Modeligo National SchoolCeapach, Dungarvan, Co. Waterford

Photography & Image Policy

Photography & Image Policy

Adopted by the Board of Management — March 2026

1. Purpose

Modeligo National School recognizes the value of photographs and video in celebrating school life and communicating with our school community. This policy sets out how we handle images of pupils in a manner that is compliant with the General Data Protection Regulation (GDPR), the Data Protection Acts 1988–2018, and guidance issued by the Data Protection Commission (DPC) of Ireland.

2. Lawful Basis

Photographs and video recordings of pupils are personal data under GDPR. Where images are shared publicly (e.g. on the school website, newsletter, or social media), the lawful basis is consent (Article 6(1)(a) GDPR). Because pupils under 16 cannot provide their own consent, written consent must be obtained from a parent or guardian.

3. Consent

  • Consent is sought from parents/guardians at enrolment and reviewed annually.
  • Consent forms clearly state: what images will be used for, where they will be published, and how long they will be retained.
  • Consent is specific — separate consent is sought for the school website, printed newsletters, and social media respectively.
  • Consent may be withdrawn at any time by contacting the school office in writing. Any images of a child whose consent has been withdrawn will be removed from public channels promptly.
  • Where a family has not returned a consent form, or has returned a form declining consent, images of that child will not be published.

4. What We Publish

When publishing images that include pupils, the school will:

  • Only publish images where written consent has been recorded for every child shown.
  • Avoid publishing images that could identify a child's home address, routine, or travel patterns.
  • Avoid pairing images with a child's full name (first name + surname together).
  • Avoid images that could embarrass or demean a child.
  • Prefer group or activity shots where individuals are not the sole focus.

5. School Website

Before any news post containing photographs of pupils is published on this website, the staff member responsible must confirm in the Content Management System (CMS) that written consent has been obtained for every child shown. This confirmation is recorded as part of the publishing workflow.

6. Third-Party Photographers

Where a professional photographer is engaged (e.g. for school photos or events):

  • Parents/guardians are notified in advance.
  • The photographer is instructed not to share or publish images without written authorization from the school.
  • The school's consent records apply to any images subsequently used by the school.

7. Retention

Photographs published on the school website will be retained for a maximum of three years from the date of publication, after which they will be reviewed and removed if no longer relevant. Consent records are retained for the duration of a pupil's enrolment plus one year.

8. Data Subject Rights

Parents/guardians and (where applicable) pupils have the right to:

  • Access images held about their child.
  • Erasure (right to be forgotten) — request removal of images at any time.
  • Rectification — request correction of inaccurate information accompanying an image.

Requests should be directed to the school in writing:

The school will respond within one calendar month. For full details on exercising your data protection rights, see our Data Protection Policy.

9. Responsibility

The Board of Management is responsible for this policy. The school principal is responsible for its day-to-day implementation. All teaching and administrative staff who publish content on the school website or social media channels must familiarize themselves with this policy.

10. Complaints

If you are dissatisfied with how the school has handled images of your child, you have the right to lodge a complaint with the Data Protection Commission (DPC) at www.dataprotection.ie. We would appreciate the opportunity to address your concerns directly first.

11. Related Policies

12. Review

This policy will be reviewed annually or following any relevant legislative changes.