth organisations or other safeguarding-sensitive settings, the organiser should follow its own safeguarding policy and ensure opt-outs/no-photo arrangements are operational.

5. Social-media publication

Publication to public social media creates materially greater privacy risk than inclusion in a private event gallery. SNOVA should require an explicit organiser confirmation before posting an image that the organiser knows or reasonably believes features a child.

Automatic publishing should not be used for events where children are the main subject. Where automatic publishing is switched on, a post that shows a child should be routed to a person for approval rather than published on its own.

Recommended confirmation wording:

“I confirm that I am authorised to publish this image and that any permissions or lawful basis required for children shown in it are in place.”

6. High-risk uses that should be disabled by default

Public location tagging of children.
Using face measurements to identify a child. Face measurements are stored with photos and used only for Find my photos and to group photos, never to identify a child.
Targeted advertising/profiling based on child images.
Automated public posting of child images without organiser confirmation.
Public searchable indexing of child-accessible event galleries.
Displaying child full names alongside images unless clearly necessary and authorised.

7. Reporting and removal

Provide an easy 'Report/Request removal' function on event galleries. Safeguarding or child-image concerns should be prioritised. Contact: privacy@snova.uk. Serious illegal child sexual abuse material must be handled under applicable reporting and law-enforcement obligations and should not be retained or redistributed unnecessarily.

8. Children's Code assessment

Because SNOVA may be likely to be accessed by children at events, conduct and document a Children's Code scope assessment and a Data Protection Impact Assessment before launch or material feature changes affecting children.