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Hello everyone - especially those who kindly replied. I'm done my best to summarise the variety of replies here in case anyone else finds it as useful as I have. I'll attempt to answer my own question with the information kindly supplied.

Our alumni team would like to use (as yet undecided pics from the archive in their promotional activity to reach new and existing alumni)

The issues to sort out are:

Is the image covered by copyright law? If yes, then does the organisation own the copyright?

If you do - you can proceed to the next question.
If the copyright is owned by another party, do you have their permission and terms?

If yes, then proceed, if not you may still be able to use the image since after 70-80 years one might assume copyright has expired.

If you're just using pics without people, then you're good to post all those lovely shots of your Students Union from the eighties. :-)

Now we come to part two.

Data Protection.

We may be free to use the images from a Copyright perspective, but now we have to consider whether we can justifiably use the images with people's personal data. IF we can identify the people in the photos - not often in our case - then we would usually need consent to use them in this way. No-one mentioned much detail about consent in the replies, but it seems a reasonable expectation that official university photographs would have been consented to, so people considered the use of those as low risk and worth doing.

We are allowed to retain Personal Data in the archive, and the usage of the images is low risk, and viewed favourably by alumni. IN the event that someone identifies themselves then a takedown policy and mechanism is a sensible precaution.

Thanks again to everyone who replied, and I hope my summary helps (it certainly helped me writing it out)



Cofion cynnes/Kind regards,



Kevin Mears

Rheolwr Cofnodion / Records Manager


Dewch o hyd i mi yn Timau Microsoft/Find me in Microsoft Teams

Ystafell / Room : TR TC211


Swyddfa Ysgrifennydd y Brifysgol / University Secretary’s Office

Prifysgol De Cymru / University of South Wales /


www.decymru.ac.uk<http://www.decymru.ac.uk/> ¦ www.southwales.ac.uk<http://www.southwales.ac.uk/>




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