This blog provides guidance for taking photos and videos during religious activities such as Church services, Eucharist, or Christenings etc.
This does not relate to non-religious activities such as fetes or parties etc. The National Safeguarding Team have created guidance for non-religious activities involving children and vulnerable adults in the Safer Environments and Activities guidance here.
If no one from your congregation will be identifiable during filming or photography then you don’t need to gain consent. However, if members of the congregation will be visible, for example by cameras facing the congregation, you must implement the following:
Consent (Adults and children over the age of 16)
Those appearing in film or photography must give written consent, because attendance at a church service reveals religious belief, which is a special category data under GDPR. You should specify on the consent form exactly what aspects of the service you intend to film.
A photo release form should also be signed by adults and must include all the places that the photo or video may be used by the church.
Regular attendees at the church need to only sign this once but it should be refreshed regularly, such as every three years. However, new visitors should be asked before the service or event begins.
Consent (Children 16 years and under)
Videos containing children may be used by the church if consent has been given by their parent or guardian, following the same guidelines as above.
Consent can be withdrawn
There are any number of reasons why someone may choose to withdraw their consent, and it is not your role to discover why they would like to withdraw, but to make this as easy as possible, as this is their legal right.
- When someone withdraws their consent, videos or images of that person should be deleted everywhere it has been stored or published online and offline, if these images are of that individual only.
- If someone who later withdraws consent appears in a group video (i.e. as a member of the congregation), it is unlikely that the video can be edited. Many churches may find it easiest to remove the video completely, but the church may find it helpful to discuss this with the individual who has withdrawn their consent to see if an alternative solution can be found. However, if the individual insists on removal, the church should comply.
- It is more likely that a church would experience people not giving consent initially, than withdrawing it later, however it is wise to be prepared for this to happen, particularly where children are filmed because they may choose to have these images removed once they get older.
Please consider whether they would want their images to be uploaded to the internet which may remain there permanently.
If permission has not been given, you will need ask them (and their parents or guardians) to sit in the film free area
Prepare ahead for filming
Tell your community your plans for filming and send out the photo release forms to your email list, WhatsApp groups, or Facebook groups – anywhere your community can see it - so they are ready.
Have spare copies with you on the day for anyone who has not yet signed. Remember, your regular attendees only need to sign this once every three years.
Simple signage to tell people the service will be recorded and where it will be broadcast will remind them on the day.
Create film free area
Those who do not give their consent to be in a video or photo do not need to sign the consent form.
Create a film free area within your church building where they may sit. This could be a side aisle, or a few rows at the back.
Simple signs will help identify where this space is, and make sure that those who are filming or taking photos are aware.
At the beginning of the service, those leading the service can remind people and give them opportunity to move.
New privacy notice
An updated Privacy Notice Template is provided here. You should add your church’s details and display it somewhere with your church building and on your website so that it can be read before the consent form is signed.
Read the Safer Environments for Churches guidance from the National Safeguarding Team which covers more on GDPR and safeguarding.
Many members of your community may have given their consent to appear as part of the congregation during filming, however, we must still be considerate to them as they worship together with others. A good camera person will be sensitive to the congregations’ needs and won’t distract or interrupt the act of worship.
Some considerations for filming services
- Communion, personal prayers are times of particular privacy and intimacy. Individuals in the congregation may have given consent, however, may still not want to be the focus of filming at this time. You should specify on the consent form exactly what aspects of the service you intend to film.
- If the camera is panning across the church building to follow a speaker, such as the vicar, do not lose focus on who else will be visible in the frame. It is better to leave the speaker out of frame, than film a member of the congregation who has not given their consent.
- Position the camera to face in the opposite direction to the photo free area so that those sitting within it are confident the camera won’t accidentally pan across them. It’s better to be overly cautious and show their privacy is being protected.
- If using a pan-tilt-zoom camera which will capture the congregation, make sure the camera operator has been fully briefed on what to do, including showing them these guidelines.