Clubs, parents and children often want to celebrate footballing successes with photos and film. Recording a child’s progress through the season is widely seen as part of the enjoyment of the game, and some coaches use photos or film to help a player develop.

Photos and film on websites, social media, posters and in the press can carry direct and indirect risks to children if they are not handled well. The FA supports appropriate photography and filming, and asks everyone who films or takes photos in football to know and follow this guidance.

In short

• Appropriate photos and film are welcome. The aim is to reduce the risk of harm, not to stop them.
• Get written parental consent before using a child’s image in public.
• Never take photos or film in changing rooms, showers or toilets.
• Keep names and personal details away from images.
• Store photos and film securely, and know how to report a concern.

Potential risks

Inappropriate taking or use of photos and film

Some people set out to take photos or film in ways that are harmful or illegal, such as:

• Children changing.
• Photos taken in toilets.
• A camera held at ground level to take photos up girls’ skirts.
• Ambiguous images used out of context by others.
• Images copied and edited to create child-abuse content.
• Images shared privately online that get re-shared and end up in public.

Identifying, contacting or grooming a child

When a photo comes with personal details like a full name or address, it becomes easier for others to identify the child. This has led to children being found, contacted or groomed. Even without those details, information about a child’s school, club or favourite team can be used to groom them.

The risk of a child being identified or contacted is higher:

• Where legal restrictions apply, for example a child in local-authority care or placed with an adoptive family.
• Where contact with one parent is restricted after a separation, for example in domestic violence cases.
• Where a child may be a witness in criminal proceedings.

Commissioning professional photographers and local media

Photographer here includes anyone filming. If you bring in a professional photographer or invite the media, agree expectations early and plan ahead:

• Give a clear brief on what counts as appropriate content and behaviour.
• Tell them about your club’s commitment to safeguarding.
• Agree who will hold the photos and film, how long they keep them, and what they will do with them, such as selling prints or passing thumbnails to the club.
• Issue the photographer with ID that is worn at all times.
• Set out where photography is not allowed, such as toilets, changing areas and first-aid areas.
• Explain how to identify, and avoid photographing, children without parental consent.
• Do not allow unsupervised access or one-to-one sessions.
• Do not allow sessions away from the event, such as at a young person’s home.
• Tell participants and parents or carers beforehand that a professional photographer will be there.

When parental consent is not given

Clubs and organisers need a way for photographers to know which children should not appear in close-up photos or film. This might be a badge, sticker or wristband, or a system for the photographer to check with the organiser or team manager, so it is clear who should be left out.

Common sense steps to keep everyone safe

Most photos and film are appropriate and taken in good faith. These steps help keep children safe.

Do

• Share this guidance with everyone who joins the club, including officials and parents or carers.
• Get written parental consent before using a player’s photo or film in public, such as on the club website, a Facebook page or in a newspaper.
• Protect any child under care proceedings with legal restrictions by keeping their image out of the public domain. The Club Annual Membership Information and Consent Form covers this (see Guidance Note 8.2).
• Make sure everyone featured is suitably dressed, at least a vest or shirt and shorts.
• Aim for photos that show the full range of youngsters taking part, including boys and girls, disabled people and ethnic minority communities.
• Remind parents, carers and spectators that sharing photos or film alongside details about children on social media can have negative consequences, and that care is needed with tagging.
• Set up clear ways to report and handle concerns, including how to contact the Police when needed.

Don’t

• Publish photos with someone’s full name unless you have written consent and have told the parents or carers how the photo will be used.
• Put player profiles online with photos and detailed personal information.
• Reuse an image for something other than what was first agreed, for example publishing a clubhouse picture in the local press.
• Allow photos or film in changing rooms, showers or toilets, including on mobile phones.
• Include alcohol or gambling advertising in photos or film of children.

Remember

• Taking appropriate photos or film in a public place is not an offence, even if you are asked not to.
• No-one has the right to decide who can and cannot take photos on public land.
• If you have serious concerns about a possible child protection issue, call the Police. Only do this where you believe someone may be acting unlawfully or putting a child at risk.
• On private land, the owner decides whether photography or filming is allowed. They need to make this known in advance, and can ask someone to leave if they do not comply.
• Try not to use footage of people wearing jewellery, as wearing it while playing goes against the Laws of the Game and is a health and safety issue.
• Swimming as a club social activity carries a higher risk of misuse than football. For this, footage should focus on the activity rather than one child, avoid showing a child’s full face and body, for example showing them in the water or from the waist or shoulders up, and avoid angles that could be misread or misused.

If you are concerned about the inappropriate use of photos or film, report it to your County FA Designated Safeguarding Officer or the FA Safeguarding Team at [email protected].

Filming as a coaching aid

Coaches who use filming to help coaching should tell parents, carers and players that it is part of the programme, and take care when storing the clips. Parental consent must be in place first. This can be gathered at the start of the season through the Club Annual Membership Information and Consent Form (see Guidance Note 8.2).

General photography and filming of events

Organisers often want wide-angle or general footage of an event, the venue, and opening or closing ceremonies. It is usually not practical or proportionate to get consent from every child for this, or to stop it because a few parents object. Organisers should make clear to everyone that this kind of footage will be taken, and why.

Secure storage

Photos and film of children must be kept securely:

• Keep hard copies in a locked drawer.
• Keep digital photos in a protected folder with restricted access.
• Do not store photos or film on unencrypted portable equipment such as laptops, memory sticks or phones.

For clubs and leagues:

• If you store and use photos to identify children and adults for official purposes, such as ID cards, follow the legal requirements for handling personal information.
• For data protection and privacy guidance, see the Information Commissioner’s Office at ico.org.uk.

Misuse and manipulation of photos and film

Someone with bad intent may target a vulnerable child to take footage that is then uploaded or shared with others who have a sexual interest. Sometimes this footage is used to threaten or force a child into unwanted, illegal sexual activity. It can also be part of wider bullying meant to humiliate a young person. Even as a joke between friends, and without abusive intent, a young person who takes and shares inappropriate footage may be committing a serious offence and could face prosecution.

Reporting a concern

Everyone involved, including officials, volunteers, children and parents or carers, should know they can report concerns about inappropriate or intrusive photography or filming. That covers the way it is done, who is doing it, or where.

You can report to:

• The event organiser or another official.
• The Event Designated Safeguarding Officer.
• The Club Welfare Officer.
• The County FA Designated Safeguarding Officer.
• The FA Safeguarding Team at [email protected].

There should be a safeguarding procedure so reported concerns are handled like any other child-protection issue. Concerns about a professional photographer should also go to their employer.

This guidance draws on advice from the NSPCC CPSU, available at thecpsu.org.uk/help-advice/topics/photography.