With the average school capturing around 30,000-50,000 photos and videos featuring students per year, scattered across various devices, I thought it timely to touch on the topic of student image protection as some of these images are then posted online, exposing a child’s digital identity to a global audience.
I have been writing about this topic for over 5 years now, but during this pandemic, more concerned parents are reaching out to me about student image-based abuse and identity theft.
Sadly, I understand why. It’s still “normal” for schools, clubs, and other child-centric organisations to post photos of their child members online without permission, even though these organisations have a moral and/or legal obligation to ensure they protect children.
Any image of a living person is considered personal data by Australian and International privacy laws, which means there are rules organisations must follow when sharing them. When those images are of children, there is an additional moral responsibility to act with caution.
The harm caused through image-based abuse (and I don’t believe this should be narrowly defined to just the sharing of intimate images) may not be physical (at the time), but the mental and emotional effects can be lifelong.
When a child gets hurt at school because of inappropriate sharing of their image(s), they are often too embarrassed to share their story. Their silence leaves the school’s reputation unscathed. The student, however, may have the harm or abuse follow them beyond school and possibly emotionally scar them for life.
With the additional stress of COVID-19 lockdown restrictions, schools require children to conduct learning online, sometimes integrated with online publishing or social media use. This new way of engagement exposes a gap in online security and privacy for school children.
Social Media Isn’t Harmless Entertainment
Did you know advertisers will have 72 million data points on a child by their thirteenth birthday?
Social media platforms use this data to create personalised content recommendations to keep children engaged. Social media effectively creates ‘echo chambers’ by making closed systems that give your child more of what they like so they spend more time on the platform.
And the longer children spend on the platform; the more advertisers pay for their attention. That’s how social media platforms make their money.
It’s clear that children don’t know what they’re signing up for, because they don’t understand how the system works.
Platforms, like TikTok, collect personal information to serve children targeted content. Information like phone numbers, videos, locations, and biometric data – all taken without sufficient warning, transparency, or meaningful consent.
As parents, it’s scary how little control we have over how platforms use our child’s data.
Are Schools Unknowingly Breaking the Law?
If schools continue to use student images in an unfettered way as marketing tools… how is that different from what Facebook, Instagram and Google are doing with children’s data?
In 2018, the FBI sent a warning to schools and parents, asking them to be more vigilant about how student personal data is collected and shared:
Malicious use of this sensitive data could result in social engineering, bullying, tracking, identity theft or other means of targeting children.
The risks are real.
The rapid adoption of online technologies by schools are putting children’s safety and wellbeing at risk. More technology use means more collection of personal and sensitive data. Right now, parents should have alarm bells going off.
If schools are collecting parent consent using a bundled ‘all-or-nothing’ approach, they are unknowingly breaking the law.
Privacy regulators and industry experts generally advise against bundled consent because it will rarely ever meet the test of proper consent; that is, consent that is voluntary, informed, current, and specific.
More schools – especially during this pandemic – are starting to get it, and I applaud them for caring enough to invest in this area. They understand how important it is to protect students online, not only within the learning environment but also their digital footprints.
What Schools Can Do
It can be challenging for schools to manage all the privacy requirements out there. But they have an obligation to protect children, and they can start with asserting more privacy controls over student photos.
Beyond sharing the actual photo or video, tagging can expose student information like name, location, interests, their close peers and more. It mystifies me how the transition from “sharing photos” to “harm” is often not considered, especially when the organisations doing the sharing are in a position of trust.
Doing the right thing is a matter of respect and consent, protecting those two things are more important than the fact of sharing. Children want to feel they are being respected – the heart of privacy – so anyone sharing, using, or publishing their images should make this the #1 priority.
The digital challenges of managing student photos are an opportunity to improve, not a reason to pull out the “too hard basket”, cut corners and increase risks.
Schools must:
- Capture current, valid photo consent from parents
- Centrally, securely store and monitor all photos/videos taken, and manage which ones can be used and shared online, based on consent
- Decide what to do when parents don’t provide consent
- Find a way to lock down sensitive case students who require further protection because of family circumstances (e.g., foster care or domestic violence in the home).
A combination of good governance, good policy, and the procurement of privacy-based technological solutions that help streamline the above essential decision-making processes when it comes to managing photos within a school environment can help support this journey.
As the saying goes: “A technological problem requires a technological solution”.
Then the challenge for all schools is to balance the growing desire to share wonderful moments, with a duty of care to protect children and provide parents with privacy and safety assurance.
What Parents Can Do
Every child has the right to privacy. All parents have a right (and responsibility) to say to their school, “please ask before sharing.”
Here is a quick checklist parents can use to assess how well their school is doing on protecting student images:
- Does your school have a student photo policy, and does it comply with Australian Privacy law?
- Did you receive an unbundled clear photo consent form that describes the possible ways a school will use your child’s photos across various channels (internal and external, online or print)?
- Is the consent valid, being asked Voluntarily, Informed, Current and Specific (VICS)?
- Have you been made aware of all possible ways your child’s photo could be used, so you can make an informed choice about whether to grant or refuse permission? Is your school asking you once a year for consent to use and publish your child’s photos for school (or related) purposes?
Is your school making student photo-protection a priority? If not, ask why not?
It’s Time to Take Back Control
When it comes to image privacy, photos should be able to be safely shared with people you know, trust and respect. Beyond that circle of trust, you should have the power to curate who can see your child’s information.
pixevety is a safe, privacy-driven photo publishing tool that keeps you in control of your content.
It empowers parents and schools to use restriction filters on all digital media content. The technology also helps verify which content can and can’t be used for online publishing purposes to assist institutions with compliance.
Create a FREE account today and start exploring a safer, private way to store and share your photos more securely online.
I’m Colin, the CEO of pixevety, a consent-driven photo management platform for schools and families focused on child digital identity protection. Thank you for reading this blog post.
