VCC Photography & Recorded Images Policy
1. New digital and information technologies are making it easier to get pictures and images into the public domain through the news media, printed publicity material and websites. This increased freedom, which widens the opportunities to publicise the activities of the VCC, brings additional responsibilities to ensure that individual and parental rights are respected, and that young people and vulnerable individuals are protected from exploitation. Additionally, the storage of identifiable images is subject to the provisions of the Data Protection Act.
2. These guidelines are to assist those promoting the work of the CF through all forms of media. They are intended to give units the confidence to implement promotional campaigns with peace of mind and to avoid over-reaction. Public Relations is a subjective matter, and common sense should be applied – if doubt exists on the suitability of material, omit it.
3. The need for guidance. The ease of generating and capturing photographic images creates many cost-effective, positive PR and promotional opportunities, but there are risks and pitfalls. Careless use of images, at its worst, can put vulnerable people, especially the young, at risk. It could also result in legal action against the MOD, and VCC.
4. Particular care needs to be taken in obtaining and publishing images of young people, and issues of safeguarding and parental consent cannot be taken for granted or ignored.
5. There is a general lack of clarity and consistency about the use of photographs, and the consent needed for filming and photography. CFAVs may not give consent – this must be obtained from the cadets’ parents or guardian as there might be reasons for a young person’s picture not being used, known only to their parent or guardian.
6. These guidelines are intended to provide a clear and consistent approach, throughout the whole VCC, which will be easily understood and accepted by all involved – and will ensure that there is proper regard to the law, and the protection of young people.
7. The legal framework. The Data Protection Act and GDPR covers the protection and processing of personal information which would include photographic images which identify an individual. In practical terms, Data Protection provisions mean that extreme care must be taken when using old photographs or any sort of stored images for new purposes. The express consent of the individuals in the image is required to do so. Access to stored images must be allowed, on request, and arrangements made for the destruction of out-of-date material. The law holds that a child lacks the legal capacity to give valid consent until attaining the age of 14 years. Until that time, the capacity to give consent is vested in the parent or guardian of the child. When a child is in the care of a local authority, the Unit should contact that authority for consent.
8. Gaining valid consent – adults. Consent is valid only if the person agreeing to the use of their image has a full and clear understanding of the purpose for which the image may be used. In the VCC this can be a consent signed at time of enrolment as a CFAV and reviewed at least every 5 years.
9. Gaining valid consent – cadets. Always ensure that written consent from the cadet and the parent or guardian has been obtained, before the images of young people are published. As with adults, the consent must be based on a clear understanding of the purpose for which the images may be used. For most purposes, consent obtained in advance from the cadet and parent or guardian will be sufficient. In the VCC, this can be a consent signed once at the time of joining, as part of the enrolment form, and again prior to any known media event on a model release form. Pictures of cadets in, for example, swimming costumes are to be avoided. If there is an event where photography would be beneficial, then cadets must be provided with t-shirts or track suits to wear on top of their swimming costumes. Additional care should be taken, therefore, if the media are invited to cover sporting events.
a. Consent. This should be signed once at time of enrolment and again prior to any known media event. However, it should be clearly stated that this consent may be withdrawn at any time, and unit commanders should carefully monitor those cadets whose parents or guardians, or the cadets themselves, have not given consent. Consent needs to be used carefully and with safeguards. It should be as specific as possible about the images that are covered. For example, it might include, press photography or recorded images of training and sporting events, A public appearance or event deliberately staged to gain publicity from the news media, annual and weekend camps, and photographs or recorded images for use in brochures and with news releases.
b. When consent has not been granted. When there is a media opportunity, and there are cadets present whose parents have not given consent, they must not be incorporated in the images.
c. Naming Cadets. Generally, there is a presumption that no identifying information will be published, other than a first name. In limited cases, where a parent or guardian has given explicit consent, a cadet can be named fully but other details such as full home addresses, date of birth, e-mail addresses and telephone numbers, must never be supplied or published.
d. Media Events. It is the responsibility of the individual unit CFAV or I/C of event to inform photographers of cadets whose parent or guardian have or have not granted consent. This is particularly important when photographers are present who are not connected to the individual unit.
e. Official Websites. Where valid consent has been given, images of cadets may be used on unit websites. However, images of individuals on websites should not be named, nor should the cadet be identifiable from accompanying copy published on the site unless it is specific to the story. Care should be taken, also, in naming the picture files, to ensure the individual cannot be identified by a viewer scrolling over the picture.
f. Social Networking Sites. The rapid development of user-created content on the internet, including blogs, social networking sites and chat rooms, means that many members of the VCC have initiated Cadet-themed web presences on sites such as, but not restricted to, Facebook, Bebo, YouTube, and MySpace. Such sites are potentially of great benefit in providing a window into the VCC but care must be taken to ensure no content is published likely to bring the organisation into disrepute or otherwise damage their reputation . For example, accepting invitations on social networking sites to be a ‘friend’ (cadet to adult or adult to cadet) is considered as unacceptable behaviour.
10. Reusing old images. If an image is going to be used for publicity, where the cadet is effectively ‘the model’, an additional consent – on a model release form – should be obtained. Problems can arise where images have been taken for one purpose and used for another. A new image should be obtained and cleared specifically for the desired purpose.
11. Storage of images. Whether images are stored electronically or as photographs, negatives, or transparencies, care must be taken to ensure that they are secure and clearly labelled and dated, to ensure they cannot be used without valid consent. Images and videos of cadets should not be stored on any adult’s personal equipment.
12. Data Protection Act 2018. Under the provisions of the Data Protection Act 2018, parents, guardians, and individuals have access, on request, to stored images of their children or themselves.
13. Action. The guidelines contained in this document are to be followed by all members of the VCC and groups wanting to use images of cadet activity for their own purposes e.g. school staff and unit committees.
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Social Media - Social media such as Facebook, Twitter, YouTube, Instagram, TikTok and other similar services are a normal, everyday part of life. This is positive as they allow people to keep in touch with their friends and family, and also allows the Royal Navy Cadet Forces to maintain an important connection with their own members and with wider society.
12. However, the Cadet Forces must think carefully about how they use social media as there are extra rules they must follow, which fall into three categories:
a. ‘Operational’ security’ – giving away sensitive information obtained through Cadet Force activities. This could include information about things like VVIP visits, forthcoming events, shortfalls or capabilities of equipment.
b. Personal security – information or images posted online may be accessed by other people and used freely by anyone who has access to that information. Care must be taken about the content people post and, without the correct security settings in place, individuals are revealing anything they post to everyone, including strangers, journalists, criminals and terrorists.
c. Appropriate and professional behaviour – when using social media, CFAV and cadets should aim to be polite, constructive, honest, and a credit to the VCC and wider Cadet Forces. They should also ensure they do not embarrass themselves or the organisation through their interactions with social media. They are ambassadors for the VCC and wider Cadet Forces and must, therefore, uphold the appropriate standards.