Data Protection Considerations for Images and Footage
Please note: this guidance has been updated (October 2025). This does not affect any actions taken based on prior advice on this page and requires no retrospective actions to be taken.
When taking photographs or filming for University purposes, such as at events, it is likely you may capture, or want to capture, images of people. Images of identifiable individuals are personal data and where these are captured by those working for the University, for University related purposes, these activities will be subject to our obligations under Data Protection laws.
Do we need to let people know we are taking photos or filming?
In all circumstances, wherever reasonably possible, you will need to make sure attendees know that photography or filming is taking place. Ideally this should be ahead of, and certainly during, the event.
Ways to inform people include using notices at the venue in the areas you will be taking photographs or filming. Any notices should be prominent and in simple terms advise people that photography is taking place along with who to make aware if they do not want to be included in the photographs. Notification should not include reference to consent because realistically they have no freely given choice with regard to wide shots, so do not allude to ‘consent’ in these messages. However, if they have concerns or want to avoid being photographed or filmed, they should have a route to raise this with the appropriate contact.
Whilst photographs or videos are being taken, the photographer should be clearly identifiable to event attendees, a prominent lanyard or ID label may help with this.
The University includes references to the potential for filming and photography on site within existing Privacy Notices. In some instances it will not be possible to ensure that all those who may feature within a wide shot are directly informed or notified by way of signage. It is accepted that the information within these notices may be relied upon in these scenarios, though it is the assumption that where smaller and more focussed groups are to be photographed or filmed that all reasonable steps will be taken to provide additional notification or signage.
Do we need consent?
Photography and filming that does not have any particular focus on any one individual, and that does not have a context of a sensitive nature can be taken and used on a basis other than consent. Those that may be captured within those images of footage should be made aware that photography or filming is taking place and who they can contact if they have a concern about being photographed or filmed. Consideration should always be given to capturing photos or filming in a way that is as unintrusive as possible.
Examples of this can include:
- Wide shots of non-sensitive campus activities, such as open days, events, concerts, festivals, and ceremonies;
- Wide shots of teaching related activities, such as field trips.
What about images and filming of children under 18?
The personal data (image) of children requires extra care to be taken. The same principles as above will apply, but you MUST ensure that the legal parent or guardian are made aware that you intend to capture images or undertake filming prior to doing so. You should also be clear on what you will do with it (including if you intend to publish it) and you should ensure that they have a means to object (or ‘opt out’) of the photography or filming. If the child is old enough to exercise their own preferences (we would recommend 16 years old as a guide) you should take into account any objections from the child also.
If you are unsure and need advice, contact imps@reading.ac.uk
What do we mean by a sensitive context?
We would recommend that staff avoid taking photos and capturing footage of scenarios that may be sensitive in context. These are circumstances where the nature of the activity being captured could give rise to revealing more sensitive information about those that feature, and/or, where there is a greater expectation (or reasonable assumption) that photography or filming will be restricted.
Examples of this can include:
- An event organised for those with particular needs or accessibility requirements, for example, quieter options for open day visits for those with neurodivergence;
- Shots taken in spaces where there may be a greater expectation of privacy, such as around entrance facilities for occupational health, counselling and welfare support, halls of residence, or within gym environments.
These are not exhaustive, and consideration must be given on a case by case basis. Advice can always be sought from imps@reading.ac.uk and if you have a justified need, we may recommend that you seek consent from those that feature.
What do we mean by capturing photos or filming that is as unintrusive as possible?
Images and filming should be taken from the least obtrusive angles available wherever reasonably possible. For example, good practice at a large event or conference, would be that photographs are taken from the back of the auditorium as opposed to the front. Even in this example it is likely you will not have everyone facing away from you, so we advise you exercise some discretion.
When should we obtain documented consent?
There are some limited circumstances where documented consent for the capture of images and footage is necessary. This is required where the images or filming is intended to be used for University core marketing and advertising purposes. This may be referred to as stock photography or where the images or recordings are to be used for activities that may incur production, printing or distribution costs.
Examples of such include:
- Content for inclusion within printed or digital brochures, prospectuses, signage or leaflets;
- Stock photography to be used on University managed websites and advertising, external advertising posters or screens (such as billboards) or web adverts;
- Content for the University’s core advertising activities and that used on social media channels managed by the central Marketing Communication and Engagement department;
- University promotional videos;
- Images or filming that will also include a personal bio or additional personal details of an individual. For example, students who are named and providing information about their course of study or university experience and where this will be made publicly available.
These are not exhaustive, and consideration must be given on a case by case basis. Advice can always be sought from imps@reading.ac.uk
Why are these different?
These kinds of activities present greater risks to the University if used without explicit agreement. Later objections to any use, or requests to cease use, can be more challenging and complex to address. For this reason we ask for documented agreement for the capture and use to ensure that all those involved are clear on the use intended and their rights (which may include copyright or intellectual property rights).
We need consent, what can we use for this?
We have a number of image release forms available for differing scenarios, and dependant on who is taking the images or filming (for example, the University, or an external photographer).
Guidance on what form to use and further advice can be found here on the
What about staff photos?
Photographs taken for internal only noticeboards or internal only department webpages do not require consent, however, you must inform the person to be photographed of where the images will be displayed and the purposes for which it will be used. The best approach is to notify staff on arrival that your department like to display their pictures to help students, and to give them a route to raise any concerns. If they have an objection to this, you must consider other ways that you could meet these objectives, for example, including a name only. Some staff may be happy to have their image on display internally, but not to the world at large via an internet search
If the photograph or video is intended to be published on a University or other webpage or social media platform then this should be made clear, and the appropriate image release form should be used. If the photograph was initially taken for the purpose of pinning to the internal notice board and now the school would like it made available on the website, the colleague will need to be asked and the colleagues agreement given in writing, ideally on the image release form.
Where can I go for advice?
If you have any questions or queries please contact imps@reading.ac.uk