All,
I am advising my organisation not to put staff photos on emails without consent. They will only be used on internally emails. At the moment there is no overriding argument for security or safety or anything like that. The woolly justification is - "it would be nice to know what people look like, it will help improve team spirit" or something like that.
I am pretty confident in the argument I am putting forward, i.e. does not meet any Schedule 2 conditions of processing and may also be a breach of confidence and article 8 of the HRA (not going there on race or religion as I don't need to).
My concern is they may eventually just put it in the employment contract and then state they have got consent when the contract is signed. It is unlikely anyone is going to turn down an offer of employment just because their photo will appear on internal emails, but I cannot see how consent is 'freely given' in this scenario. Am I right?
Thanks
Steve
Stephen Cotterill
Procurement & Technical Officer
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