Purpose and scope of this policy

This policy forms part of a range of documents and practical arrangements that help safeguard anyone involved in Old Colwyn Golf Club (OCGC)activities.

The document sets out OCGC expectations for anyone wishing to take photographs or videos of children or young people participating in club activities. It details the benefits and risks associated with taking and/or sharing images; outlines good practice guidance; and explains how to respond to concerns that may arise about images or their mis-use.

The policy applies to anyone undertaking any role on behalf of OCGC, including staff/volunteers, commissioned professional photographers, press photographers, and spectators. It applies when services and activities are delivered on site at the club or when staff, volunteers and junior members are in other settings (for example at golf competitions, training camps etc.)

This policy has been drawn up to compliment child and adult protection and online abuse legislation, policy and guidance that seeks to protect children and adults.

1. How images can be used positively

Taking and/or sharing photos and videos is often very positive. Images may:

Allow OCGC and its members to record and share their experiences, successes and achievements
Provide and promote a record of the services and activities the club offers Ø As a coaching tool.

Photography can take a number of forms, including:

Club staff using cameras, mobile phones, tablets or video equipment
Images of groups or individuals, or wider angle, general images of events or activity sites
Press or TV coverage of events or activities
CCTV used to make a site a safer environment.

Here are some of the ways images may be used:

On the club website and/or social media platforms (e.g. Facebook or X)
On club promotional materials
In the printed or online press (e.g. by local newspapers)
On local or national TV
For club staff profile information.

2. Potential risks associated with photography/filming

If safe processes aren’t in place, photos and videos may be shared outside of the organisation or posted online without prior consent from children and parents, or additionally vulnerable adult service users.

This could lead to safeguarding risks such as:

images being modified or misused out of context, for example to create child abuse images
a child or adult being identified and targeted/contacted for the purpose of grooming and abuse
information (about vulnerable child or adult) being disclosed which provide opportunities for a third party (for example an existing child abuser, a perpetrator of domestic violence, or the birth family of an adopted child) to trace and contact them.

Any of these outcomes will have devastating and long-lasting consequences for the child.

Some children are subject to court orders and other legal arrangements that prohibit the taking and sharing of their images.

3. Consents and information for junior players/parents

An absolutely basic principle is to seek the informed permission of the child, young person and their parents before any images are taken.

Informed consent means that the individual understands the type of images to be taken (e.g. close-ups, group shots or more general images); how, where, and by whom the images will be used (e.g. on a public website, on publicity materials, or in the press); how images will be stored securely in line with Data Protection requirements (e.g. with access limited to approved users) and for how long. Consent should be obtained in writing (Parental consent form – Template 14) and should be kept securely.

If children, parents and/or carers do not consent to photographs being taken, we will respect their wishes. We will agree in advance how they would like to be identified so the photographer knows not to take pictures of them, and ensure this is done in a way that does not single out the child or make them feel isolated.

We will never exclude a child from an activity because we do not have consent to take their photograph.

4. In-house photography/filming

Ideally most images will be taken by identified club staff or volunteers who have been the subject of a safer recruitment policy and are considered appropriate for this role.

They should be familiar with the contents of this policy, and apply the guidance practice provided below (section 8) in all cases.

The club will establish a secure way to store all images, and a deletion policy to remove images after an identified time period.

The club staff and volunteers will never store images of children on unencrypted portable equipment such as laptops, memory sticks and mobile phones.

The club does not permit staff and volunteers to use any personal equipment (phones, tablets or cameras) to take photos and recordings of children without the agreement of the Club Welfare Officer. Whenever possible, only OCGC owned cameras or devices should be used.

5. Using external professional photographers

When employing/using external contractors – or when press photographers attend activities – it will not be possible to assess their suitability in the same way that staff are subject to safer recruitment processes. Therefore, OCGC will ensure that these photographers are supervised by club staff throughout the process.

Ahead of the session, the club should understand the details of purpose and use of any images planned to be taken, and only approve this if/when satisfactory service-user consents and photographer supervision arrangements are in place.

In addition, photographers will be required to adopt the same good practice guidance (section 8 below) as club staff. Where possible this should be provided to the photographer ahead of the session, and their written agreement to comply with it recorded. This will also include their name and contact details, their employing organisation, the reason for taking the images and how they will be used/shared.

At the event we will inform children, parents and carers that an external photographer is present and ensure the photographer is easily identifiable, for example by issuing them with a coloured identification badge.

6. Spectators taking images for personal use

For club events and activities we will provide guidance for spectators wishing to take photos or films of family members’ involvement in activities for personal use.

This includes:

asking for photos taken during the event not to be shared on social media, unless they gain permission from children, their parents and others before sharing photographs and videos that include them
avoid tagging the names of anyone else’s children in social media posts including images
recommending that people check the privacy settings of their social media account to understand who else will be able to view any images they share
reminding children, parents and other spectators who they can talk to and how they could make a report if they have any concerns about the way images were taken or are being shared.

7. Good practice guidance for taking photos and videos

inform children, parents and adult service users that a photographer will be present at a session/event and will be wearing identification
Photographers will wear the accreditation/identification badge provided so their status as official photographer is clear – and to help identify nonaccredited photographers
always ensure that written consent has been obtained from a child and/or their parents before taking and using any images – this includes explaining what the images will be used for, whether/how they will be shared or published, and how/for how long they will be securely stored
when there are individuals who have not provided consent, ensure that the photographer is familiar with who these are and avoid including them in any images
the photographer will not be given unsupervised access to any children or potentially vulnerable adult service users
the photographer will not be permitted to arrange or carry out sessions away from the activity site or session, or at a child’s home
no photography is allowed in the toilets, showers, or changing rooms – or any other areas where service users may change
clarify that consent to use or share images can be withdrawn later, but that it may not be possible to delete images that have already been shared or published (particularly online)
change the names of children whose images are being used in our published material whenever possible (and only using first names if we do need to identify individuals)
never publish personal information about individual children which could lead to them being contacted, and disguising any identifying information (for example the name of their school or a school uniform with a logo)
you can reduce the risk of images being copied and used inappropriately when you:
- only use images of individuals in appropriate clothing
- be aware of the potential for some poses and camera angles to create images that are more easily mis-used (e.g. a person doing the splits)
- only using images that positively reflect the individual’s involvement in and enjoyment of the activity.

8. Responding to concerns arising from photography/filming

Any concerns about the way images are being taken or subsequently shared, mis-used or published should be reported to the Club Welfare Officer in the same way as any other safeguarding concerns are. The club should provide guidance to juniors and their parent/carers about how they can report concerns. All reported concerns will be considered and responded to by the Club Welfare

Officer, and, if required, in collaboration with the Wales Golf Safeguarding Team.

9. Storing images

OCGC will store photographs and videos securely, in accordance with our Safeguarding Policy and Data Protection law. We will keep hard copies of images in a locked drawer and electronic images in a protected folder with restricted access. Images will be stored and available for consented use for a period of three years, after which they will be deleted.

We will never store images of children on unencrypted portable equipment such as laptops, memory sticks and mobile phones.

The club does not permit staff and volunteers to use any personal equipment to take photos and recordings of children.