The Portrait Co. – School Photography Policy

1. Introduction

The Portrait Co. (“the Company”) provides professional school photography services. This policy outlines the procedures, practices, and responsibilities related to the photography services provided to schools. Our goal is to protect the safety, privacy, and rights of students, staff, and families while ensuring the smooth operation of our services.

2. Purpose of the Policy

This policy is designed to:

  • Ensure compliance with UK laws and regulations, including the Data Protection Act 2018 (UK GDPR), Safeguarding laws, and health and safety requirements.

  • Define how images and personal data will be handled, stored, and protected.

  • Set out protocols for school visits, including child protection and security.

  • Ensure that students’ and parents’ rights are respected at all stages of the photography process.

3. Legal Framework

The Portrait Co. will comply with the following legal requirements:

  • Data Protection Act 2018 and UK GDPR (General Data Protection Regulation)

  • Children Act 1989 & 2004

  • The Education (School Photography) Act 2000 (if applicable to any contracted agreement)

  • The Equality Act 2010

  • Health and Safety at Work Act 1974

  • The Protection of Children Act 1999 (and subsequent updates)

4. Collection and Use of Personal Data

The Company collects the following personal data:

  • Student photographs (used for identification, school records, and personal portraits)

  • Contact information of students, parents, and staff for order fulfillment and communications

Data Usage: Personal data will only be used for the specific purpose for which it was collected. This includes:

  • Photographic prints and digital files for customers (students/families).

  • To communicate with families regarding orders or queries.

  • For administrative purposes (invoicing, order tracking).

Consent:

  • Consent will be obtained from parents or guardians before any photographs are taken. The Company will provide a clear opt-in/opt-out consent form to be completed by the parent/guardian before the photography session.

  • In cases where children are under 13, consent must be given by a parent or legal guardian.

Data Retention:

  • Photographs will be stored in a secure cloud storage system with limited access.

  • Personal data will be retained only as long as necessary for the purposes it was collected. For photography, this will typically be for up to 12 months after the order is completed, unless parents or guardians request removal.

5. Safeguarding and Child Protection

  • Supervision: At no point will photographers be alone with children without a teacher or school staff member present.

  • Vetting of Employees: All photographers and staff working at schools will have undergone an enhanced DBS (Disclosure and Barring Service) check to ensure they meet child protection and safeguarding requirements.

  • Respect for Boundaries: Photographers will always respect the comfort and personal boundaries of students. No student will be photographed inappropriately or without their consent (or their guardian's consent).

  • Photography of Vulnerable Students: Special care will be taken when photographing vulnerable students or students with special needs. In these cases, additional consent may be sought.

6. Health and Safety

  • The Portrait Co. will adhere to health and safety regulations while on school premises.

  • Photographers are trained in appropriate ergonomics and will use safe, non-intrusive equipment.

  • A risk assessment will be conducted prior to each school visit to ensure any hazards are mitigated.

7. Image and Brand Use

  • Ownership of Images: The school will retain ownership of the individual student’s photograph as part of the student’s record. The Portrait Co. will retain the copyright of all photographs taken for the purpose of production and distribution to the family.

  • Usage of Images for Promotion: The Portrait Co. will not use any student photographs for promotional or marketing purposes without explicit written consent from parents/guardians.

  • Third-Party Distribution: Photographs may only be shared with third parties (e.g., printing services) under contractual agreements ensuring the confidentiality and security of the personal data.

8. Security Measures

  • Data Encryption: All digital images and personal data will be encrypted in storage and during transfer to prevent unauthorized access.

  • Access Control: Only authorized personnel will have access to sensitive data and images. All staff members are trained on the importance of data privacy and security.

  • Physical Security: All equipment used by The Portrait Co. (e.g., cameras, laptops) will be securely stored during transport and when not in use.

9. Complaints and Disputes

If a parent, guardian, or school has a complaint or concern about the photography service, they can contact the Company directly via the contact details provided at the time of booking. The Portrait Co. will respond promptly and work to resolve any issues in accordance with our customer service standards.

10. Review and Update of Policy

This policy will be reviewed annually or in response to any changes in applicable law. The Company will communicate any major changes to schools and parents/guardians as appropriate.

Conclusion

This policy ensures that The Portrait Co. adheres to all relevant UK laws, especially those related to safeguarding children and data protection. By implementing this policy, the company ensures that the photography service is both professional and respectful of the privacy and security of students, parents, and staff.

Please consult with a qualified solicitor or data protection officer to ensure the policy is fully compliant with the latest regulations and best practices.