Regardless of anything someone at ICO may have suggested the right to object does not even exist when the processing is based on legal obligation as Art 6 (1)(c) is not one of the triggering conditions of Art 21. So there are no times when it needs to be considered. It is also practically impossible to see how any of the triggering conditions for restriction in Art 18 could arise and certainly not condition (d). The photo will not be inaccurate, the processing cannot be unlawful (legal obligation) and the data is still needed (legal obligation).
Isn't the real problem here that you are all wrong in using legal obligation? The functions you mention may be legal obligations but I don't think any of them say "thou shalt keep a photo". Your post referring to it as fairly common suggest others manage otherwise
Surely the reality is it is 6(1)(e) or (f) - I leave you to decide whether these functions are part of your public task / official authority as it matters not for this issue - and the 'normal rules' under Art 21 and 18 apply? I also leave you to ponder the necessity test if the practice is not universal.
All archives of messages are stored permanently and are
available to the world wide web community at large at
If you wish to leave this list please send the command
leave data-protection to [log in to unmask]
All user commands can be found at https://www.jiscmail.ac.uk/help/subscribers/subscribercommands.html
Any queries about sending or receiving messages please send to the list owner
[log in to unmask]
Full help Desk - please email [log in to unmask] describing your needs
To receive these emails in HTML format send the command:
SET data-protection HTML to [log in to unmask]
(all commands go to [log in to unmask] not the list please)