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The West Midlands Police Sports & Wellbeing Association (“Club”) Photography and Video Policy
The Club recognises that Members, Juniors, and visitors to the Club will want to record and share special moments through photographs and video. The Club also uses photography and video to promote the Club and the achievements of Members and Juniors. However, there are risks attached to the use of video and photography:
Under the General Data Protection Regulation (GDPR), personal data is defined as any information that could be used to identify an individual. As such, photographs, or videos, where the subject is easily identifiable are considered personal data. Photographs and video are therefore subject to the same conditions of processing as contact details.
Without appropriate measures in place, allowing photographs and video of children is open to the following risks:
This policy sets out the measures the Club has put in place and the expected behaviour of Members and Juniors. This aims to ensure an appropriate balance between the taking of images for personal record whilst protecting individuals’ right to privacy and safeguarding children and vulnerable adults.
The Policy has been developed using the guidelines of the Child Protection in Sport Unit and the Information Commissioner’s Office.
The Club’s responsibilities
From time to time the Club wishes to take photographs of Members enjoying our facilities to promote the Club in publications, online and on social media. At many of our events (club tournaments and social events) the Club may decide to take wide angle, general images.
In such circumstances, the Club will make it clear that it intends to photograph or film the event and that anyone attending the event, who does not wish to be photographed, should make it known to the event organiser.
Prior to an event or photography shoot, a process will be put in place to ensure any photographer is made aware of individuals who should not be featured in images. This may involve the use of wristbands or stickers.
For young people under 18, parental consent will be obtained before taking and using an image.
In addition to seeking the permission of parents, children will always be consulted about the use of their photograph. This ensures they are aware that the image is being taken and understand what the picture is going to be used for. A secure link will be added to any on-line access facilities.
Using professional photographers
Prior to commissioning professional photographers and videographers, a clear brief will be drawn up outlining:
On arrival at the Club, the photographer will be issued with identification, which must be always worn.
Storing images securely
Images or video recordings, especially of children will be kept securely. Any hard copies of images will be kept in a locked drawer in the Marketing and Communications office. Electronic images will be maintained in a protected folder with restricted access. No unauthorised images of adults and no images of children will be stored on unencrypted portable equipment such as laptops, memory sticks and mobile phones.
Staff and coaches must only take photos and recordings of children using cameras or devices belonging to the Club.
When publishing images, the Club will:
The Club uses CCTV equipment to provide a safer, more secure environment for members and staff and to prevent bullying, vandalism, and theft. Essentially it is used for:
The Club does not use the CCTV system for covert monitoring.
Access to the CCTV recorded footage is limited to designated staff and other authorised personnel (including police) with a legitimate reason to view and/or otherwise use the captured footage, including the provision of evidence in support of prosecution of criminal or illegal behaviour. Authorisation to review any footage will be given to relevant parties on a case-by-case basis which will be determined at the discretion of the Chief Executive in accordance with applicable data protection legislation.
Live footage recording is automatically erased after four weeks. Further details governing the use of CCTV may be found in our CCTV Policy.
Responding to any safeguarding concerns
All staff, volunteers, children, parents, and spectators will be informed that if they have any concerns regarding inappropriate or intrusive photography, these should be reported to the Designated Safeguarding Lead or the Event Organiser or through the website secure reporting system
All reported concerns will be dealt with in the same way as any other safeguarding concern.
If there are concerns or suspicions about potentially criminal behaviour this will include referral to the police.
Photography and Filming consent
All booking forms, both membership and conferencing will have a note to the event organiser/member/guest on the activities taking place and opt out if they do not wish to be included in any filming or photography.