Good Practice Note
Good Practice Note – School Websites, Photographs and Data Protection Issues
This Good Practice Note is aimed at those working in schools and concerns some of the data protection issues associated with a school website and blog. Each school is required to have Acceptable Use Policies (AUPs) covering the use of all information and communication technologies (ICTs) used in the school. The School’s Internet AUP should cover the use of the school website/blog and the school should consider how digital and video images are captured and stored within the school, and if images of pupils are published on the school website how the Data Protection Act (2003 and 1988) and Data Protection in Schools might apply.
Digital and video images of pupils on school websites and blogs
Publishing images of pupils on the school’s website can be very motivating and encouraging for the pupils. It can help celebrate their work and help create a community spirit within the school while bringing their work to a wider audience.
There are however data protection issues (see http://dataprotectionschools.ie/en/Data-Protection-Guidelines/Taking-Using-Images-Photos/) to be considered when publishing the image of a minor on the Internet. The school must comply with the requirements of:
- Data Protection (Amendment) Act 2003
- The Data Protection Act 1988
- Video Recordings Act 1989
Any image published online may easily be edited inappropriately or misused. Pupils may also be personally identified and attract unwanted attention through a photograph posted on the school website. To manage these risks the school should consider:
- Asking for parental permission to cover use of such photographs throughout the school year in line with the conditions of the school’s AUP.
- Consider using group photos rather than full-face photos of individual children
- Keeping names and images separate.
- Password locking videos
- Creating a procedure for regularly checking the website for posting of personal data
- Teaching pupils eSafety: see Posting Inappropriate Photos Lesson in Topic 3 of Be Safe Be Webwise and the CSPE booklet "Sign up, Log in, Opt out protecting your privacy and controlling your data" on the Data Protection Website
Each school should develop its own guidelines for the protection of both pupils and staff and these notes will be a starting point. The following sample School Website statements are part of the Webwise Internet AUP Template. The Webwise Internet Safety Education Pack was sent to every school in March 2007 and its Information & Advice for Schools booklet is also available for download.
The School Website (Webwise Sample AUP)
- Students will be given the opportunity to publish projects, artwork or school work on the World Wide Web in accordance with clear policies and approval processes regarding the content that can be loaded to the school’s website.
- The website will be regularly checked to ensure that there is no content that compromises the safety of students or staff.
- A school website which allows comments to be posted such as a blog, guestbook, noticeboard will be checked frequently to ensure that no personal details are contained or posted.
- A school website will not have links to outside un-moderated sites such as ‘Next blog’ , flickr, etc. where the content is not known to be suitable.
- The publication of student work will be co-ordinated by a teacher.
- Students’ work will appear in an educational context on Web pages with copyright notice prohibiting the copying of such work without express written permission.
- The school will endeavour to use digital photographs, audio or video clips focusing on group activities. Content focusing on individual students will not be published on the school website without parental permission. Video clips may be password protected.
- Personal student information including home address and contact details will be omitted from school web pages.
- The school website will avoid publishing the first name and last name of individuals in a photograph.
- The school will ensure that the image files are appropriately named and will not use students’ names in image file names or ALT tags if published on the web.
- Students will continue to own the copyright of any work published.
The Case Study below from the Data Protection Commissioner’s Sign up, Log in, Opt out CSPE Teaching Resource will give an understanding to schools about their obligations and responsibilities pertaining to The Data Protection Acts (1988 and 2003).