School photography in an AI world: is it time to revisit consent? 

Many schools rely on photographs and videos of pupils to celebrate school life, engage their communities and support admissions and marketing activities. However, new guidance from the National Crime Agency (NCA) and the Internet Watch Foundation (IWF) suggests that schools now need to view the use of pupil images through a different lens. 

The guidance follows growing concerns about the misuse of publicly available images of children through artificial intelligence (AI). Images and videos shared online can potentially be manipulated to create harmful and illegal content, prompting the NCA and IWF to encourage parents and carers to review how and where images of their children are shared.  

For schools, the significance of the guidance is that parents are now being encouraged to revisit decisions made about the use of their children’s images and videos online.  

As awareness of these issues grows, schools may see increasing numbers of requests to restrict or withdraw consent for photographs and videos to appear on websites, social media channels, marketing materials and other publicly accessible platforms. The challenge for schools will be managing those requests whilst continuing to promote school life, celebrate pupil achievement and engage effectively with prospective families. 

The conversation is no longer simply about obtaining consent. Schools also need to consider whether their approach to publishing pupil images and videos remains appropriate in light of evolving safeguarding risks and parental expectations. 

What should schools be thinking about now? 

The publication of the NCA guidance provides a timely opportunity for schools to review their current arrangements and ask a number of practical questions: 

• Are existing image and video consent forms still fit for purpose in an AI-enabled world? 

• Do current safeguarding, data protection, photography and social media policies adequately address AI-related risks? 

• Is the school’s use of publicly accessible websites and social media proportionate and necessary? 

• How would the school respond if a significant number of parents sought to withdraw consent? 

• Are older pupils sufficiently involved in decisions about how their images and videos are used online? 

• Are staff clear about the distinction between taking photographs for internal purposes and publishing them online? 

• Could some images and videos be shared through more restricted-access platforms rather than publicly available channels? 

• Does the school have a clear process for reviewing and removing images and videos where consent is withdrawn? 

There is unlikely to be a single right answer. Every school will need to balance safeguarding considerations against the legitimate benefits that photography and video content can bring in supporting admissions, marketing, fundraising, community engagement and the celebration of pupil success. 

The NCA has been clear that the aim is not to stop families, schools and organisations sharing photographs and videos altogether. Rather, the guidance encourages more informed decision-making about the risks associated with publishing children’s images online and the steps that can be taken to reduce those risks.  

The concerns raised by the NCA and IWF sit alongside a broader regulatory response, including the Online Safety Act, which places greater responsibility on online platforms to tackle harmful content. For schools, it underlines the increasing focus on risks associated with publishing children’s images online. 

For many schools, this may be less about making wholesale changes and more about ensuring that policies, consent arrangements reflect a rapidly changing technological landscape. The latest version of Keeping Children Safe in Education 2026 which comes into force on 1 September 2026, reflects this shift by encouraging schools to consider whether their relevant policies, including their behaviour, child-on-child abuse and anti-bullying policies, adequately address issues arising from AI-generated content and manipulated images and videos of children.  

How Birketts can help 

Our education team regularly advises schools on safeguarding, data protection, parental complaints and reputational issues. 

We can support schools with reviewing photography and filming policies, updating image and video consent arrangements, responding to requests to withdraw consent, and considering how existing safeguarding frameworks should respond to emerging AI-related risks. 

The question is no longer simply whether a school has a lawful basis or permission to publish a photograph or video. Schools increasingly need to consider whether their overall approach remains appropriate in light of new technologies, emerging safeguarding concerns and changing parental expectations.