Special Topics

School photographs

Photographs are often taken of students, in many cases by professional photographers, at the school’s request. Any photograph of one or more identifiable individual(s) is considered to be personal information.

Schools are permitted to collect personal information, including photographs, where it is necessary to the proper administration of a lawfully authorized activity.92 The collection of student photographs is considered necessary to the operation of a school (a lawfully authorized activity under the Education Act) because, for example, photographs enable staff to identify students.


Are schools required to give notice when photographs are taken?

Yes, a school must give notice if photographs of its students are taken by employees or anyone else working for the school, which may include contractors hired by the school and volunteers.93 The school can provide notice in a variety of ways, including on the school’s website, by email, regular mail, or in the student handbook (see Does a school board need to give notice that it is collecting personal information?).


What are the school’s responsibilities if it uses a professional photographer to take photographs?

If a school board uses a professional photographer, the board is still ultimately responsible for the security and confidentiality of its students’ personal information.94 Any service agreements with vendors must align with the provisions of MFIPPA. Their contracts should clearly describe the administrative, physical and technical safeguards to protect personal information (see How do school boards safeguard records).


In IPC privacy reports MC16-4 and MC16-5, the IPC found that schools are permitted to disclose limited personal information of students to a professional photographer for administrative purposes.

The IPC also concluded that disclosure for limited marketing-related purposes was permitted because it could be reasonably expected that a student’s personal information would be disclosed to the photographer for the purpose of offering parents the opportunity to purchase their children’s school photographs. However, parents/guardians should be given the choice to opt out of receiving marketing materials.


What about photographs taken by people who are not employed by the school?

Individuals not employed by the school may not be subject to MFIPPA. However, given that schools and school boards control who has access to school property, they are ultimately responsible for the safety and security of their students and the security and confidentiality of the students’ personal information, including their image.

In some instances, parents and students take photographs at sporting events, school concerts and other functions, and these photos appear in the school newsletter or in photo displays. On occasion, the media or researchers may request permission to photograph within the school setting. In these situations, the school board must notify students and their parents or guardians and get their consent.

Schools should develop a policy regarding photography of students on school property or at school events by non-school employees. The policy should be developed in consultation with parents and guardians and communicated to them and to teachers. These policies should apply to all images, including photographs, web postings, film and video recordings.


92. MFIPPA, s. 28(2)
93. MFIPPA, s. 29(2)
94. Regulation 823 under MFIPPA,s. 3
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