Our Photography Policy
Our contact details:
Lucy Sparkles Pte Ltd
Address: 30E Watten Rise, Watten Residences, 287402, Singapore
Telephone: 8112 6564
Email: [email protected]
1. THE PURPOSE AND SCOPE OF THIS POLICY STATEMENT
We are Lucy Sparkles PTE LTD T/A Lucy Sparkles & Friends (“we” or “us”.) This Photography Policy outlines Lucy Sparkles & Friends’ practices regarding the collection, storage and use of images. Our activities include teaching music, drama and dance to young children aged 0-7. We mostly teach at privately hired venues alongside parents and carers and at pre-schools alongside staff. We also entertain at children’s parties at people’s homes or privately hired venues such as a church hall.
2. LEGAL FRAMEWORK
This policy has been drawn up on the basis of legislation, policy and guidance that seeks to protect children in Singapore. Summaries of key legislation and guidance are available from the Ministry of Social and Family Development (MSF) here.
3. OUR POLICY STATEMENT
We believe that:
- children and young people should never experience abuse of any kind
- we have a responsibility to promote the welfare of all children and young people and to take, share and use images of children safely
We recognise that:
- the welfare of the children and young people taking part in our activities is paramount
- children and their parents/carers have a right to decide whether their images are taken and how these may be used, regardless of age, disability, gender reassignment, race, religion or belief, sex or sexual orientation
- consent to take images of children is only meaningful when the children and their parents/carers understand the potential risks associated with the use and distribution of these images
- there are potential risks associated with sharing images of children online. More information about this is available from the MSF.
We will seek to keep children and young people safe by:
- always asking for specific and informed consent from a parent or carer before taking and using a child’s image
- not using the names of children whose images are being used in our published material
- never publishing personal information about individual children
- making sure children, their parents and carers understand how images of children will be securely stored and for how long (including how we will control access to the images and their associated information)
- reducing the risk of images being copied and used inappropriately by only using images of children in appropriate clothing (including safety wear if necessary)
- using images that positively reflect young people’s involvement in the activity
We will also develop a procedure for reporting the abuse or misuse of images of children as part of our child protection procedures. We will ensure everyone involved in our organisation knows the procedures to follow to keep children safe.
4. PHOTOGRAPHY AND/OR FILMING FOR PERSONAL USE
Parents and carers may take photographs of their own children at a Lucy Sparkles & Friends class or party for personal use. However, they must not take any photographs of other children at a class or party under any circumstances, nor film/record any children (including their own) or any portion of the class/party without our written consent.
We recommend that parents and carers:
- only use images of children in suitable dress to reduce the risk of inappropriate use
- do not accompany images with personal information that could be used by an individual to learn more about a child prior to grooming them for abuse. E.g. this is X who likes to collect stamps
- check the privacy settings of their social media account to understand who else will be able to view any images they share
5. PHOTOGRAPHY AND/OR FILMING FOR LUCY SPARKLES & FRIENDS USE
We may from time to time, and with specific and informed indication of your consent for us to do so, collect photographic or video images of you or your child/children taken/recorded at Lucy Sparkles & Friends events. Under the Personal Data Protection Act 2012, the lawful basis we rely on for processing this information is your consent.
Lucy Sparkles & Friends may use these photographs or video images for the purpose of making our media applications more accessible, inspiring, and motivating for our audience; to promote or advertise the aims of Lucy Sparkles & Friends, which may include our printed publications; website; adverts; audio-visual and electronic materials; media work; display materials; briefing of staff, and any other media we may use in the future.
- Open Classes – Video and Photography: On occasion, and with specific and informed consent of participants, classes may be photographed or filmed by us. Lucy Sparkles & Friends may use photographs and footage from classes for the purpose of making our media applications more accessible, inspiring, and motivating for our audience; to promote or advertise the aims of Lucy Sparkles & Friends, which may include our printed publications; website; adverts; audio-visual and electronic materials; media work; display materials; briefing of staff, and any other media we may use in the future.
- Pre-schools – Video and Photography: On occasion, subject to your pre-school’s photography policy, and with specific and informed consent of participants, classes may be photographed or filmed by us. Lucy Sparkles & Friends may use photographs and footage from classes for the purpose of making our media applications more accessible, inspiring, and motivating for our audience; to promote or advertise the aims of Lucy Sparkles & Friends, which may include our printed publications; website; adverts; audio-visual and electronic materials; media work; display materials; briefing of staff, and any other media we may use in the future.
- Parties: You may if you wish share images of your event with us by contacting the Party Co-ordinator at [email protected]. Please note we will only use these images with your specific and informed consent and only if they do not contain any children’s faces other than your own child’s
- Photo and Video Shoots: If we hire a photographer for a specific event, we will seek to keep children and young people safe by:
(a) providing the photographer with a clear brief about appropriate content and behaviour
(b) ensuring the photographer wears identification at all times
(c) informing parents/carers that a photographer will be at the event and ensuring they give specific and informed consent to images which feature their child being taken and shared
(d) not allowing the photographer to have unsupervised access to children
(e) not allowing the photographer to carry out sessions outside the event or at a child’s home
(f) reporting concerns regarding inappropriate or intrusive photography following our child protection procedures
6. PHOTOGRAPHY AND OR FILMING FOR WIDER USE
If people such as local journalists, professional photographers (not hired by Lucy Sparkles & Friends) or students wish to record one of our events and share the images professionally or in the wider world, they should seek permission in advance. They should provide:
- the name and address of the person using the camera
- the names of children they wish to take images of (if possible)
- the reason for taking the images and/or what the images will be used for
- a signed declaration that the information provided is valid and that the images will only be used for the reasons given
Lucy Sparkles & Friends will verify these details and decide whether to grant permission for photographs/films to be taken. We will seek consent from the children who are the intended subjects of the images and their parents and inform the photographer of anyone who does not give consent.
At the event we will inform children, parents and carers that an external photographer is present and ensure they are easily identifiable, for example by using them with a coloured identification badge. If Lucy Sparkles & Friends is concerned that someone unknown to us is using their sessions for photography or filming purposes, we will ask them to leave and (depending on the nature of the concerns) follow our child protection procedures. You should exercise caution and look at the privacy statement applicable to the website in question.
7. STORING IMAGES
We will store photographs and videos of children securely, in accordance with our safeguarding policy and data protection law. Images will be stored in password protected accounts that are encrypted, reviewed annually and deleted when no longer required. Photographs and videos may be retained for as long as necessary for the purpose for which they were originally taken. While Lucy Sparkles & Friends’ employees and associates may use unencrypted portable equipment (e.g. a mobile phone or tablet to collect images), we will never store images of children on unencrypted portable equipment such as laptops, memory sticks and mobile phones.
8. CONTACT DETAILS
Photography and Images Co-ordinator
Name: Lucy Milan Davis Email: [email protected]
We are committed to reviewing our policy and good practice annually. This policy was last reviewed on: 2nd July 2021.