Photographic, Video and Digital Image Procedure

In this policy, words in italic text are defined terms which have the specific meanings set out in Gowrie Victoria Policies and Procedures – Definitions and Abbreviations.

Purpose 

The purpose of this procedure is to outline the process for the capturing, storing and use of photographic and video images at any Gowrie Victoria services, programs and for marketing purposes.  It ensures our practices align with ethical standards while upholding the privacy and dignity of individuals in accordance with the National Model Code for Managing Images of Children.

Scope 

This procedure applies to Board members, staff members, volunteers, students on placement, children, visitors, contractors and labour hire employees (such as photographers, film crews, and other third parties involved in image capture or use).

It applies to all situations where photographic or video images are captured, stored, or used at any Gowrie Victoria services and programs, including use in internal documentation, professional development, external communications and public promotion.

Procedure 

Staff Responsibilities in the Safe Use of Digital Technologies and Online Environments

Staff members are responsible for:

• Implementing this procedure in line with the Use of Technology Policy
• Actively contributing to an organisational culture that prioritises child safety and wellbeing when children are accessing digital technologies and online learning
• Being familiar with the individual needs and action plans for children and understanding how these relate to safe and appropriate technology use
• Actively supervising children when they are using digital technologies, including maintaining appropriate staff-to-child ratios
• Recognising and responding effectively to children when discussing the use of digital technologies, considering their diverse needs, interests and backgrounds
• Supporting children to participate in decision-making on matters that affect them, including the safe use of digital platforms at services
• Understanding the National Model Code and the delivery program and practice outlined by the NQF Online Safety Guide
• Reading and understanding the Shared Pedagogical Understanding (SPU) – Use of Digital Technology in Early Learning document
• Seeking guidance from designated managers when clarification or support is needed
• Ensuring that, even when not working directly with children, such as during on-site training sessions or meetings, all activities are conducted in ways that uphold a culture of safety that does not compromise children’s privacy or digital safety
• Adhering to the use of personal and service-issued devices in accordance with this procedure.

Informed Consent

In recognition of everyone’s right to privacy, dignity, and choice, photographic and video images must only be used respectfully and with informed consent.

No photographic or video image of any child or adult at a Gowrie Victoria may be taken or used in any external communication without their explicit consent. Where the individual is under 16 years of age, consent must be obtained from a parent or legal guardian.

This requirement applies regardless of whether the individual is clearly identifiable, or only partially visible (e.g., back of head, hands, feet, or presence in the background). It is not permissible to obscure or edit an image (such as blurring or cropping faces) to make an individual non-identifiable to bypass consent requirements.

Service Issued Devices and Storage

Photographic and video images of staff, children, or visitors may only be captured and stored using Gowrie Victoria-owned devices. Personal devices must not be used for this purpose under any circumstances.

Staff who are not employed to work directly with children and who receive a phone allowance to use their personal phones as part of their duties may carry these phones in licensed spaces. However, they must not take images or videos of children or staff at any time. In these cases, phone calls must not be made or answered within children’s rooms. All calls must be taken outside of the room to avoid disruption and maintain privacy and safety standards.

Personal electronic devices that can take images or videos as well as personal storage devices (including but not limited to laptops or tablets, smart watches, smart glasses), or file transfer media, are not to be in the possession of any educator, staff member, student or volunteer within children’s program areas and while on excursions. These devices are to be stored in staff lockers or as otherwise directed. Any exceptions to this requirement must be approved in writing in advance by the relevant manager, with clear agreement on the reason, agreement that mobile devices must be switched to aeroplane mode, the duration of the exemption and how the educator-to-child ratios will be maintained when an urgent call needs to be taken. Regardless of the exemption period, photos or videos of children and or staff must not be captured using personal devices under any circumstances.

Personal devices may be accessed during scheduled breaks or non-contact time and only in designated areas outside of children’s rooms, for personal business and appropriate work-related purposes i.e. via Humanforce, or Arrival.

Program planning documentation and related communications can only be performed on service-issued laptops, tablets, or computers.

All service-issued devices must be stored in designated locked areas at the conclusion of each day. These devices are only to be used by individuals within the defined scope of their role. Any exceptions to these requirements must be approved in advance by the relevant manager.

Photographic and video images must only be stored on Gowrie Victoria’s digitally approved platforms, as approved by the CEO.  Alternative storage platforms may be considered with the approval of the CEO.

Use and Storage of Devices for Third Parties

Devices owned by professional contractors or media outlets (e.g., photographers or film crews) may be used only where written agreement from the third party is provided outlining the use, storage and disposal of imagery and video footage and must be approved by an Executive Manager or CEO.

The agreement must clearly state that all images and videos will be used only for the purposes outlined in the written agreement, and that the third party will delete all related content on conclusion of the engagement.

Landlord representatives, such as property managers or contractors, are permitted to take and store images of building works or funded project progress on service premises using their own devices. This is permitted only if no individuals (children or adults), other than themselves, are included in any images or videos under any circumstances. A staff member where possible from the service must always accompany the representative while images or videos are being captured.

A business or institution-issued device refers to a device that is purchased and managed by an organisation and used by its employees while delivering a service or performing their duties within an early childhood setting. For example, allied health professionals visiting the service may use such devices as part of their work. These professionals are permitted to capture and store images and or videos only as required for their professional practice, in accordance with relevant privacy, consent, and data protection requirements.

Gowrie Victoria Staff Visiting Other Licensed Services

Staff visiting other licensed services have a duty of care to ensure that they act in accordance with the applicable Education and Care Regulations and the National Model Code by not using their personal devices in children’s spaces at all.

Storage of personal devices and personal belongings is at the discretion of each service.

Use of Personal Devices in Gowrie Victoria’s spaces by internal staff and visitors

To ensure personal device use supports adult learning, professional conduct and child safety, particularly in areas near children’s environment, participants must adhere to the following:

• No use of personal devices to capture or store images, videos or information related to children, staff or programs at all
• Personal devices must only be used for work or study related purposes
• Storage of personal devices away from the person may be required at the discretion of the meeting chair or service manager.

Families and Personal Devices

Families whose children are enrolled and attending the service may carry their personal devices; however, they must not take any photos or record videos while on the premises under any circumstances.

Staff are actively responsible for monitoring and enforcing this requirement to ensure the privacy and safety of all children and staff at services.

Responding to inappropriate use of digital technology

If inappropriate use of digital technology occurs contrary to this procedure, staff must immediately report the incident to the designated manager.

Upon notification, the following steps will be taken:

1. Immediate Action
   • Any captured imagery that breaches this procedure will be secured and deleted, where appropriate and lawful to do so.
   • Immediate measures will be implemented to protect any child or person affected.
2. Internal Investigation
   • An internal investigation will be conducted to assess the nature and extent of the breach, the individuals involved and any contributing factors.
   • The investigation will be documented in line with organisational policy and may result in disciplinary action.
3. Notification to Authorities
   • If required, the matter will be reported to the relevant regulatory or statutory authorities, in accordance with legal and organisational obligations.
4. Disciplinary Process
   • Where a staff member is found to have breached this procedure, the matter will be managed in accordance with Gowrie Victoria’s disciplinary procedures.
   • Disciplinary outcomes may range from formal warnings to termination of employment, depending on the severity of the breach.
   • All disciplinary actions will be undertaken fairly, confidentially and in line with relevant employment legislation and internal policies.
5. Documentation and Follow-Up
   • All incidents, investigations and outcomes will be documented and stored securely.
   • Ongoing monitoring or training may be implemented as part of follow-up actions to ensure continued compliance and uphold child safety standards.

Form of consent for use of personal images 

General requirements 

All consents must be given in writing using a specific consent form which states clearly:

• the persons whose images can be taken and used
• the entity which can use the images (such as The Lady Gowrie Child Centre (Melbourne) Inc, trading as Gowrie Victoria)
• the use of the images
• the duration of the consent
• the right of the person giving consent to withdraw their consent
• Gowrie Victoria’s rights to continue using image after consent expires or is withdrawn.

Consent forms must be signed and dated by the person giving consent.

Expiry and withdrawal of consent for use of images 

Withdrawal of consent 

Families (for their children and/or themselves), and any adult must be able to withdraw consent for use of their images at any time.

Continued use of images after expiry of withdrawal of consent 

Following expiry or withdrawal of consent:

• The Executive Manager, Adult Learning and Marketing will ensure that Gowrie Victoria takes all reasonable action to remove images from digital platforms (such as a website).
• Gowrie Victoria can continue to use existing communication incorporating images of people whose consent has expired or been withdrawn if it was in use at the date of expiry or withdrawal (for example in video, printed material, display materials)
• The Executive Manager, Adult Learning and Marketing must ensure that Gowrie Victoria does not produce any new external communication incorporating images of people whose consent has expired or been withdrawn

Image management 

The Executive Manager, Adult Learning and Marketing must ensure that:

• all images used in external communication are kept in the Gowrie Victoria online image library for the duration of their permitted use (including a full log with the date of the image, description of the image, names of all persons in the image, verification that consent has been provided by all persons in the image)
• as and when notified of the withdrawal of consent by a person, all images showing that person are removed from the library
• no later than 1 July in each year, remove all images of persons whose consent has expired are removed from the library.

The manager of individual services or programs must ensure that:

• images taken at the service during the year and used in any external communication are added to the library by the Educational Leader or sent to Communications & Marketing by the Educational Leader
• that any new image added to the library includes the date of the image, description of the image, names of all persons in the image, and verification that consent has been provided by all persons in the image.

The licensing of Gowrie Victoria photographic and video images or permission for use by any third-party entity must be approved by the Executive Manager, Adult Learning and Marketing or CEO. Approval should be in writing and include the specific use only and that the image is not to be stored beyond this use.

Template consent forms 

Authorisation 

Approved by	Executive Manager
Name	Alison Smith
Signature
Date	12 Sep 2025

References

Appendices

Appendix A: Consent for children attending any Gowrie Victoria service or program 

Consent for Photographs and Video

We would like your consent to take photos and video of your child and of any artwork/material created by your child when they are at Gowrie Victoria and to use to produce communication and training materials, to explain what we do at Gowrie Victoria and how we do things.

With your consent, we will video and take photos of your child interacting with other children and staff, engaging in regular activities, creating artwork and playing in both the indoor and outdoor spaces.

Internal Communications  

Photos and artwork will be shared within Gowrie Victoria only and may appear in children’s portfolios, be displayed in the service and shared in reflections.

Please tick either     Yes ​☐​  or  No ​☐​ 

External Communications  

Photos and video may appear on the Gowrie Victoria website, email, newsletters, social media and printed material. Learning materials may be used by Gowrie Victoria and other organisations to deliver training and to promote the early learning sector and will be made available online and in printed materials.

Please tick either     Yes ​☐​  or  No ​☐​ 

If you tick Yes and sign this form, you are agreeing that you:

• have read this form
• give us consent to take photographs and videos of your child
• understand that we will use the photographs and videos in the ways listed above
• agree to inform the manager of the service in writing should you no longer wish Gowrie Victoria to use the photographs and film.

We will stop using the photos and film by 30 June in the year after your child is no longer enrolled at Gowrie Victoria.

Child’s Name:  …………………………………………………………

Room Name/No: …………………………………………….

Parent/Guardian Name: ……………………………………………………………………………….…………………………………..

Signature: ……………………………………………………………………………………  Date: …………………………………………

If you have any questions or would like further information, please speak with the manager at your service.

Withdrawing your consent  

If you would like us to stop using the film and photos of your child, you should inform the manager of the Gowrie service in writing. We will not use the film and photos again; however, we will not be able to delete some communication that has already been published or printed.  

Appendix B: Consent for adults 

Consent for Photographs and Video

With your consent, Gowrie Victoria takes photos and video to produce a range of communication and learning materials.

The purpose of this form is to ensure we have your agreement to also use these photos and video.

Photos and video may appear on the Gowrie Victoria website, in email, newsletters, social media and printed material. Learning materials may be used by Gowrie Victoria and other organisations that Gowrie Victoria enters a formal partnership with (such as the Victorian Department of Education) to deliver training or to promote the early learning sector and will be made available online and in printed materials.

Do you agree? Please tick either  Yes ​☐​  or  No ​☐​ 

If you tick Yes and sign this form, you are agreeing that you:

• understand that Gowrie Victoria will use the photos and videos as described above
• give Gowrie Victoria continuing consent to use photos and videos as described above
• agree to inform the Executive Manager, Adult Learning (Glyn Williams) glynw@gowrievictoria.org.au) in writing should you wish to withdraw your consent and no longer wish Gowrie Victoria to use the photos and video as described above (however Gowrie Victoria will not be able to delete communication that has already been published or printed).

Name: …………………………………………………………………………………………………………..

Service/Organisation (If relevant): ………………………………………………………………..

Signature: …………………………………………………………….      Date: …………………………