Storage of Photographs

Just see in ACP 50, with regards to the Data Protection Act is this snippet:


  1. In practical terms, care must be taken when using old photographs or stored images. Photographs should be date stamped and kept for a maximum of 2 years and then destroyed, unless they are specifically required for archive purposes. The latter are exempt under the DPA.

So . . . how of us are actually deleting our photos that are over 2 years old, or just saying they are all required for archival purposes?


How are squadrons/wings storing their photographs?

I’m getting more and more involved in Sqn/wing media and with hundreds of photos just being taken by myself at any single event, the storage capacity quickly racks up.
Obviously the cloud is the sensible answer for storage, but I’d prefer to upload them to somewhere that allows others to view as well, allowing squadrons to then have access to high quality media for recruitment purposes etc.

Photos…of what? Anything? Does the ACP specify?

Photos of all cadets activities. . . cause we’re in the business of getting young people getting out there and doing activities. . .
What do you mean “does the ACP specify” ?

I think he means does it specifically refer to photos of people, or all photos regardless of if there’s a person in it.

Well in that case, I copied the para verbatim so assume it applies to all photographs taken within the ATC.

GDPR for a daffodil :stuck_out_tongue:

Going to assume they expect photos to be saved in folders by date in the standard format - yyyymmdd-activity.

Taking this another stage, how many squadrons ensure compliance to individuals not permitted to have they photos taken? How is monitored at higher than squadron level?

Yes, that’s what I meant.

Like a lot of squadrons, we share our numberplate with a former RAF squadron and have pictures of their aircraft displaying logos and symbols that make up part of our own crest. Should we destroy those pictures because they’re 70 years old?

I get that I’m taking this to almost absurd levels, but if it’s not spelt out, then interpretations can run wild.


It surely can only be photographs containing personal images … and frankly, if you can demonstrate you have the individual’s permission, then it is irrelevant.

I think Brooke Bond asks some salient questions.

Wait, 2 years then destroyed?

Has the person that wrote this never heard of the internet?? Once it’s on there, it’s on forever!

Don’t think they care how it’s implemented . . . but yes

ACP 50 lays the issue of consent solely on the shoulders of the Squadron Commander.

Ch 1 Para 21. The main change following introduction of the DRFC Photographic Policy 04 is that consent is needed from parents/guardians on Enrolment Form 3822A CHECK before photographs or footage is taken of cadets aged under 18. Common Case Law holds that a child lacks the legal capacity to give valid consent until aged 18 years. Consent is valid only if the person agreeing to the use of their image has a FULL and CLEAR understanding of the final use of the images. Consent covers the use of photographs/footage for publicity and recruitment reasons. Once consent is given the onus rests with parents/guardians to inform the squadron commander of any change in status. Written consent is needed as verbal consent is transient. However, under the Human Rights Act, cadets can still opt not to be photographed even if parental consent has been given.

And then

Ch 10 Para 4. Squadron Commanders are to ensure cadets for whom permission for photography has not been given are not photographed. In group activity sessions, adventure training, athletics and parades etc it may be appropriate to identify individuals without permission using an armband so images can be easily deleted and thus not used.

Personally I would love to see in the new SMS Events module a report of those without permission(s) (not just photography) and also those with declared medical issues.
(@james_elliott :smiley:)

But then as it states in the policy, they are kept for archival purposes aren’t they?

We have a discussion as staff on an event where a cadet is not allowed photos to be taken of them. Camps for example now all seem to have separate photo consent forms.

For cadets who have no photo consent in the past when they put there name down for a large event i have always rang the parents to tell them we cannot guarantee no photos are taken and it is up to them to let them go or not.

A person under 18, if they have the capacity to decide whether they have medical treatment then I’m sure that they have capacity to consent to a photograph.

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Well yes, although Ch 1 Para 21 states that they can’t give valid consent untill over 18, it does also state that "cadets can still opt not to be photographed even if parental consent has been given."

It is, but who decides what’s specifically required for archive, and through what process?

Guess that’s a question to pass up the MCO chain . . .

Well that’s gonna make the poor little blighter feel good about themselves…


The main reason I have come across for no photos is so an abusive parent who is no longer in the picture can’t find the family. Do they seriously expect us to flag this to the rest of the cadets?

Or adopted young people.
Of course the suggestion isn’t that you publicise that they can’t have photo’s for x y z. They are just suggesting you make sure the cadet is identified in some way so that photographers are aware and mindful.