Photo & Video Consent

 

Photographing and Filming Children

​Parents, children, and football clubs commonly anticipate celebrating and promoting football-related achievements by capturing photographs and videos of children during matches and events. Documenting a child’s participation and progress throughout the season through visual media is widely acknowledged to enhance the enjoyment of the game. Additionally, it is recognised that some coaches find photographs and videos to be valuable coaching tools for supporting players’ development.​

The Football Association (FA) acknowledges that the use of photos and videos on websites, social media, posters, press, or other publications can pose direct and indirect risks to children if not properly managed. However, The FA supports the practice of taking photographs and filming children in the context of football.​

All individuals who wish to capture photographs or film within football settings have a responsibility to acquaint themselves with and adhere to the following guidelines.​

The following guidance below is drawn from The FA and advice provided by the NSPCC CPSU. You can find this advice at:

www.thecpsu.org.uk/help-advice/topics/photography

https://www.thefa.com/-/media/thefacom-new/files/rules-and-regulations/safeguarding/section-8/8-3-photographing-and-filming-children-colour-version.ashx

Common Sense Considerations to Ensure Everybody’s Safety

It is crucial to remember that the majority of photographs and films taken are appropriate and captured with good intentions. By implementing the following measures, we can contribute to ensuring the safety of children in football.​

Do

• Share the FA’s guidance on taking photos and filming with all individuals who become club members, including officials, parents, and caregivers.
• Obtain written parental consent for using a player’s photo and/or film footage in the public domain, such as on the club website, Facebook page, or in newspaper articles. This step is essential in relation to the following point.
• Safeguard children under care proceedings with legal restrictions by ensuring that their images are not made public. Utilize The FA’s Club annual membership information and consent form for this purpose.
• Ensure that all individuals featured in photographs are appropriately dressed, with a minimum requirement of wearing a vest or shirt and shorts.
• Strive to capture images that represent the diverse range of youngsters participating safely in football, including boys and girls, disabled individuals, and members of ethnic minority communities.
• Advise parents, caregivers, and spectators about the potential negative consequences of sharing photos or film footage linked to information about their own or other people’s children on social media platforms like Facebook and Twitter. Caution should be exercised when it comes to tagging.
• Establish procedures for addressing and managing any concerns, including clear reporting structures and a system for contacting the police when necessary. Club and event organizers bear the responsibility of implementing arrangements to ensure that official or professional photographers can identify or receive information about children who should not be subjects of close-up photography or filming. This can be achieved through the provision of recognizable badges, stickers, wristbands, or by establishing a system for photographers to verify with the activity organizer and/or team manager which groups or individuals should not be featured in photographs or film footage.

Don’t

• Do not publish photographs with the full name(s) of the individuals featured unless you have obtained written consent and informed the parents/carers about how the photo will be used.
• Avoid using player profile pictures alongside detailed personal information when sharing content online.
• Refrain from using an image for purposes other than those initially agreed upon, such as publishing it in local press when it was originally intended for a clubhouse commemorative picture.
• Prohibit the recording of photos or film footage in changing rooms, showers, or toilets, including the use of mobile phones that can capture images.
• Ensure that photographs or film footage of children do not include any advertising related to alcohol or gambling.
• It is important to understand that taking appropriate photographs or filming in a public place is not considered an offence, even if someone requests you not to do so. No individual has the authority to determine who can or cannot capture photos or film footage in public areas. If you have serious concerns regarding a potential child protection issue associated with the taking of photos or film footage, contact the police. This course of action should be reserved for situations where there is a belief that someone may be acting unlawfully or endangering a child.

What to do When Parent Consent is NOT Given

It is the responsibility of club and event organisers to establish measures that allow official or professional photographers to identify or receive information about children who should not be subjected to close-up photography or filming.
This may involve implementing a recognisable badge, sticker, or wristband system, as well as establishing a procedure for photographers to consult with the activity organiser and/or team manager to ensure clarity on which groups or individuals should be excluded from photographs or film footage.

General Photography and Filming at Events

During various events, organisers may desire to capture wide-angle, general photographs and film footage of the overall event, the venue, opening and closing ceremonies, and similar moments. Obtaining individual consent for every participating child in order to capture such photography or filming may not be reasonable, practical, or proportionate, particularly in response to the concerns of a limited number of parents.​

In such situations, organisers should clearly communicate to all participants and parents that this type of photography or film footage will be taken and explain the intended purposes for capturing such images.

Filming As a Coach Aid

The FA recommends that coaches who utilise filming as a valid coaching tool should inform parents/carers that it will be part of the coaching program. It is important to handle the storage of film clips with care. Naturally, parental consent must be obtained, and this can be requested at the beginning of the season through The FA’s Annual Membership Information and Consent Form.

Secure Storage Practices

It is crucial to securely store photographs or film recordings of children.

• Hard copies of photographs should be stored in a locked drawer to ensure restricted access.
• Digital photos should be placed in a protected folder with limited access.
• It is important not to store digital photos and film footage on unencrypted portable devices such as laptops, memory sticks, or mobile phones.​

For clubs and leagues

If you are storing and utilising photographs for official purposes, such as identity cards to identify children and adults, it is essential to comply with legal requirements regarding the handling of personal information.​For guidance on data protection and other privacy regulations, please refer to the Information Commissioner’s Office (ICO) website at ico.org.uk.

Misuse and Manipulation of Photographs and/or Film

It is crucial to be aware of the potential misuse and manipulation of photographs and film footage, especially when it involves vulnerable children. Individuals with malicious intent may intentionally target vulnerable children to capture photos or film footage, which can then be uploaded to social media platforms or shared with like-minded individuals or groups driven by sexual interests.​

Unfortunately, these photos or film footage can also be utilised to threaten and coerce the child into engaging in unwanted and illegal sexual activities. In some instances, the taking and sharing of such content may contribute to broader bullying of the targeted young person by peers, with the intention of causing humiliation and embarrassment.​

It is important to note that even in the context of a shared joke among friends, without abusive intent, a young person who captures and shares inappropriate photos or film footage may still be committing a serious offence and could face criminal prosecution.

Responding to Concerns

It is important to inform all club officials, volunteers, children, and parents/carers that if they have any concerns regarding inappropriate or intrusive photography or filming, whether during general club activities or at events, they should report these concerns.
Reports can be made to the following individuals or entities:

The Internet Watch Foundation

E: [email protected]
T: 01223 237700
W: iwf.org.uk
Fax: 01223 235921
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Potential Risks

 

Inappropriate Taking and or Use of Photographs or Filming of Children

There are individuals who may deliberately aim to capture inappropriate photos or film content that can be potentially illegal and harmful. Examples of such behaviour include:

• Taking photos of children while they are changing
• Capturing photos in restroom areas
• Using a camera at a low angle to photograph up girls’ skirts
• Creating photos and film footage that can be easily manipulated or edited, potentially for the creation of child abuse images or videos

The Identification of, Contact With, or Grooming of a Child

The inclusion of significant personal information, such as a child’s full name or address, along with their photograph or film, can make them more easily identifiable to third parties. This increased identifiability has resulted in instances where children have been located, contacted, and subjected to grooming. Even if personal details are kept confidential, information that reveals the child’s school, club, favourite sportsperson, or team can still potentially be exploited for grooming purposes.​

Certain circumstances pose a higher risk of identification and contact with a child, including:

• Cases where legal restrictions apply, such as when a child is under the care of local authorities or placed with an adoptive family.
• Situations involving restrictions on contact with one parent following a parental separation, particularly in cases involving domestic violence.
• Instances where a child may be a witness in criminal proceedings

Commissioning Official or Professional Photographers and the Local Media

When engaging professional photographers or inviting the media to cover a football activity, it is crucial to establish clear expectations and ensure effective communication between all parties involved. The key is to plan in advance and initiate early discussions. To facilitate this process, please follow the steps outlined below:

• Provide a detailed brief outlining what is considered appropriate in terms of content and behaviour.
• Inform photographers and media representatives about your club’s unwavering commitment to safeguarding children.
• Determine who will be responsible for storing the film or photographs and specify the duration for which they will be retained and/or utilised. Additionally, clarify the intended use, such as placing them on a website for sale or distributing thumbnails to the club to coordinate sales.
• Determine who will be responsible for storing the film or photographs and specify the duration for which they will be retained and/or utilised. Additionally, clarify the intended use, such as placing them on a website for sale or distributing thumbnails to the club to coordinate sales.
• Issue professional photographers with identification that must be visibly worn at all times during the event.
• Ensure clear communication regarding areas where all photography is strictly prohibited, such as toilets, changing areas, and first aid zones.
• Educate photographers on identifying situations where parental consent is necessary and emphasise the importance of refraining from taking photos or filming children without such consent.
• Do not allow off-site photo or filming sessions, such as at a young person’s home, and limit photography to the designated event area.
• Notify participants, parents, or guardians well in advance of the event about the presence of a professional photographer.

Video Calls with Children – Specific Guidance for Coaches/Managers/Scouts

Engaging in online video calls provides coaches, managers, and scouts with a valuable means to stay connected with others in similar roles, offering training ideas, fitness tips, and online skills challenges. However, as a coach/manager, it is crucial to maintain appropriate boundaries within your digital space.​

Please ensure that you consistently uphold the principles outlined in your code of conduct and bear in mind that, as a coach/manager/scout, you remain in a “relationship of trust” even when providing encouragement and coaching online. To ensure the safety of both yourself and those you support, follow the procedures outlined below.​

Please visit https://www.thefa.com/about-football-association/who-we-are/county-fas for a list of County FAs and their websites. Then visit the relevant website to find your County FA’s DSO.

Digital Communications and Children

When communicating with 16/17-year-olds who hold positions of trust and/or responsibility within football, it is important to follow the following guidance:

• Prior to engaging in email, social networking, or mobile phone communication with young people in positions of trust, obtain signed consent from their parents/carers. Ideally, clearly identify the adult(s) who will be involved in such communication, and ensure that the purpose of the communication is explicitly stated.
• Both parties should limit their communication to matters directly related to the identified professional role(s).
• When exchanging emails or communicating through social media, copy either the parent/carer or the Welfare Officer to ensure transparency.