Hi James
I think if guests are actively choosing to use the photo booth with the alumni then there is a consent there and you do not need to worry about those photos (unless you plan to use them for any reason).
Photos of the ceremony itself is an interesting one – and something we have been considering for events/visits etc. generally, for large events where the photograph is focused on the event overall as opposed an individual within the crowd then we are relying on suitable signage making people aware photographs are being taken and for an individual to make themselves known if they do not wish to appear in photos. I think very much the intended subject matter of the photograph will determine if the data can be considered personal or not. Where you take a photo of the empty stage for example and someone happens to be in the background of the shot I would not class this, but if you take a photo of that person then I would.
Option 2 will not be considered a freely given consent (because attendance is conditional on them providing it) so I do not believe this will work.
If you are planning on taking smaller group/individual shots of audience members and plan on using those images for marketing or promotional purposes then having alumni and attendees signing a consent form at registration (option 3) would also make sense to ensure this is collected.
At the Library, we use a mix of 1 and 3. Hope that helps.
Kind regards
James
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James Courthold
Information Compliance Manager
Corporate Information Management Unit
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From: This list is for those interested in Data Protection issues <[log in to unmask]> On Behalf Of James Davies
Sent: 14 September 2018 12:55
To: [log in to unmask]
Subject: [data-protection] Managing consents for photography at graduation event
Hello everybody
We run various educational initiatives and for one of these graduates of the programme will come back for their graduation ceremony.
They are allowed to bring one guest. In order to access the venue we need the guest’s name and both the guest and alumni will bring ID with them on the day.
When our graduates register on Eventbrite, we will be asking them to confirm the name of their guest as well as whether the guest has any access or dietary requirements.
A photographer will be present to take some photos of the audience in venue as well as the stage area. Additionally there will be a photo booth set up nearby for any graduates wishing to have their photograph taken.
Guests can choose to be photographed in the photo booth with the alumni they are accompanying and the guest may also be photographed as part of the audience at the ceremony.
The team running the event would like to come up with an option that allows us to take these photographs whilst accommodating the guest’s rights under GDPR.
The options they are considering are:
1. To put a notice up in both locations saying that by entering the buildings they are consenting to have their photograph taken
2. At the point of sign-up make it clear to the alumni that a photographer will be present and they must ask their guest to consent to being in venue shots if they wish to attend
3. Notifying them when they collect their badge that photographs will be taken
None of these seem to really satisfy the rights of the individuals and making the event run as smoothly as it could and in particular suggestions 1 and 3 don't seem to be satisfactory at all. Suggestion 2 would have the consent coming third hand which also doesn't seem optimal.
Does anyone on the list have any thoughts on how we can manage the consent for photos as efficiently as possible?
Regards
James
James Davies
Information Security, Risk and Compliance Officer
Saïd Business School
University of Oxford
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T +44 (0)1865 288928
Saïd Business School
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