Publishing images of minors in schools, websites, social media or video channels requires special care. Photographs and videos of students are personal data and often concern particularly vulnerable individuals.
In this article we will discuss...
When a school may take images
An educational centre may take images for internal, educational or management purposes where there is an appropriate legal basis and proper information is provided. However, publishing those images on websites, social media or promotional materials will usually require specific and informed consent.
Consent from families and students
Consent should be clear and separated by purpose: using an image on a private platform for families is not the same as publishing it on open social media. For children under 14, consent is usually given by parents or legal guardians.
Good practices for schools
- Inform about purpose, publication channel, recipients and retention period.
- Separate consent for website, social media, videos, activities and publications.
- Do not make ordinary educational activities conditional on accepting image publication.
- Use private and authenticated environments to share photos with families.
- Remove images where appropriate and manage objections.
- Avoid publishing additional data such as full names, class or unnecessary location.
Families and school events
Domestic recordings made by families for personal use may fall outside the GDPR. But if they are published on social media or widely shared, they may affect the rights of other minors and cause conflicts.
Recommended official sources
- AEPD: guide for educational centres.
- AEPD: images of students in school activities.
- AEPD: minors and education.
Conclusion
Images of minors should be processed with transparency, proportionality and control. For a school, generic consent is not enough: purposes and channels should be separated, authorisations documented and withdrawal facilitated where appropriate.
Frequently asked questions
Do schools need consent to publish pupils’ photos?
Yes, for websites, social media and publications.
Who gives consent?
The parents or guardians. From age 14, the pupils themselves (Article 7 LOPDGDD).
Can parents post photos of school events?
For private family use only. Publishing images of other children requires consent.
Does your company need a Data Protection Officer? We act as external DPO for companies and over 30 schools in Spain. See our DPO service.
Auratech Legal Solutions legal team
Lawyers specialised in data protection, compliance and technology law. External Data Protection Officers for companies and schools, whistleblowing channel managers (University Expert in Internal Reporting Systems, UNED) and ISO 27001 / ISO 27701 implementation. Contact us.
