Hi,
The issue with using any other processing condition is satisfying necessity - mostly photographs are useful but are they necessary? Pictures of events etc. will probably be ok but for publicity purposes only? I am not so sure.
If you hold photographs based on consent only then the Right to be Forgotten could require you to erase the pictures. In that case, would you still be processing any personal data? If you have to retain copies for any purpose such as for historical purposes then would that not be a different processing condition and so should have been set out in the privacy notice. I think that it may be a bit late to find a new processing condition upon someone trying to exercise their Right of Erasure.
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