Images of People

Images of People

Images of individuals, such as photographs or video, can be considered personal data if:

  • an individual is the focus of the image.
  • the image includes significant biographical facts about an individual.
  • the processing of the image affects an individual’s privacy.

Where an individual is incidental to the image captured, for example if they are part of a crowd, appear in the background, or is otherwise not easily identifiable, this would not be considered personal data.

In most circumstances, consent is the appropriate Lawful Basis for Processing for capturing images of individuals.

Please consult the Media & Copyright Consent webpage for further guidance on capturing images of people and recording consent where needed.