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Posted

Hi there,

 

Would consent be required from Staff if a school wanted to produce a wall board of staff photos/Name to go up in a reception area? I believe so but just want to see if anyone else has come across this

 

Thanks

Posted
Hi there,

 

Would consent be required from Staff if a school wanted to produce a wall board of staff photos/Name to go up in a reception area? I believe so but just want to see if anyone else has come across this

 

Thanks

 

Ask yourself what is the purpose behind having the photos there.

 

Then ask if there is an applicable lawful basis.

 

If others would like to give responses I’ll feed back tomorrow.

Posted
It would be classed as personal data as you would be able to identify the individual. You are going to need consent for doing that and give your staff the ability to rescind that if they want to in the future (and remove their photo).
Posted
It would be classed as personal data as you would be able to identify the individual. You are going to need consent for doing that and give your staff the ability to rescind that if they want to in the future (and remove their photo).

 

You don’t always need consent if it is personal data. If you did you would have pupils refusing to have their attendance recorded or have detention details sent to parents.

 

Or staff refusing to have performance management recorded.

 

What is the purpose of having photos in reception?

Posted

In my last (primary) school there was one on display for all staff. The head teacher just had it put up. I don't think anyone complained.

 

Current school is only HT, DH, SLT and safeguarding team. Not sure what they did but knowing my school they just put it up without consulting.

Posted
I could see safeguarding as a reasoning for having the photos up in a "public" area that parents/public can see, tho not sure which (if any) basis that can work with. Assuming the same issue would apply if the photos were placed within the school as well (i.e outside offices for students to help identify staff)
  • Thanks 1
Posted
I could see safeguarding as a reasoning for having the photos up in a "public" area that parents/public can see, tho not sure which (if any) basis that can work with. Assuming the same issue would apply if the photos were placed within the school as well (i.e outside offices for students to help identify staff)

 

Safeguarding is a very good purpose. In a previous response we had SLT and safeguarding team ... so a good example.

 

Why would people need to know them?

 

(And apologies for leading people through this ... just trying to demonstrate the process that is needed).

  • Thanks 2
Posted
Identification is all I can think of, so that someone would know they're talking to the correct person - But that's covered under ID cards
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Posted
Why would people need to know them?

 

It's handy for IT to consult when they need to put a name to a face or vice versa?

 

I sometimes think I have a variant of Prosopagnosia...

  • Thanks 1
Posted
It's handy for IT to consult when they need to put a name to a face or vice versa?

 

I sometimes think I have a variant of Prosopagnosia...

 

That's why we had the staff photos in SIMs though for the IT team to see who was who. Seeing as we had to add the photos in as well anyway.

  • Thanks 1
Posted
That's why we had the staff photos in SIMs though for the IT team to see who was who. Seeing as we had to add the photos in as well anyway.

 

I always feel like looking in SIMS is snooping - too much detail there.

  • Thanks 2
Posted
At a previous school we were asked if it was OK for our photo to be put up. Legalities aside, I appreciated being asked and very few declined. I don't think those declining the request significantly affected any aspect of safeguarding. The reason for the photo board - I don't recall with any accuracy, but it would have been a relatively minor reason, like just putting a face to a name.
  • Thanks 2
Posted
I always feel like looking in SIMS is snooping - too much detail there.

 

That's why there's permissions, roles and groups etc within SIMs though. We only needed to view names, titles, timetable and add photos. That's all we needed so that's all we had setup.

 

At a previous school we were asked if it was OK for our photo to be put up. Legalities aside, I appreciated being asked and very few declined. I don't think those declining the request significantly affected any aspect of safeguarding. The reason for the photo board - I don't recall with any accuracy, but it would have been a relatively minor reason, like just putting a face to a name.

 

I think it's a case of respecting people's privacy. Some people are extroverts and some are introverts. The name and photo being on the staff badge is good enough for data and ID purposes. Personally I think on ours the full name (first and last) of the staff shouldn't be on there.

  • Thanks 1
Posted

Tricky. With my security hat on I feel it is releasing too much information, someone can come in and instantly pick up a lot of information to run a social engineering attack, or if something external is going on confirm, that an individual actual works at the school.

With my friendly, happy-clappy hat on I think it is good as it gives parents an idea of who is who, visitors can get an idea of who they are visiting, but none of that is a lawful basis, just nice.

 

So the compromise of Management and/or the Safeguarding team would seem the best option. This would allow an external party or visitor to report a safeguarding concern without announcing to all and sundry, asking for the DSL by name rather than role, if it was sensitive issue or if they wanted to report it confidentially.

  • Thanks 2
Posted

Not completely derailing this thread I hope (as we indeed have a display board in reception with all the staff photos on it)...

 

But how about on your website.... Yes/No?

Posted
Tricky. With my security hat on I feel it is releasing too much information, someone can come in and instantly pick up a lot of information to run a social engineering attack, or if something external is going on confirm, that an individual actual works at the school.

With my friendly, happy-clappy hat on I think it is good as it gives parents an idea of who is who, visitors can get an idea of who they are visiting, but none of that is a lawful basis, just nice.

 

So the compromise of Management and/or the Safeguarding team would seem the best option. This would allow an external party or visitor to report a safeguarding concern without announcing to all and sundry, asking for the DSL by name rather than role, if it was sensitive issue or if they wanted to report it confidentially.

 

 

I'd argue the social engineering point is a very valid point indeed and enough to cause issues - full staff name, photo, place of work etc.

 

Not completely derailing this thread I hope (as we indeed have a display board in reception with all the staff photos on it)...

 

But how about on your website.... Yes/No?

 

On our website as names only, no full first names either. Same as my previous school.

 

Ours just got put up with names etc. I carefully removed my picture and nothing has ever been said.

 

+1 I'd personally request it to be taken down for privacy reasons.

  • Thanks 1
Posted
Not completely derailing this thread I hope (as we indeed have a display board in reception with all the staff photos on it)...

 

But how about on your website.... Yes/No?

 

We've sought permission from all staff for website photos/personal information. Had the odd 1 or 2 not consent, so we left them out. The world has gone mad but that's a whole new topic!!!

  • Thanks 1
Posted
Ours just got put up with names etc. I carefully removed my picture and nothing has ever been said.

 

Are you saying nobody asked permission to put it up there? I have had a similar issue where my picture appeared on the website (no permission requested), when I found out I had it removed. I have never taken part in any photos for school apart from for an ID badge (which is the one they used), I also made it clear I didn't want to go on the board in reception...

 

On our website as names only, no full first names either. Same as my previous school.

 

As in Miss. Smith?

 

Had the odd 1 or 2 not consent, so we left them out. The world has gone mad but that's a whole new topic!!!

 

Are those statements related?

  • Thanks 1
Posted
The world has gone data. Thanks for matching the person to the name, now my ML software can more easily identify everyone, match them to their social media accounts, cctv footage, etc etc. I can then track your movements, people you meet, create a graph of who's connected to who.
  • Thanks 1
Posted

Thanks for the responses so far ...

 

So, we have that you need a purpose ... we've had one good example - for safeguarding reasons. To expand this a bit more ... schools have responsibilities to make sure that parents, children and visitors know who to approach should there be a concern. To see and ID badge you need to be fairly close to a person but if you have seen their pic on the noticeboard in reception, or even on the website (the purpose is the same ... it is just the place where data is published is different ... but you can review this as a whole) then there is a better chance the right person will be recognised and approached. Safeguarding is part of the school's responsibility so it clearly fits within Public Task as a lawful basis. So ... no consent needed. That's not to say staff can't refuse. This is the right to object, and whilst not an absolute right, consideration may be needed (adults who have escaped abusive relationships may not want their pic on the website, but fine on a noticeboard in reception).

 

There are a range of possible purposes ...

Allowing parents and children to identify staff (Note what I mentioned about ID cards. One company I know stopped using lanyards after complaints that the ID Cards ended up situation smack bang in the middle of cleavage, and that was linked to many people being very uncomfortable about the situation on both sides)

Allowing parents and children to identify staff roles and teams (important for DSL and so on)

Supporting parental engagement

Professional standing (photos on website)

 

and there can be more.

Once you have these you look at the relevant lawful basis ... Public Task is a general one ... but LI could be used (you need to do an assessment on this) and then Consent.

 

Risk assessments can help with the breadth of where images are used and what you do when you need to uphold the rights of individuals.

 

Does that help @DrCheese ?

Posted
The world has gone data. Thanks for matching the person to the name, now my ML software can more easily identify everyone, match them to their social media accounts, cctv footage, etc etc. I can then track your movements, people you meet, create a graph of who's connected to who.

 

Yes, all the stuff that analysts used to do in their heads but can now be done on a wider scale. That is why Privacy by Design is such an important principle.

Posted
As in Miss. Smith?

 

Yes we had something like ...

 

Science

Mr P James

 

Maths

Mr H Cooper

 

PE

Mr H Simpson

 

Easy enough for the name, enough privacy etc. Students shouldn't know the first names of staff really.

Posted

Well, it seems that photos and position of staff are still on the website with title and surname (even down to the cleaners... really?)!

 

But the board in reception has now been changed to group photos for year or department (SLT, Admin, Family Workers, YEAR 3, 4 etc).

 

Harder to keep relevant with all the staff changes recently... Up to date info...?

 

Taking into consideration the comments from @GrumbleDook on the fact that it is not an absolute right to refuse to have my picture publicised, I will stand by my decision as I feel with the Public Task purpose so far given as safeguarding, my lack of interaction with children (and the fact I am either in my office or the server room 90% of the time) hopefully means that I am not needed to be identified by the general public (website) or parents/children/visitors (notice board).

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