FA Guidance - Photographing & Filming Children

Parents, children and clubs generally look forward to celebrating footballing successes by photographing children at matches and events, and some coaches find film a helpful coaching tool. The FA supports appropriate photography and filming of children, but recognises that images on websites, social media, posters and in the press can pose direct and indirect risks if they are not managed well. Everyone wishing to film or take photos in football should familiarise themselves with the following guidance.

Potential risks

Inappropriate taking or use of photographs or film

Someone may set out to take inappropriate content in ways that are potentially illegal and harmful, such as: photographing children changing or in toilets; using a camera at ground level to photograph up skirts; using ambiguous images out of context; copying and editing images to create abuse content; or re-sharing images privately online so they enter the public domain.

Identification, contact or grooming of a child

When a child's image is accompanied by significant personal information – full name, address – they become more easily identifiable to third parties. This has led to children being located, contacted and groomed. Even where personal details are confidential, details identifying a school, club, favourite player or team can be used to groom a child. The risk is increased where there are legal restrictions (for example a child in local-authority care or placed for adoption), where contact with a parent is restricted after separation, or where a child may be a witness in criminal proceedings.

Commissioning official or professional photographers and the local media

If you commission a professional photographer or invite the media to cover an activity, plan ahead and communicate early so expectations are clear on both sides. You should:

Provide a clear brief about what is appropriate in terms of content and behaviour.
Inform them of the club's commitment to safeguarding children.
Establish who will hold the images, for how long, and what they intend to do with them.
Issue the photographer with identification, to be worn at all times.
Clarify areas where all photography is prohibited – toilets, changing areas, first-aid areas.
Explain how to identify and avoid photographing children without the required parental consent.
Not allow unsupervised access to children, or one-to-one sessions at events.
Not allow sessions away from the event, such as at a young person's home.
Inform participants and parents beforehand that a professional photographer will be present.

When parental consent is not given

Clubs and event organisers must put arrangements in place so any official photographer can identify (or be told) which children should not be subject to close-up photography or filming – for example a recognisable badge, sticker or wristband, and a system to check with the organiser or team manager before an event.

Common-sense considerations

Most photographs and film are appropriate and taken in good faith. These measures help keep children safe.

Do

Share the FA's guidance with everyone who becomes a club member.
Ensure the club has written parental consent to use a player's image in the public domain – website, Facebook, newspaper.
Ensure any child under care proceedings with legal restrictions is protected by keeping their image out of the public domain.
Ensure everyone featured is appropriately dressed (a minimum of vest or shirt and shorts).
Aim to take pictures representing the broad range of youngsters playing safely – boys and girls, disabled people, ethnic minority communities.
Advise parents and spectators of the negative consequences of sharing images linked to information about children on social media, and the care needed around tagging.
Establish procedures to respond to concerns, including clear reporting structures and a way to contact the police when necessary.

Don't

Publish photographs with the full name of the individual featured without written consent and having informed the parents how the photo will be used.
Use player profiles with pictures and detailed personal information online.
Use an image for something other than what was originally agreed.
Allow images to be recorded in changing rooms, showers or toilets – including on mobile phones.
Include any advertising relating to alcohol or gambling in images of children.

Remember

It is not an offence to take appropriate photographs or film in a public place, even if asked not to.
No one has the right to decide who can and cannot take photos or film on public land.
If you have serious concerns about a possible child-protection issue, call the police. Take this action only where you believe someone may be acting unlawfully or putting a child at risk.
On private land, the land or facility owner can decide whether photography and filming is permitted, but must make this known before allowing people access.
Try not to use images that include individuals wearing jewellery.
Swimming as a social activity presents a higher risk of misuse than football: focus on the activity rather than a particular child, avoid showing the full face and body, and avoid camera angles prone to misinterpretation.

Filming as a coaching aid

Coaches using filming as a legitimate coaching aid should make parents, carers and players aware that this will be part of the coaching programme. Care should be taken when storing the clips. Parental consent must have been given – this can be requested at the start of the season via the FA's Club Annual Membership Information and Consent Form.

General photography and filming of events

At many events, organisers will want wide-angle, general photos or film of the event, the site and ceremonies. It is usually not reasonable or proportionate to secure consent for every child, or to preclude such photography because of the concerns of a small number of parents. Organisers should make clear to all participants and parents that these kinds of images will be taken, and for what purposes.

Secure storage

Hard copies of photographs should be kept in a locked drawer.
Digital photos should be in a protected folder with restricted access.
Digital photos and film should not be stored on unencrypted portable equipment such as laptops, memory sticks or mobile phones.
If storing images to identify people for official purposes such as identity cards, comply with the legal requirements for handling personal information. For guidance on data protection, visit the Information Commissioner's Office at ico.org.uk.

Misuse and manipulation of images

An individual with bad intent may deliberately target a vulnerable child to take images that are uploaded to social media or shared with like-minded individuals. Occasionally these images are used to threaten and force a child into unwanted, illegal activity, or form part of wider bullying motivated by a wish to cause humiliation. Even as a shared joke among friends, a young person taking and sharing inappropriate images may be committing a serious offence.

Responding to concerns

All club officials, volunteers, children and parents should be told that any concerns about inappropriate or intrusive photography or filming must be reported. Reports can be made to the event organiser or another official, the event Designated Safeguarding Officer, the Club Welfare Officer, the County FA Designated Safeguarding Officer, or the FA Safeguarding Team at safeguarding@TheFA.com. Concerns about professional photographers should also be reported to their employers. To report potentially unlawful material on the internet, contact the Internet Watch Foundation at report@iwf.org.uk or iwf.org.uk.

Source: The FA Guidance Notes 8.3 – Photographing and Filming Children (v1.2, July 2020), drawing on advice from the NSPCC CPSU.