Ensure correct use of images

The University of Manchester often takes photographs or video film for publicity purposes. These images may appear in our printed publications, on our website, or both. This guidance covers photos or video (images) of people taken for such purposes.

Personal Data

If the image can be used to identify an individual and tell you something about them it is likely that it will be personal data for the purpose of the General Data Protection Regulation and the Data Protection Act 2018. People can obviously be identified from names but may also be identified from contextual information e.g. captions.

Photos of specific individuals/groups

Where an image is clearly of an individual or group of individuals, who are the focus of the image, it will be personal data, and consent is required to use it.

Consent forms must explain clearly and fully how the image will be used, and must also inform the individual how they can withdraw consent should they choose to do so. The University’s consent form can be found here.

Photos where individuals inadvertently appear in the background

It will not normally be necessary to obtain the specific permission of all who appear incidentally in the background of publicity shots where they are clearly not the focus of the image.

Photos of large crowds/events

Where an image does not focus on one individual or group of individuals, the data is unlikely to be personal data. In addition, it may not be practicable to obtain the consent of every individual. However, it is good practice to ensure that there are clear signs around the venue indicating that publicity photos are being taken.

Publication on the website or social media sites

Publishing an image on the web or social media is a potential disclosure to the world at large, and not just in the United Kingdom. Particular care must be taken therefore to obtain appropriate consent where the image constitutes personal data. In cases of doubt you should err on the side of caution and not publish the image.

Children

In the UK only children aged 13 or over who are judged to have the capacity to understand the consequences of a decision are able provide their own written consent. For children under this age written consent must be sought from whoever holds parental responsibility for the child. The University’s consent form for parental consent can be found here.

Further information on The University of Manchester’s visual identity and general photography guidelines can be found here.