Photo and Video Policy (Under 18s) 

1. Purpose of this policy

This policy sets out how Bloom Educational Courses CIC, trading as Bloom, collects, uses, stores, and shares photographs, video recordings, and other visual media featuring young people under the age of 18. It applies to all organisational activities, including but not limited to:

•  Marketing and communications

•  Website and social media

•  Press and public relations

•  Fundraising campaigns and materials

•  Internal publications

Bloom is committed to protecting the privacy, safety, and rights of children and young people and complying fully with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Legal basis for processing

Under UK GDPR, Bloom must have a lawful basis for collecting and using personal data. Images and recordings of identifiable individuals constitute personal data, and for those under 18, special care is required.

For young people, the lawful basis will be:

•  Explicit consent from a parent or legal guardian (Article 6(1)(a) UK GDPR)

•  Consent from the young person where they have capacity and understanding (typically 13+), but parental consent is still mandatory for those under 18 for marketing and publicity.

Consent must be:

•  Freely given

•  Specific

•  Informed

•  Unambiguous

•  Recorded and auditable

3. When and how consent is collected

Bloom will obtain written parental/legal guardian consent before taking or using any images or recordings of a young person for marketing, PR, or fundraising purposes.

Consent will:

•  Specify the types of media captured (photo, video, etc.)

•  Outline where images may be used (website, print, social media, press, digital advertising, etc.)

•  Confirm that images may appear in externally produced media (press articles, partner features, news coverage, etc.)

•  Clarify that consent can be withdrawn at any time

4. Use of images and recordings

Images and recordings may be used in:

•  Printed marketing materials

•  Digital publications, advertising and e-newsletters

•  Social media channels

•  Website content

•  Fundraising bids and appeals

•  Press releases and media coverage

•  Internal training or presentations

Bloom will ensure:

•  Images are used respectfully and appropriately

•  No identifying details are published without explicit consent

•  Images do not expose young people to risk or distress

•  No commercial sale or transfer of images takes place

·     Staff and volunteers are not permitted to use any personal equipment to take or store photos and recordings of children

·     Bloom will only use 3rd party photographers whose photo and video permissions policy is in accordance with our policy.

5. Withdrawing consent

Parents or guardians may withdraw consent at any time by contacting Bloom.

When consent is withdrawn:

•  The organisation will stop further use of the image immediately.

•  Reasonable steps will be taken to remove images from websites and future publications.

•  Previously printed or distributed materials cannot be recalled, but new use will cease.

6. Data storage, security and access

Bloom will:

•  Store images securely on 2-step-verification protected systems.

•  Limit access to authorised staff only.

•  Keep records of consent linked to each image or media item.

7. Retention period

Images and recordings of young people will be retained for as long as they remain necessary for the purposes for which consent was given, unless:

•  Consent is withdrawn earlier, or

•  A shorter retention period is specified by the parent or guardian.

If consent is withdrawn:

•  Images and recordings will be securely deleted, and

•  Any physical copies will be destroyed.

Images will be reviewed periodically and removed when they are no longer required for marketing, communications, or archival purposes, in line with data protection principles.

8. Sharing with third parties

Images may be shared with:

•  Partner organisations directly involved in a project or event (e.g. Conservation Foundation), but only with a third-party data processing agreement in place and informed consent from parents

·     Images will never be sold or used for commercial third-party gain.

9. Safeguarding considerations

Bloom will:

•  Avoid taking or using images that may be considered inappropriate or intrusive

•  Never publish images of a child who is subject to safeguarding concerns or restrictions

•  Avoid providing personal details that could identify or locate a child

•  Ensure group photos are used where possible for additional safeguarding protection

10. Responsibilities

All Bloom staff and professional photographers/videographers must:

•  Follow this policy at all times

•  Confirm that parental consent is in place before capturing or using an image

•  Report any misuse or safeguarding concerns immediately

•  Ensure that consent documentation is completed, stored, and accessible

11. Policy review

This policy will be reviewed annually or sooner if:

•  Legislation changes

•  Best practice guidelines are updated

•  Significant organisational changes occur

Date of policy: 24th April 2026

Date of next review: 24th April 2027

Signed by: