Taking, Storing and Using Images of Children Policy

⚠️ SAFEGUARDING-CRITICAL POLICY — REQUIRES HUMAN SIGN-OFF BEFORE USE This policy touches child safety. Before it is published or relied upon, Al Fajer Private School leadership must: (1) fill every [NEEDS AFS INPUT] placeholder, (2) name the school's designated safeguarding lead (DSL) and deputy with real contact details, and (3) formally adopt it with real dates. Nothing in this document has been invented to fill those gaps.

DOCUMENT CONTROL

Table of Contents

1. Introduction
2. Guidelines for Taking Images
3. Guidelines for Taking Images at School Events
4. Guidelines for Publishing Images
5. Closed-Circuit Television (CCTV)
6. Concerns

1. Introduction

1.1 This policy is created under Law No. 30 of 2018 with respect to Personal Data Protection ("PDPL") and applies to the use of images in school publicity printed materials, including the yearbook, newsletters and flyers; on digital media, including the school website and the school's official social-media channels; and in the press. [NEEDS AFS INPUT: confirm the full list of AFS publication channels — the source policy also listed teachers' blogs and a school YouTube channel, which have not been assumed for AFS] This policy covers publication in the school's own channels only. [NEEDS AFS INPUT: whether AFS shares images with any external network, partner organization or third-party publication — if so, a separate, clearly explained consent option must be added to the Audiovisual Consent Form] For the purposes of this policy, the word "image" includes any kind of still or moving image, with or without sound, and whether stored/transmitted electronically or as hard copy.

1.2 Schools need and welcome positive publicity. Children's images add color, life and interest to depictions of the school's activities and initiatives. Making use of images in school publicity materials can increase student motivation and staff morale, and help parents and the local community identify and celebrate the school's achievements.

1.3 Al Fajer Private School (also referred to herein as "the school" or "AFS") adopts the following guidelines when using images of children in school publicity materials, including the use of images/names on the school website, in newsletters, and in displays:

2. Guidelines for Taking Images

2.1 Staff are permitted to take images to support educational aims, e.g. for classroom displays or projects.

2.2 Images should be stored securely and used only by those authorized to do so.

2.3 Staff should ensure that image files are appropriately named and will not use students' names in image file names.

2.4 When taking images, teachers should ensure that the students are appropriately dressed and are not participating in activities that might bring the individual or the school into disrepute.

2.5 Digital images should not be manipulated or amended, for example using a "cut & paste" facility. However, it is acceptable to crop an image.

2.6 Students must not take, use, share or publish images of others without consent.

2.7 Staff will not take or share images in public media, or use images outside educational purposes, without prior parental consent.

3. Guidelines for Taking Images at School Events

3.1 It is up to school management to decide whether to allow videos or images to be taken by parents during school events, such as award ceremonies or end-of-year celebrations.

3.2 Parents are not required to comply with the PDPL when taking images of their children, for their own private use, at an organized event.

3.3 Al Fajer Private School will advise parents, through appropriate signs or notices where events or celebrations take place (for example, in the assembly hall or other school facilities), that they should be cautious in taking and publishing photographs. Parents must be informed that the school will not be responsible in any case for the distribution of images on parents' social networks.

3.4 In the event that Al Fajer Private School needs to contract the services of an external photographer, or any graphic-design and image-editing services, it will ensure that the corresponding services agreement is signed by both parties and that the supplier adheres to, and complies with, the confidentiality and data-protection requirements indicated in the PDPL.

4. Guidelines for Publishing Images

4.1 Parents will be provided with the Audiovisual Consent Form, which will contain information about the uses of images and the contact details of the staff member responsible for data protection [NEEDS AFS INPUT: AFS data-protection contact — role, name and email; the source school named a Data Protection Officer, which has not been carried over], as well as non-pre-marked boxes making it possible to choose the options for the use of images in the school's own media. Their consent will be the lawful basis for processing the images.

4.2 Parents may at any time withdraw their consent/non-consent for the use of student images and digital recordings in school publicity printed materials, on digital media, and in the press. Any such request must be made in writing to the Principal and the staff member responsible for data protection [NEEDS AFS INPUT: AFS data-protection contact].

4.3 Images of students or staff should not be published on the school website after they leave the school, without their consent. Al Fajer Private School shall guarantee, through the corresponding procedure, that parents can easily withdraw their consent at any time, and shall attend to their query without undue delay.

4.4 Except for the yearbook, no other publication will use personal details (including the name) of any child or adult in an image in association with the image (including in the accompanying text or the image caption) without explicit written permission from the parent/guardian. The student's name and grade will be stated in the school yearbook. [NEEDS AFS INPUT: confirm AFS yearbook practice]

4.5 Where images are taken at an event attended by a large crowd — for example a whole-school celebration or an international day event — this is regarded as a public area, so it is not necessary to get the permission of everyone in a crowd shot before publishing the image on the school website.

5. Closed-Circuit Television (CCTV)

5.1 Al Fajer Private School is fully committed to operating a safe environment and has in place a CCTV Policy [NEEDS AFS INPUT: a CCTV Policy is not in the current AFS policy set — create it or remove this reference], which stipulates the legal requirements to install and use the video-surveillance system. The school therefore has in place a closed-circuit television ("CCTV") system to assist in providing a safe and secure environment for students, staff and visitors, as well as to protect school property. The CCTV system comprises a number of fixed cameras located both internally and externally around the campus. All cameras may be monitored and are only available for use by approved members of staff. CCTV is located in a number of locations, but it is NOT installed in classrooms, changing areas or toilets. [NEEDS AFS INPUT: confirm AFS camera locations and that no cameras are installed in classrooms, changing areas or toilets] Parents are assured that Al Fajer Private School does not stream images collected via CCTV to any third parties or outside agencies. Please note, however, that the school may be legally required to provide CCTV footage to the Police or other law-enforcement agencies if requested.

5.2 Al Fajer Private School has installed a CCTV system to:

5.2.1 increase the personal safety of staff and students and reduce the fear of physical abuse, intimidation and crime;

5.2.2 protect school buildings and assets, to ensure they are kept free from intrusion, vandalism, damage or disruption;

5.2.3 support the Bahrain Police in a bid to deter and detect crime;

5.2.4 assist in the prevention and detection of crime and misbehavior;

5.2.5 assist with the identification, apprehension and prosecution of offenders;

5.2.6 assist with the identification of actions/activities that might result in disciplinary proceedings against staff or students;

5.2.7 monitor the security of campus buildings. The system will be provided and operated in a way that is consistent with an individual's right to privacy.

5.3 Image Viewing and Download Procedure

5.3.1 Viewing: recordings may be viewed in the presence of a member of the school leadership team following a formal request. Otherwise, permission to view CCTV data will depend on the subject of the potential investigation.

5.3.2 School leadership team members are authorized to review CCTV recordings to ascertain the circumstances relating to potential incidents involving students, staff, contractors, and visitors/public incidents. Should a download be required as evidence, an electronic copy may only be made by the designated senior staff member [NEEDS AFS INPUT: AFS role authorized to make CCTV downloads]. Where footage is to be released to the Police, it will only be released on receipt of a written request and on sight of their warrant card/proof of identity. Where a download is requested by a school leadership team member in relation to a student incident, the request must be put in writing (e.g. via email). CCTV footage may be released for civil proceedings at the written request of an attorney or insurance company.

5.3.3 All requests by individuals for access to view or copy CCTV footage should be made in writing, following the same procedure implemented in our school for the exercise of rights requests. Requests for access to CCTV images must include:

5.3.3.1 the reason for the request;

5.3.3.2 the date and time the images were recorded;

5.3.3.3 information to identify the individual, if necessary;

5.3.3.4 the location of the CCTV camera.

5.3.4 Third parties who wish to have a copy of CCTV images (i.e. images not of the person making the request) do not have a right of access to images under the PDPL, and care must be taken when complying with such requests. CCTV downloads or viewings requested by other parties, including parents, for purposes outside the scope of this policy are not permitted.

5.3.5 Recorded images will be retained for 120 days from the date of recording, as per Bahraini law, unless required for evidential purposes or the investigation of crime, or otherwise required and retained as a download. All images on electronic storage will be erased by automated system overwriting. All downloads, still photographs and hard-copy prints will be securely disposed of as confidential waste.

5.3.6 Complaints regarding the CCTV system and its operation should be made under the school's Parent Complaints Policy.

6. Concerns

6.1 If parents have any concerns about inappropriate or intrusive imagery at a school event, they should report their concerns to the staff member responsible for data protection [NEEDS AFS INPUT: AFS data-protection contact] or to the Principal.

6.2 If a parent or child wishes to have an image removed from the school website, prospectus, etc. at any time, they should contact the Principal, who will involve the staff member responsible for data protection as previously indicated.

6.3 When a press image has been captured, the data controller for that image is the media organization concerned and not the school. Therefore, parents will need to make any objections to that organization and not to the school.

6.4 AFS will provide parents with information about the Personal Data Protection Authority at all times, in case they wish to file a claim before the Authority, which can be contacted at: http://www.pdp.gov.bh/en/index.html. The school will endeavor to resolve any claim first, in order to avoid the need for action before the Authority.