Photography, Images and Social Media

1. Purpose

Photographs can celebrate progress and show families and partners what we do. For our learners they also carry real risk. Many are at risk of exploitation or have contact restrictions, and simply being seen at an alternative provision can affect how others treat them. Images can be copied, shared and altered, including by AI. This policy makes sure every image of a learner is taken safely, used only with clear consent and never puts anyone at risk.

2. Scope

This policy applies to everyone at or working with Care Cove Alternative Provision: staff, agency and partner staff, coaches, volunteers, students, SWMC members, visitors, families and learners. It covers photographs, video and audio of learners on site, in outdoor classrooms, on placements and at events, and every Care Cove channel: the website (carecove.co.uk), Instagram (@carecoveap), print and the press. It applies to every AP learner, whoever commissions the place.

3. Law and guidance

• UK GDPR and the Data Protection Act 2018, as amended by the Data (Use and Access) Act 2025. An image of an identifiable person is personal data. Consent must be freely given, specific, informed and as easy to withdraw as to give. Our lawful basis for publicity images is consent, as the Data Protection, Retention and Information Sharing policy sets out.

• Keeping Children Safe in Education 2026: generative AI is an online safety risk, and nude and semi-nude images include AI-generated and deepfake images. The UKCIS advice on sharing nudes and semi-nudes and the DfE guidance on generative AI in education apply.

• Protection of Children Act 1978, Criminal Justice Act 1988 and Coroners and Justice Act 2009: making, possessing or sharing an indecent image of a child is a crime, including AI-generated images.

• Our contracts with commissioning local authorities: no press announcements, no publicising a contract or its contents, and no use of a commissioning local authority's name or logo in promotion or marketing, without its prior written consent.

4. Roles and responsibilities

5. Consent

5.1 What consent means here

• Written: on the form in Appendix A, recorded on Connect. Nobody assumes consent.

• Learner and parent: we need the learner's agreement and the written consent of a parent or carer with parental responsibility. If either says no, the answer is no. For a looked-after child we also need the local authority's written agreement through the child's social worker, and follow its advice on parental consent.

• Specific to each use: each use is listed separately. Agreeing to one is not agreeing to another. The press is always asked about separately, each time.

• Informed: the key mentor explains that a recognisable image online may tell people who know the learner that they attend Care Cove, that Instagram is a worldwide service run by another company, and that published images can be copied.

• Free: saying no never affects the placement.

• Withdrawable: at any time, in any way, including by telling any member of staff. The withdrawal is recorded on Connect the same day and the image removed from our website and Instagram within 2 working days. Printed items already given out cannot be recalled but are not reprinted.

A learner can also say no on the day, and staff respect that. Staff and volunteers are photographed for publication only with their own written consent.

5.2 Images for the learner's record

Images kept only in the learner's record, such as evidence for a qualification, are part of delivering the placement under the Data Protection, Retention and Information Sharing policy. We still ask about them on the form, and if a learner does not want to be photographed we record evidence another way, such as a written observation.

6. Learners who must never be photographed for publication

The DSL sets a "no publication" flag on Connect whenever publishing any image of a learner could increase risk. A flagged learner may appear only in their own learning record. The flag is always set for:

• a looked-after child, unless the local authority has agreed in writing;

• a learner at risk of criminal or sexual exploitation, county lines or serious youth violence;

• a learner with a child protection plan or other protection concern where publicity could add to the risk;

• a learner with a court order or contact restriction, or whose whereabouts must be kept from someone;

• a learner involved in criminal proceedings or subject to reporting restrictions.

The DSL reviews flags whenever risk changes and at each formal plan review. The flag overrides any consent.

7. Taking images

• Care Cove devices only. Never use a personal phone, smart watch or camera to photograph or film a learner, not even for a moment. This applies to agency staff, coaches, volunteers and partners too.

• Check first: the consent record and any flag on Connect.

• Have a purpose: learning evidence, accreditation portfolios, the RESET Passport, celebrating achievement or a consented publicity use.

• Never take images in toilets, regulation spaces or therapy rooms; of a learner who is distressed, partly dressed, or during or after a physical intervention or search; of an injury (the Safeguarding and Child Protection policy explains how injuries are recorded); or in any way that could embarrass a learner.

• Off site, avoid identifiable members of the public and anything showing routes or places a learner regularly uses. Placement employers, Dream Chasers coaches and other partners do not photograph our learners for their own use.

8. Publishing on our website and Instagram

Only the Director and staff the Director authorises post on Care Cove accounts. The accounts use multi-factor authentication, and access is removed the day an authorised person leaves.

Our default is images in which learners cannot be recognised: hands at work, finished products, backs or wide shots without faces. A recognisable image is published only with consent for that channel and no flag. Before posting any image that includes a learner, the poster checks the consent record that day, the Director approves, and the Administrator records it in the publication log. Every post must:

• never name a learner (including first names, initials or nicknames) or give their age or school;

• show no identifying details, such as school uniforms, badges, home areas, street names, house numbers, vehicles or the current location;

• carry no geotag, be posted after the session (never live) and never tag learners or families;

• never describe a learner's needs, behaviour, history or reasons for attending;

• never mention a commissioning local authority's contract, describe a placement as funded by it, or use its name or logo without its written consent. We name a school or another local authority only with its written agreement.

Case studies and quotes are anonymised and used only with consent. Comments that identify a learner are deleted. Care Cove accounts do not follow or message learners; anyone sending a direct message is directed to hello@carecove.co.uk, and any safeguarding concern goes to the DSL immediately.

9. Storage, retention and deletion

• Upload images to Connect (learning record) or the restricted Care Cove publicity folder, and delete them from the device by the end of the day. Never store them on personal devices, personal cloud accounts or messaging apps.

• Record images and consent forms are kept with the learner's education record, for the period in Appendix A of the Data Protection, Retention and Information Sharing policy.

• When a placement ends, unpublished publicity images are deleted and we stop using the learner's images in anything new. Images on our website and Instagram are removed within one month unless the learner and parent agree in writing that they can stay. The removal log records each removal.

10. Staff personal social media

The Staff Code of Conduct applies in full. In particular:

• Keep accounts private. Never contact learners or families through them, and never send or accept friend or follow requests from current learners or former learners under 18.

• Never post images taken at work or anything about learners, families, colleagues, incidents or commissioning local authorities, even without names. Do not check in at Care Cove or outdoor classrooms while working.

• You may share Care Cove's official posts, but never add comments or tags that could identify anyone.

• If a learner or parent contacts you on a personal account, do not reply. Tell the Head of AP the same day and record it on Connect, or tell the DSL immediately if it raises a safeguarding concern.

11. Learners taking images

Learner phones and connected devices stay in lockers all day (the Mobile Phones and Digital Devices policy). As their acceptable use agreement says, learners do not photograph or film anyone at Care Cove, including other learners, staff and members of the public in outdoor classrooms. On Care Cove devices they photograph only their own work, objects and places, in a supervised task a teacher sets, and never send or post the images.

Filming fights, upskirting, or sharing images of other learners or staff, on or off site, is dealt with under the Behaviour, Rewards and Restorative Practice and Anti-Bullying policies, and goes to the DSL where anyone may be harmed. Learners are taught about consent, their digital footprint and the law on images.

12. Deepfakes and AI-generated images

• Nobody may use AI to create, edit or animate an image, video or voice of a real learner, member of staff or family member, including face swaps and "nudify" apps. This is a disciplinary matter for staff and a behaviour and safeguarding matter for learners.

• Care Cove never puts images of learners into AI tools and does not use AI-generated images of young people in publicity.

• Published images can be copied and altered, which is one reason our default is images without faces.

• A manipulated image of a learner is a safeguarding concern. A sexual deepfake of a child is an indecent image of a child and is illegal. Follow section 13 and the Online Safety and Acceptable Use policy.

• A deepfake of a member of staff is reported to the Director, who offers support, reports it to the platform and involves the police where it may be a crime, under the Dignity at Work and Preventing Sexual Harassment policy.

13. If an image is misused

1. Tell the DSL immediately if a learner may be at risk, and the Director in every case.

2. Do not share, copy or comment on the image. Never view, screenshot or save a nude or semi-nude image; note where it is instead.

3. Remove it from our channels at once and ask the platform to take it down.

4. The DSL decides on safeguarding action: telling parents and the school, a Sheffield Safeguarding Hub referral, the police, and helping the learner use the Childline and Internet Watch Foundation Report Remove tool, following the UKCIS guidance.

5. The Director treats it as a possible data breach: logged the same day, reported to the ICO within 72 hours where reportable, the commissioning local authority told immediately where its placed learners are involved, and reviewed by the SWMC.

6. Misuse by staff, volunteers or partners is handled under the Managing Allegations Against Staff and Low-Level Concerns policy and, where relevant, the Disciplinary, Capability and Grievance policy.

7. We tell the learner and family what happened and what we did, unless the DSL advises that would increase the risk.

14. Parents, carers and visitors at events

At events, families may photograph or film only their own child, for their own use, and must not post online any image showing another learner. We say this on invitations and at the start. Where a flagged learner is present, staff may ask that no photographs are taken at all, without saying why, and can photograph each family's own child on a Care Cove device to share through the Family portal. Visitors and professionals never photograph learners, as the Site Security, Visitors and CCTV policy sets out.

15. The press and media

• Every media enquiry goes to the Director the same day. Staff do not comment.

• The Director tells the commissioning local authority's contract manager before responding to any enquiry about the service, and makes no announcement about a contract without the commissioning local authority's written consent.

• The press meet or photograph learners only with specific written consent for that occasion and a DSL flag check, with staff present throughout. We never give names, and decline if an outlet insists. Families are told we cannot recall an image once the press has used it.

16. Monitoring and review

Monthly, the Administrator checks Care Cove devices for images not uploaded and deleted, and spot-checks the publication log against consent records. Termly, the Director checks the website and Instagram against consent records and removal deadlines, and the SWMC reviews image incidents and samples consent records. This policy is reviewed every year, or sooner after an incident, a change in law or guidance, or a contract change.

17. Related policies

• 01 Safeguarding and Child Protection
• 03 Managing Allegations Against Staff and Low-Level Concerns
• 06 Online Safety and Acceptable Use
• 07 Behaviour, Rewards and Restorative Practice
• 10 Mobile Phones and Digital Devices
• 17 Data Protection, Retention and Information Sharing
• 21 Staff Code of Conduct
• 28 Site Security, Visitors and CCTV
• 29 Anti-Bullying
• 32 Disciplinary, Capability and Grievance
• 34 Privacy Notices for Learners, Families and Staff
• 43 Dignity at Work and Preventing Sexual Harassment

Appendix A: Consent form outline

Completed with the key mentor at the initial meeting and stored on Care Cove Connect.

Document control and ratification

This policy is signed off by the Designated Safeguarding Lead and the Head of Alternative Provision, and ratified by the Social Work Management Committee. It is reviewed every year, or sooner after an incident or a change in law, statutory guidance or contract requirements, and it is available to any commissioning local authority on request.