PBC Ltd’s Photographic Policy
(Mostly Junior Members’ Protection Photographic Policy and Procedures)
Portslade Bowls Club appreciates that parents, guardians and young club members do sometimes wish to celebrate or publicise their involvement and bowling achievements by being photographed or filmed at club events. But PBC Ltd reserves its right to restrict or stop such activity if safeguarding issues or concerns become apparent. We wish to avoid any inappropriate use of images in resources and media publications, on the internet or elsewhere.
(The following guidance should be read by parents or guardians prior to them completing a Photographic Permission form at the time of the junior joining the bowls club.)
Parents or Guardians should be aware that photographs or videos etc of young club members enjoying bowling may be used by the Club as a promotional asset. Great care would be taken to ensure that personal information which could be used to identify an individual is not added to the photographs, etc. Published images can unfortunately compromise the young person’s safety and privacy making them more vulnerable to individuals looking to locate, contact or groom them. Photographs can also be adapted for inappropriate use for abusive reasons. Special care needs to be taken when ‘tagging’ images for filing reference purposes.
Before PBC Ltd. or the Bowls Club use the images in a public environment, PBC would let parents / guardians know how, where and in what context the image(s) will be used – for example, on a public website, through social media or in a printed resource.
In view of the above, parents and youngsters have the right to decide whether images can be taken and how they will be used. In this context, parents or guardians of those members under 18s must give the Club written consent for images to be taken and used. (A Photography Permission Form must be filed with the Treasurer who acts as Membership Office when a person under 18yrs. joins the club. Permission may be revoked at any time.)
Content of photographs or filming sequences:
Those taking photographs etc. should ensure that they only convey best practice and positive aspects of bowls. Images are not to be sexual or exploitative in nature, or open to misinterpretation and misuse. Photographs should focus on the activity, rather than a particular person. Preferably images should reflect positive aspects of junior members’ involvement in bowls; like fun, competition and special achievements. We urge club members to report any inappropriate images they see published to the Safeguarding Officer.
Invited Press or a Professional photographer:
An event organiser who proposes to invite a press or a professional photographer to a session must make sure that the photographer understands their responsibilities when it comes to child protection issues. Make it clear that unsupervised access to junior members for one-on-one photography or filming sessions will not be permitted. All attendees must be advised that an invited photographer is present on site. A photographer must identify themselves to the parent or guardian before filming or taking any photographs of their son /daughter if they are under 14yrs old. The photographer must comply with the parents’ wishes; or for a 14yr. or older member then whatever their personal preference is but bearing in mind that they would have already signed a Photographic Permission form indicating their personal preference regarding being photographed in public.
Spectators taking photographs or filming:
Parents / Guardians or other spectators who plan to photograph or film whilst on PBC premises must be prepared to identify themselves and explain their reasons for recording the event on camera. Visitors may be asked to provide some form of identity with an address, or else may be asked to cease any photographic activity. In no instance should they take their photographic equipment into the changing rooms other than for storage purposes. This applies to all photographers!
Our concerns about photography:
Children may be identified, contacted or groomed for potential abuse. Photographic identification of a Junior member must be prevented to avoid circumstances where there are legal restrictions – such as if the child is in local-authority care or placed with an adoptive family or if it could reveal the child’s whereabouts to an estranged parent should there be some concerns of domestic violence.
Inappropriate or illegal images of children could be put directly on-line. Although a photo or video content may in itself be appropriate, the images may later be digitally altered out of context so becoming potentially illegal and harmful. Another concern we wish to avoid is anyone using a camera at ground level to photograph ‘up-skirts’. Such images can easily be copied and edited, perhaps to create a child-abuse image and then shared privately online, possibly later entering the public domain on websites or social media sites.
Storage, Retention, Privacy & Confidentiality considerations:
Generally, all photographs and videos captured for club purposes, whether for promotional, archival, or social use, will be stored securely in accordance with relevant data protection regulations and accessible only to authorized personnel. Images or video recordings of junior members are to be kept secure with all hard copies of images being stored in a locked drawer whilst electronic images should be stored in a protected digital folder with restricted password access. No bowls associated images are be stored on unencrypted portable equipment eg. laptops, memory sticks or mobile phones. All physical copies, if applicable, are to be kept in a secure location within the club’s premises.
Media files may be retained for a period of two years only unless otherwise required for historical reasons or are a part of official club documentation. After the retention period expires, files are to be securely deleted or archived in a manner that prevents unauthorized access. Any request for the removal of personal images of junior members from club records will be, in most instances granted; unless required by the Safeguarding Officer in the course of his/her duties. Any such request for deletion must come from the person who signed the Photographic Permission form when joining the bowls club. The text in italics above will also apply to requests from adult club members. Otherwise, they too will be granted and dealt with accordingly.
Confidentiality and Privacy of Photographs and Videos:
The Bowls Club is committed to protecting the privacy of its members and visitors regarding the capture, storage, and use of photographs and videos. All ‘media’ individuals will be handled with discretion and in accordance with applicable data protection laws.
Photographs and videos must not be shared publicly or with third parties without the explicit consent of those featured, except where club activities necessitate promotional or archival purposes and the individual’s agreement has been sought. Private and sensitive images will be stored securely, and access will be restricted to authorized personnel only. A club member may request the removal of their image from club records; refer to the previous section.
The club will take reasonable steps to prevent unauthorized access, misuse, or distribution of media. Should any privacy concerns arise, members are encouraged to report them promptly to the Club’s Safeguarding Officer so that appropriate action may be taken.
Mobile Phones:
It may be difficult to determine whether someone using a mobile phone may actually be taking photos or videoing their subject(s). Parents / Guardians must be particularly aware and are advised to move away from the suspected mobile user.
Ownership of the image:
Image ownership will remain with the owner of the photographic equipment on which the image was recorded unless PBC Ltd. had specifically commissioned and agreed a fee with the photographer for the photos / filming to be undertaken. PBC Ltd would in that instance claim ownership. A Club Officer is to be present and supervise all commissions when the agreed task is being implemented.
Open Events:
This policy still applies should the event be on PBC’s premises but is open to the general public, viz: limited and invited sponsorship days; or on pre-advertised ‘Open’ days to encourage more local people to bowl. In these circumstances, it should be made clear to all participants and parents / guardians that various kinds of images may be taken by the general public and to be on their guard.
Responding to concerns:
It is imperative that anyone who has any concern regarding inappropriate or intrusive photography (in terms of the way, by whom, or where photography is being undertaken) must immediately those concerns to a Club Officer for referral to the Club’s Safeguarding officer. Should the concern or suspicions be about potentially criminal behaviour then these must be referred by the Club to the police.
Photographic Permission Form:
This form only applies to Junior Members, those under 18yrs of age. It is to be completed when applying for new membership and will be kept safely with the other club membership files. Parents or Guardians are to sign for any youngster up the age of 14yrs but the Club will permit those over 14yrs. to make their own minds up, presuming that they have read this policy document which is available on the Club’s web site.
John Green
Company Secretary, Portslade Bowls Club Limited, (aka PBC Ltd.)
May 2025