Introduction
In the course of carrying out its various functions, Power2 works with children, young people and vulnerable adults as part of its activities across all its programmes.
These programmes include, but are not limited to;
- Teens and Toddlers
- Power2 Thrive
- Power2 Advance
- Power2 Rediscover
- Power2 Progress
- Power2 Energise
This policy supports Power2 in demonstrating the safeguarding measures that are in place that are there to protect children, young people and vulnerable adults who take part in Power2’s services, events and activities, specifically those where photographs and videos may be taken.
Definitions
Child: Although we recognise that the legal definition of a child varies in different countries, for the purpose of this policy children are defined as all those under 18 years of age.
Young person: For the purposes of this policy a young person is anyone aged between 18 and 25.
At risk adult: For the purposes of this policy an adult is someone over the age of 25. An at risk adult is an individual who has needs for care and support, who is experiencing, or at risk of, abuse or neglect and as a result of their care needs – is unable to protect themselves.
Beneficiaries: For the purposes of this policy the reference to beneficiaries will include children and young people that have taken part in a Power2 programme.
Consent: Obtaining permission for something to happen or agreement to do something.
Purpose
The purpose of this policy is:
- To set out the overarching principles that guide our approach to online engagement with and photographs/videos being taken of children and young people during our events and activities.
- To ensure that we operate in line with our values and within the law when creating, using, storing and sharing images of children and young people.
This policy statement applies to all staff, volunteers and other adults associated with Power2.
Scope
We believe that:
- Children, young people and vulnerable adults should never experience abuse of any kind.
- We have a responsibility to promote the welfare of all children, young people and adults at risk and to take, share and use images of children safely.
We recognise that:
- Sharing photographs and films of our activities can help us celebrate the successes and achievements of our children and young people, provide a record of our activities and raise awareness of our organisation.
- The welfare of the children and young people taking part in our activities is paramount.
- Children, their parents and carers have a right to decide whether their images are taken and how these may be used, regardless of age, disability, gender reassignment, race, religion or belief, sex or sexual orientation.
- Consent to take images of children is only meaningful when children, their parents and carers understand how the images will be used and stored, and are fully aware of the potential risks associated with the use and distribution of these images.
- There are potential risks associated with sharing images of children online.
Legal framework
This policy has been drawn up on the basis of legislation, policy and guidance that seek to protect children in England.
The charity is committed to processing data in accordance with its responsibilities under the GDPR. GDPR requires that personal data shall be:
- Lawfulness, fairness and transparency.
- Purpose limitation.
- Data minimisation.
- Accuracy.
- Storage limitation.
- Integrity and confidentiality (security).
- Accountability.
Power2 policies and procedures
This policy statement should be read alongside our organisational policies and procedures, including:
- Safeguarding children.
- Record retention & disposal policy.
- Code of conduct for staff and volunteers.
- Safeguarding data.
- Employee handbook.
- E-safety policy.
Obtaining consent
We will:
- Always ask for written consent from a beneficiary and their parent or carer (if they are under 16) before taking and using their image. Generic consent is obtained at the start of all programmes:
- Face-to-face programmes: I give permission for images of my child to appear in media deemed safe by Power2, including, but not limited to; social media, presentations, website and promotional material in order to publicise the Power2 programmes. In the event of Power2 wanting to produce more detailed content on participants (e.g. case studies, newspaper articles, radio, television etc.), parents or carers will be contacted and a more detailed consent will be obtained.
- Online programmes/activity: I consent to the capturing of images during online activities that may be shared externally via Power2’s social media accounts. In the event of Power2 wanting to produce more detailed content on participants (e.g. newspaper articles, radio, television etc.), parents or carers will be contacted and a more detailed consent will be obtained.
- Liaise with nursery staff who have loco parentis for the younger children involved in our programmes and follow their guidance.
- Always explain what images will be used for, how they will be stored and what potential risks are associated with sharing images of beneficiaries.
- Make it clear that if a beneficiary or their family withdraw consent for an image to be shared, it may not be possible to delete images that have already been shared or published.
- Change the names of beneficiaries whose images are being used in our published material whenever possible (and only using first names if we do need to identify them).
- Never publish personal information about individual beneficiaries and disguise any identifying information (for example the name of their school or a school uniform with a logo) unless we have prior written consent to do so via the standalone consent form (see appendix 1).
- Make sure beneficiaries, parents and carers understand how images of children will be securely stored and for how long (including how we will control access to the images and their associated information).
- Reduce the risk of images being copied and used inappropriately by:
- only using images of beneficiaries in appropriate clothing (including safety wear if necessary).
- avoiding full face and body shots of beneficiaries taking part in activities such as swimming where there may be a heightened risk of images being misused.
- Use images that positively reflect young people’s involvement in the activity.
The procedure for reporting the abuse or misuse of images of children is part of our safeguarding procedures. We will ensure everyone involved in our organisation knows the procedures to follow to keep children safe.
Consent is not needed when a quote or testimonial is being published anonymously.
Assets
We recognise that our programme team may use photography, filming, case studies and quotes as an aid to capture sessions in action and our beneficiary’s voices. However, this must only be done with Power2’s permission and using our equipment.
Children, young people, adults at risk, parents and carers must also be made aware that photography and filming is part of the programme and give written consent.
If we hire a photographer/videographer for one of our events or if we collaborate with external organisations on joint projects/events, we will seek to keep beneficiaries safe by:
- providing the photographer with a clear brief about appropriate content and behaviour
- ensuring the photographer wears identification at all times
- informing beneficiaries, their parents and carers that a photographer will be at the event and ensuring they give written consent to images which feature their child being taken and shared
- ensuring the photographer has a valid DBS in place or ensure they are supervised by Power2 staff at all times
- not allowing the photographer to carry out sessions outside the event or at a beneficiaries home
- Reporting concerns regarding inappropriate or intrusive photography following our Safeguarding procedures.
Storing images
We will store assets of children securely, in accordance with our safeguarding policy and data protection law.
We will keep hard copies of images in a locked location and electronic images in a protected folder with restricted access. Images will be stored for a period of up to 10 years.
When it proves necessary to use a portable device to store images this will be encrypted and restricted to named individuals.
Power2 does not permit staff and volunteers to using any personal equipment to take photos and recordings of children. Only cameras or devices belonging to Power2 should be used.
Appendix 1: In-depth consent form
Please complete this form to give consent for us to capture and store your story in the form of case study, video recording, audio recording or other formats as detailed.
This form covers consent for use of the above for internal and external communication and storage of the data within this form. All data (images, film, comments, personal information this form) will be stored by Power2. The data may be shared with 3rd party organisations in order to fulfil the communication work necessary, e.g. providing images to funding partners.
