Camera And Mobile Phone Policy
Aims of the Policy
It is our intention to provide an environment in which children, parents/guardians and staff are safe from images being recorded and inappropriately used in turn eliminating the following concerns:
- Staff being distracted from their work with children
- The inappropriate use of mobile phone cameras other image recording equipment, around children
- The inappropriate use of access to the internet and emails
Our aim is to:
- Have a clear policy on the acceptable use of mobile phones and cameras that is understood and adhered to by all parties concerned without exception
- In order to achieve this aim, we operate the following Acceptable Use Policy:
- Friends & Families of Special Children Ltd will allow staff to bring in personal mobile telephones and devices for their own use. Under no circumstances does the Charity allow a member of staff to contact a current child or parent/guardian using their personal device. This also refers to personal numbers and contact details to be given out.
- Users bringing personal devices into work must ensure there is no inappropriate or illegal content on the device.
- To ensure the safety and welfare of all the children and young people within our care, we operate a no mobile phone policy during activities. This policy is also to protect our staff members against possible allegations.
- At the beginning of an activity they will be asked to turn their mobile phone off and place it in a secure place.
- Staff members will be allowed access to their mobile phones on their break, but this must be away from the children. After your break, staff members must return their mobile phone back to the secure place. (whoever is present and in charge on the day will be responsible for checking this is adhered to.)
- If staff members have a personal emergency, they are free to use the setting’s landline telephone. They can in turn speak to the Manager to ask permission to make a personal call from their mobile in the designated area. If any staff member has a family emergency or similar, they are encouraged to give the office number for them to be contacted on. IF this is not possible for whatever reason, and they are required to keep their mobile phone on and “to hand”, prior permission must be sought from the Manager (whoever is in charge on the day) and the mobile phone should be placed in the designated place in the Office, where it can be visible at all times.
- All parent helpers/students will be requested to follow the same policy.
- During group outings nominated staff members will have access to the setting’s nominated mobile phone, which is to be used for emergency purposes only.
- It is the responsibility of all members of staff to be vigilant and report any concerns to the Manager or Trustees.
- Concerns will be taken seriously, logged and investigated appropriately.
- The Manager or Trustees in their absence reserves the right to check the image contents of a member of staffs’ mobile phone should there be any cause for concern over the appropriate use of it.
- Should inappropriate material be found then our Local Authority Designated Office (LADO) will be contacted immediately. We will follow the guidance of the LADO as to the appropriate measures for the staff member’s dismissal.
- During Activities for children and young people it is our Policy that no mobile phones are taken. The official mobile phone number will be given to parents in case of emergencies.
Photographs taken for the purpose of recording a child or a group of children participating in the Charity’s arranged activities, celebrating their achievements is an effective form of recording. However, it is essential that photographs are taken and stored appropriately to safeguard the children in our care.
- Only the work phones/cameras are to be used to take any photo within the setting or on outings.
- Images taken on this camera must be deemed suitable without putting the child/children in any compromising positions that could cause embarrassment or distress.
- All staff members are responsible for the location of the phone/camera; this should be placed in a secure place when not in use.
- Images taken and stored on the camera must be downloaded as soon as possible, ideally daily or a minimum of once a week.
- Under no circumstances must cameras of any kind be taken into the bathrooms without prior consultation with the Manager or Trustees. If photographs need to be taken in a bathroom, i.e. photographs of the children washing their hands, then the Manager or Trustees must be asked first, and staff be supervised whilst carrying out this kind of activity. At all times the camera must be placed in a prominent place where it can be seen.
- Failure to adhere to the contents of this policy will lead to disciplinary procedures being followed.
The right of parents, children and young people to take photographs and videos
Statement of intent
Parents/Guardians will not be covered by the General Data Protection Regulations 2018 (GDPR) if they are to take photographs or make a video recording for their own private use. The Regulations will therefore not prevent parents from taking photographs or making video recordings of their own children within the setting environment.
The right to refuse parents/guardians the opportunity to take photographs and make videos is however to be reserved on health and safety grounds. This right will be implemented should it be deemed appropriate. For example, if an excessive use of flashlights and/or bulky and noisy equipment are to be considered a potential health and safety risk.
Permission from all parents/guardians will be sought if a parent or guardian should wish to take or make any recordings within the setting environment. Authorised use will only be permitted on agreed dates and times, and within designated areas of the setting.
Before a photography request can be authorised, consent will need to be obtained from all parents/guardians of other children who maybe captured in any photograph or video. Should it not be possible to gain consent from the parents/guardians of all children who may be implicated, there will be no option but to refuse an open request to take or make images. Consideration will however be given to organising a one-off photograph opportunity which will only involve those children for who consent has been obtained.
Parents/guardians will only be permitted to make recordings or take photographs of any event for their own personal use. The use of such images and recordings for any other purpose, without express permission, will be a breach of the GDPR 2018.
Parents/guardians who are to be authorised to use photographic equipment must be encouraged to be mindful of others when making and taking such images. This will be to ensure minimum disruption to other parents during any event. Care must be taken to ensure the view of others will not be obscured and intrusive photography or filming must be avoided at all times. The right to withdraw consent will be maintained and any images or filming must be open to scrutiny at any time.
Use of a professional photographer
Statement of intent
Friends & Families of Special Children will ensure that any professional photographer who is to be engaged to record any events will be prepared to work according to the terms of this policy document and the following guidelines:
- In the context of data protection legislation, the photographer will be considered a “data processor” and any agreement with them will be in accordance with GDPR 2018.
- Photographers will only be used where they will guarantee to act appropriately to prevent unauthorised or unlawful processing or images; and will insure against accidental loss or destruction of, or damage to, personal data.
Photographers will be asked to sign an agreement which will aim to ensure;
- Compliance with GDPR 2018.
- Images are only to be used for a specified purpose and will not be used in any other context.
- Images will not be disclosed to any third party unless it is to be a specific requirement to do so in order to fulfil the requirements of the agreement. Such use will also be subject to parental permission.
- Only reputable photography agencies and/or professional photographers will be used. Evidence of such authenticity will be required.
- Details of any checks regarding suitability, which are to include evidence of Criminal Record Bureau checks will be requested. Photographic identity will be checked on arrival. Should there be any concerns in respect of the authenticity of any photographer, entry will be refused. Such concerns will be reported as is to be deemed appropriate.
- Photographers are to be treated as any other visitor. As such, appropriate levels of supervision will be in place at all times. This will ensure that no unsupervised access to children will be given.