The purpose of this policy is to:
- protect children, young people and vulnerable adults who take part in Kent Music’s services, events, and activities, specifically those where photographs, videos, and recordings may be takenÂ
- set out the overarching principles that guide our approach to photographs/videos/recordings being taken of children, young people and vulnerable adults during our events and activitiesÂ
- to ensure that we operate in line with our values and within the law when creating, using, and sharing images of children, young people, and vulnerable adultsÂ
This policy applies to all staff, volunteers and other adults associated with Kent Music.
We use legitimate interest as the lawful basis for our processing and storage of media images. We believe that the processing of your data is necessary for the operation of our music education service and that it does not override your fundamental rights and freedoms.
This policy should be read alongside our organisational policies and procedures, including:
- Safeguarding policy Â
- Procedures for responding to concerns about a child or young person’s wellbeingÂ
- Code of conduct for adults working with children and young peopleÂ
- Staff Code of ConductÂ
- Online safety policy and guidanceÂ
- Acceptable Use of Technology PolicyÂ
- Online Instrumental and Vocal Lessons Guidance for Parents, Carers and LearnersÂ
- Online Instrumental and Vocal Lessons Guidance for TeachersÂ
- Data Management Policy Â
Kent Music is registered with the Information Commissioner’s Office (ICO). Kent Music has implemented an Acceptable Use of Technology policy which will cover all staff. This will include an audit and ongoing monitoring of compliance.
We believe that:
- children and young people should never experience abuse of any kindÂ
- we have a responsibility to promote the welfare of all children and young people and to take, share and use images of children safelyÂ
We recognise that:Â
- the welfare of the children and young people taking part in our activities is paramountÂ
- children and their parents/carers have a right to decide whether their images are taken and how these may be usedÂ
- there are potential risks associated with sharing images of children onlineÂ
We will seek to keep children and young people safe by:Â Â
- aways giving the parents or carers (or the child themselves, if ages 13 or older) the choice to opt out
- changing the names of children whose images are being used in our published material whenever possible (and only using first names if we do need to identify them)Â
- never publishing personal information about individual childrenÂ
- 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)Â
- reducing the risk of images being copied and used inappropriately by only using images of children in appropriate clothingÂ
- using images that positively reflect young people’s involvement in the activityÂ
Requirements for parents/carers and students
When having lessons delivered online, students should be located somewhere:
- with room to play an instrument/microphone and space to set up the laptop/PC/phone they will use to connect to the online lesson or courseÂ
- where they can focus and that is not noisy Â
- within earshot of a parent, carer, or responsible adult (to help sort out practical difficulties, if the internet connection drops, or if the student is uncomfortable about anything) Â
- that is appropriate (e.g. not a bedroom or bathroom)Â
Students having lessons online should be dressed appropriately, as if they were attending the lesson in person.
Screen recording and/or taking screenshots in online activities
It is not possible for Kent Music to prohibit participants from recording still or video images of their computer screen, whether they use software built into the computer or take pictures or videos of their screen using another device. However, we will ask all participants before or at the start of an online activity not to take screenshots or video recordings of any part of the session.
Recording of online activities
Kent Music currently uses Zoom Video Communications zoom.us and Microsoft Teams teams.microsoft.com for videotelephony. It is possible for the session host to record audio and video through these applications – it is our policy that only Kent Music employees using their Kent Music email address and a Kent Music (not personal) device will be used for recordings, and these will be stored on a Kent Music device or on our server.
Permission must be sought from the tutor in advance if any recording is to be taken of the tutor either vocally or visually.
Photography and/or filming for personal use
When children themselves, parents/carers or spectators are taking photographs or filming at our events and the images are for personal use, we will publish guidance about image sharing in advance, or at the event and/or announce details of our media policy before the start of the event. This includes:
- reminding parents/carers and children that they can opt out of Kent Music taking and using images of children
- asking people to gain permission from children and their parents/carers before sharing photographs and videos that include themÂ
- recommending that people check the privacy settings of their social media account to understand who else will be able to view any images they shareÂ
Photography and/or filming for Kent Music’s use
Images posted online to Kent Music websites or social media accounts should never be, and never be approved to be, accompanied by the full name of the child or any personal contact information.
The Designated Safeguarding Lead (DSL) and Deputy DSLs for Kent Music have overall responsibility for ensuring the acceptable, safe use and storage of all recording technologies and images involving children, young people, and vulnerable adults. Responsibility for individual activities and programmes within Kent Music will lie with the Programme or Activity Manager, in consultation with the DSL. All images (including moving images) should be available for scrutiny by the DSL and staff members should be able to justify any images in their possession. Images taken should be uploaded to the Kent Music secure storage where they will be securely held. Once uploaded it is the tutor’s responsibility to delete the image from the recording device.
External photographers/videographers engaged by Kent Music should read this policy and have an agreed plan for obtaining and storing of images of students, negotiated with the DSL and/or Communications Manager and specified in their contract for services. Images should not be posted on third party websites without express permission from Kent Music and parents/carers and/or students.
In line with Kent Music’s Acceptable Use of Technology policy, images stored on Kent Music staff’s personal devices must be transferred to the secure Kent Music storage area as soon as is reasonably practicable and deleted from personal devices.
Recording of Images for Educational Purposes
We recognise that our teachers and music leaders may use photography and filming as a teaching aid in activities. However, children/young people and their parents/carers must be made aware that this is part of the programme and be reminded that they can opt out of Kent Music using and taking images of students.
We will store photographs and videos of children securely, in accordance with our safeguarding policy and data protection law. We will keep hard copies of images in a locked drawer and electronic images in a protected folder with restricted access. Digital copies of forms noting decision to opt out will be stored in a separate secure folder with restricted access. Any physical forms will be scanned and stored in the same folder. Records of students opting out on SpeedAdmin is only accessible through secure login to select members of Kent Music staff.
Images used on digital and print media will be refreshed on an ongoing basis, with images of students replaced at least every seven years.
Images will be kept for archive purpose indefinitely but will not be used for other purposes, such as marketing.
Designated Safeguarding Lead
Trevor James: 01622 358431 TJames@kent-music.com
Deputy Designated Safeguarding Leads
Ruth Roberts rroberts@kent-music.com
Zoe Marksford zmarksford@kent-music.com
Media Permissions Notice
Kent Music may occasionally take still photos, video and audio recordings of students in rehearsals or concerts for archive purposes, teacher training and inclusion in our brochures and publicity material, including, but not limited to, our website and social media. Kent Music will never sell or swap your details with third parties.
We use legitimate interest as the lawful basis for our processing and storage of media images and therefore do not require consent from customers.
However, permission for Kent Music to take and use images for media or publicity can be withdrawn at any time by selecting the option to opt out.