Photography, Filming and Consent Policy

Street Lights Collective CIC uses photography, filming and storytelling to celebrate community, evidence impact, promote events, share opportunities, support funding applications and communicate the values of Presence, Power and Purpose.

Because the Organisation works with children, young people, families, communities affected by serious youth violence, safeguarding concerns, contextual risk, trauma, social media pressure and public visibility, all media activity must be carefully controlled.

This policy ensures that photography, filming and consent are managed in a way that is safe, lawful, respectful, trauma informed and aligned with safeguarding duties.

This policy applies to all media created, collected, received, stored, published or shared by or on behalf of Street Lights Collective CIC.

This includes:

• photographs
• video recordings
• audio recordings
• livestreams
• screenshots
• social media content
• website images
• promotional images
• funding evidence
• case study material
• testimonials
• press and media content
• event photography
• school based images
• community event images
• images received from partners, parents, carers or participants
• This policy applies to all settings where Street Lights operates, including schools, youth clubs, community venues, public events, online sessions, mentoring spaces, festivals, workshops, training sessions and NEET Futures placement activity.

This policy is informed by relevant UK law and safeguarding guidance, including:

• UK General Data Protection Regulation
• Data Protection Act 2018
• Children Act 1989 and Children Act 2004
• Working Together to Safeguard Children
• Keeping Children Safe in Education where work is delivered in schools or education settings
• Charity Commission safeguarding expectations for organisations working with beneficiaries, staff and volunteers
• NSPCC guidance on photographing and filming children
• ICO guidance on children and personal information
• Street Lights Collective CIC Safeguarding and Child Protection Policy
• Street Lights Collective CIC Data Protection Policy
• Street Lights Collective CIC Online Safety and Social Media Policy
• Images and recordings of identifiable people are personal data. Images and recordings of children require particular care because children merit specific protection in data protection law and safeguarding practice.

Street Lights Collective CIC will only take, use and share images or recordings when there is a clear and legitimate reason to do so, when safeguarding has been considered, and when the individual has been treated with dignity and respect.

The Organisation will not use images or recordings in a way that exposes a child, young person, family or adult at risk to harm, embarrassment, exploitation, stigma, retaliation, online abuse, unwanted contact or loss of privacy.

No image, recording or story is more important than the safety, dignity and rights of the person involved.

Street Lights Collective CIC will identify an appropriate lawful basis before taking, using or sharing images or recordings. In many community settings, consent will be used because people should have genuine choice about whether their image or story is used.

Consent must be:

• freely given
• specific
• informed
• clear
• recorded
• easy to withdraw
• separate from attendance wherever possible
• Where consent is not the lawful basis, Street Lights must still be transparent about how images are used, must assess privacy and safeguarding risk, and must give people clear information about their rights.

Consent for taking an image is not the same as consent for publishing it. Consent forms must explain where and how images may be used.

For children under 18, consent must be obtained from a parent or carer with parental responsibility unless a school, local authority or partner has already obtained valid consent for the specific purpose and has confirmed this in writing.

Where a young person is old enough and mature enough to understand the decision, their own views must also be sought. A child or young person must never be forced, pressured or manipulated into being photographed, filmed or recorded.

If a child or young person says they do not want to be photographed, filmed or included, this must be respected even if parental consent has been given.

Extra care must be taken where a child or young person:

• is looked after or care experienced
• is adopted or subject to special guardianship arrangements
• is affected by domestic abuse or family conflict
• is involved with youth justice, gangs, exploitation or serious youth violence concerns
• is subject to a court order, safety plan or social care involvement
• is at risk of being located by someone unsafe
• is known to be vulnerable to online harm or retaliation
• has asked for their identity to remain private

Adults must be asked for clear permission before their image, voice, name, story or testimonial is used. This includes parents, carers, family members, staff, practitioners, volunteers, community members and partners.

Where adults are vulnerable, distressed, involved in safeguarding processes, affected by trauma or sharing sensitive personal experiences, consent must be handled with particular care. They must understand what they are agreeing to and must not feel pressured to take part.

Consent forms must clearly explain:

• who Street Lights Collective CIC is
• what type of image, recording or story will be collected
• why the content is being collected
• where the content may be used
• whether the content may appear on the website, social media, reports, funding applications, newsletters or printed materials
• whether names will be used
• how long the content may be kept
• how consent can be withdrawn
• who to contact with questions or concerns
• that safeguarding concerns may override confidentiality

Street Lights Collective CIC recognises that images and recordings can create contextual safeguarding risks. An image can reveal who a young person is with, where they are, what area they are linked to, what school they attend, what group they are part of, or what programme they are involved in.

Before taking or sharing media, staff must consider whether the image or recording could increase risk through:

• postcode conflict or area based tension
• gang related retaliation
• criminal exploitation
• child sexual exploitation
• online grooming or unwanted contact
• bullying, harassment or humiliation
• identification of a vulnerable child or family
• exposure of a safe location or confidential venue
• misuse of images by others
• association with serious youth violence narratives
• damage to dignity or future reputation
• If there is any concern that an image or recording may increase risk, it must not be used until the DSL has reviewed the matter.

Photography and filming should be planned in advance wherever possible. Staff must explain to participants that photography or filming will take place and must identify those who have not given consent.

The following rules apply:

• only authorised staff, practitioners, volunteers or approved photographers may take images for Street Lights purposes
• personal phones should not be used unless authorised for a specific reason and images are transferred securely and deleted from the device as soon as possible
• images must be appropriate, respectful and connected to the Organisation’s work
• images must not be taken in changing areas, toilets, private rooms or any setting where privacy is expected
• images must not show children or young people in a state of distress unless there is a clear safeguarding reason to record evidence and the DSL has advised
• images must not glamorise violence, gangs, weapons, drug use, exploitation or unsafe behaviour
• images must not reveal confidential information on walls, paperwork, screens or badges
• staff must remain alert to people who do not want to be photographed or filmed

Street Lights will avoid publishing full names of children and young people alongside images unless there is a clear, safe and agreed reason to do so.

The Organisation will not publish information that could unnecessarily identify a child or young person, including:

• home address
• school name where not already public or approved
• exact location of regular attendance
• social care status
• youth justice involvement
• details of trauma or safeguarding history
• gang related information
• personal contact details
• private family information
• Where case studies are used, names and identifying details should normally be changed unless explicit permission has been given and safeguarding risk has been reviewed.

Images and recordings must only be shared through approved Street Lights channels or approved partner channels.

Before posting content online, the person responsible must check:

• consent has been obtained and recorded
• the image or recording is respectful and appropriate
• no child or adult at risk is identified without proper permission
• no safeguarding or contextual risk is created
• no confidential location or personal information is visible
• comments and messages can be monitored where appropriate
• the content supports the values of Presence, Power and Purpose
• Street Lights will remove images or recordings where consent is withdrawn, where safeguarding risk emerges, or where the Organisation considers that continued use is no longer appropriate.

Livestreaming creates additional risk because content can be captured, copied, shared and misused quickly. Livestreaming involving children or vulnerable participants must be approved in advance by a Director and, where safeguarding risk is present, the DSL.

Before livestreaming, Street Lights must consider:

• who will be visible or heard
• whether children or young people have consent to appear
• whether names, locations or personal information could be revealed
• who can access the livestream
• whether comments will be moderated
• whether recording will be kept afterwards
• how safeguarding concerns will be managed during the livestream

At events, Street Lights must use clear notices to inform people that photography or filming may take place. Notices should explain who is taking images, why images are being taken, how images may be used and who to speak to if someone does not want to be included.

Where possible, people who have not given consent should be identified discreetly through practical arrangements agreed before the event. This may include wristbands, marked registers, seating areas, staff briefing or photographer briefing.

At large public events, it may not always be possible to obtain individual consent from everyone in the background. In these cases, Street Lights must still act fairly, avoid intrusive images, use clear notices, respect objections and avoid publishing identifiable images of children without consent.

Where Street Lights delivers work in a school, college, alternative provision setting or partner venue, the Organisation must follow the host organisation’s photography and consent arrangements as well as this policy.

Street Lights must not assume that consent exists. The host organisation must confirm whether photography or filming is permitted and whether relevant consent has been obtained.

Where Street Lights wishes to use images for its own promotion, reporting or evidence, consent must cover that use specifically.

External photographers, videographers, journalists, content creators or media partners must not work with Street Lights participants unless approved in advance.

Before external media activity takes place, Street Lights must ensure:

• the purpose is clear and appropriate
• safeguarding risk has been assessed
• consent arrangements are in place
• the external person has been briefed on safeguarding and conduct
• a written agreement is in place where necessary
• content ownership and use are clear
• participants know they can refuse or withdraw
• the DSL is consulted where children or vulnerable people are involved

Images and recordings must be stored securely and accessed only by people who need them for an authorised Street Lights purpose.

The Organisation will use secure storage arrangements and will avoid keeping images on personal devices, personal cloud accounts, personal messaging apps or unsecured folders.

Where personal devices are used in exceptional circumstances, images must be transferred to approved secure storage as soon as possible and deleted from the device and any automatic backup where practical.

Images and recordings must be retained only for as long as necessary. Retention must be consistent with the Data Protection Policy and any consent given.

Individuals, parents or carers may withdraw consent for future use of images or recordings at any time.

Where consent is withdrawn, Street Lights will take reasonable steps to stop future use and remove content from platforms it controls. The Organisation may not be able to remove content that has already been printed, published by third parties or shared beyond its control, but it will take reasonable action where possible.

Requests to withdraw consent should be sent to a Director, the relevant programme lead or the DSL where safeguarding is involved.

Young people, families, volunteers and community members may create their own content during Street Lights activities. Staff must set clear expectations about respectful and safe use of personal phones, videos, images and social media during sessions and events.

Participants must not be encouraged to film or photograph others without permission. Where participant generated content creates safeguarding, bullying, exploitation, conflict or reputational risk, staff must intervene and report the concern through the Incident Reporting Policy and Safeguarding Policy.

Street Lights may use testimonials and stories to evidence impact and celebrate change. These must be collected and used ethically.

The Organisation must ensure that:

• people understand how their words may be used
• children and families are not pressured to share personal trauma
• stories are not sensationalised
• identifying details are removed where needed
• safeguarding concerns are not disclosed publicly
• permission is recorded
• dignity is protected
• people can ask for future use to stop

Street Lights images and recordings must not be used to:

• shame, mock, expose or embarrass any person
• glamorise violence, gangs, weapons, exploitation or risky behaviour
• identify a vulnerable child, young person or family without proper permission and safeguarding review
• suggest guilt, criminality or risk without evidence
• share safeguarding information publicly
• promote personal brands without approval
• create content for private gain
• contact young people through personal accounts
• post images to personal social media without authorisation
• use images beyond the consent given

Any concern about an image, recording or online post must be reported to the DSL immediately where it involves a child, young person, vulnerable adult or safeguarding risk.

Examples include:

• an image being misused online
• a child being identified despite safety concerns
• unwanted contact after an image is shared
• bullying or threats linked to an image
• images being taken secretly or without permission
• images that may be sexual, exploitative or harmful
• images showing weapons, violence, drugs or criminal exploitation
• images that reveal confidential locations or information
• Where immediate risk exists, emergency services should be contacted. Safeguarding referrals must be made where required.

If images or recordings are lost, shared with the wrong person, published without permission, accessed by unauthorised people or otherwise compromised, this may be a data breach.

Data breaches must be reported in line with the Data Protection Policy. The Organisation will assess the risk, take action to contain the breach, notify affected individuals where appropriate and report to the Information Commissioner’s Office where required.

Breaches of this policy may lead to action under the Code of Conduct Policy, Volunteer Policy, Safer Recruitment Policy, Complaints and Whistleblowing Policy or relevant contract arrangements.

Serious breaches may lead to removal from duties, termination of volunteering or contract arrangements, safeguarding referral, police referral or legal action where appropriate.

Street Lights will make this policy available to directors, advisors, staff, practitioners, volunteers and relevant partners.

People involved in taking, storing, approving or sharing images must receive guidance on consent, safeguarding, contextual risk, online safety and data protection.

This policy will be reviewed at least annually by the Board of Directors, or sooner if there is a serious incident, change in law or guidance, significant change in delivery, safeguarding concern or data protection issue.

Learning from incidents, complaints, participant feedback and safeguarding reviews will be used to strengthen this policy and practice.

Before taking or sharing any image, recording or story, ask:

• Do we have a clear and legitimate purpose?
• Has consent been obtained where required?
• Does the person understand where this may be used?
• Could this create safeguarding or contextual risk?
• Could this identify someone who needs privacy?
• Is the content respectful and dignified?
• Is any confidential information visible?
• Is this being stored securely?
• Would we be comfortable explaining this decision to a parent, school, funder, regulator or safeguarding partner?
• If there is doubt, has the DSL been consulted?

This policy was approved by the Board of Directors of Street Lights Collective CIC.

Date approved: ____________________________________

Review date: ____________________________________

Signed on behalf of the Board: _______________________________

Name: ____________________________________

Role: ____________________________________