NEW TESTAMENT CHURCH OF GOD WILLENHALL TABERNACLE
PRIVACY, PHOTOGRAPHY, FILMING & SAFEGUARDING POLICY
Church: New Testament Church of God Willenhall Tabernacle (WILLTAB)
Address: 5 Upper Lichfield Street, Willenhall, West Midlands
Effective from: 1 April 2026
Policy review: April 2027
Policy owner: Church Leadership
Safeguarding Lead: Mavis Wright
Version: 1.0
Church contact email: Info@ntcgwillenhalltab.org
Telephone: __________________________
Safeguarding email: __________________________
Safeguarding telephone: __________________________
1. PURPOSE OF THIS POLICY
New Testament Church of God Willenhall Tabernacle (WILLTAB) is committed to respecting the privacy, dignity, safety and wellbeing of everyone who attends, participates in, serves within or engages with the Church.
The Church collects and uses personal information for legitimate purposes including church administration, communication, pastoral care, ministry, events and safeguarding.
WILLTAB has an active social media and digital presence, including photography, video, livestreaming and the sharing of content through platforms such as Facebook, Instagram, YouTube and other communication channels.
The Church recognises that photography, filming and online publication can create particular privacy and safeguarding concerns for children, young people, looked-after children, adults at risk and anyone whose identity or location may need to remain confidential.
This policy explains:
• how the Church collects, uses and protects personal information;
• how photography, filming and livestreaming are managed;
• how images and video may be used online;
• how children, young people and adults at risk are protected;
• the responsibility of parents, guardians and foster carers to notify the Church of known restrictions;
• the responsibilities of Church workers and volunteers;
• how safeguarding and privacy concerns are reported and dealt with; and
• how individuals can raise questions or concerns.
This policy should be read alongside the Church's Safeguarding Policy, children's and youth procedures, volunteer procedures and applicable denominational safeguarding requirements.
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2. OUR COMMITMENT
WILLTAB is committed to:
• respecting people's privacy and dignity;
• handling personal information responsibly and securely;
• collecting only information that is reasonably necessary;
• taking additional care when handling children's information;
• respecting photography, filming and publicity restrictions that have been made known to the Church;
• taking reasonable steps to protect children, young people and adults at risk from inappropriate exposure;
• providing clear notice where photography, filming or livestreaming is taking place;
• responding appropriately to privacy and safeguarding concerns;
• ensuring Church workers and volunteers understand their responsibilities;
• regularly reviewing our practices; and
• acting promptly where a privacy or safeguarding concern is identified.
Safeguarding is a shared responsibility and is not the responsibility of the Safeguarding Lead alone.
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3. WHO THIS POLICY APPLIES TO
This policy applies to:
• Church members;
• visitors and guests;
• children and young people;
• parents and guardians;
• foster carers;
• adults at risk;
• ministers and Church leaders;
• employees;
• volunteers;
• ministry leaders;
• children's and youth workers;
• photographers and videographers;
• media and communications volunteers; and
• anyone acting for or representing the Church.
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4. PERSONAL INFORMATION WE MAY COLLECT
Depending on the circumstances, the Church may collect:
• names;
• addresses;
• telephone numbers;
• email addresses;
• emergency contact details;
• attendance information;
• membership information;
• volunteering and ministry information;
• children's registration information;
• parent, guardian or foster-carer details;
• communication preferences;
• consent or permission information;
• photographs and video recordings;
• livestream recordings;
• correspondence;
• pastoral information;
• safeguarding information;
• event registration and booking information; and
• information submitted through the Church website, forms, email, social media or other Church platforms.
The Church will seek to collect only information that is relevant and reasonably necessary for the purpose for which it is being collected.
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5. HOW WE USE PERSONAL INFORMATION
Personal information may be used to:
• administer Church activities and services;
• communicate with members, visitors and participants;
• organise services and events;
• manage volunteering and ministry;
• provide pastoral support;
• maintain safeguarding records;
• respond to safeguarding concerns;
• contact emergency contacts where appropriate;
• meet legal or regulatory obligations;
• communicate important Church information;
• promote Church activities and events;
• operate the Church website and social media;
• create and publish photographs and videos;
• livestream Church services and events;
• maintain appropriate records of Church activities; and
• support the safety and wellbeing of those engaging with the Church.
The Church will not knowingly use personal information for an unrelated purpose without appropriate consideration of the legal basis and privacy implications.
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6. SENSITIVE AND SAFEGUARDING INFORMATION
Some information requires particular care because disclosure could cause harm, distress or risk.
This may include information concerning:
• health or disability;
• care needs;
• safeguarding concerns;
• family circumstances;
• children's welfare;
• allegations or incidents;
• adults at risk;
• a child's care status;
• court or confidentiality restrictions;
• publicity restrictions; or
• circumstances where disclosure of someone's identity or location could place them at risk.
Such information will be treated confidentially and access will be limited to those with a legitimate need to know.
Where there is a lawful basis to do so, information may be shared with appropriate individuals or organisations where this is necessary to protect someone from harm.
Data protection and privacy must not be used as a barrier to appropriate safeguarding action.
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7. PHOTOGRAPHY, FILMING AND LIVESTREAMING
WILLTAB may photograph, record video or livestream Church activities for communication, outreach, community engagement and promotional purposes.
This may include:
• Sunday services;
• worship;
• preaching and teaching;
• conferences;
• women's, men's and youth events;
• community activities;
• celebrations;
• performances;
• baptisms;
• interviews and testimonies;
• promotional material;
• livestreams; and
• social media content.
Images and recordings may be copied, downloaded, shared or redistributed by others once published online. The Church will therefore take reasonable care to collect and use such material responsibly.
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8. NOTICE OF PHOTOGRAPHY AND FILMING
Where reasonably practicable, the Church will provide notice that photography, filming or livestreaming may take place.
Notice may be provided through:
• entrance signs;
• notices;
• event information;
• booking or registration information;
• announcements; or
• participant information.
Where practical, cameras will primarily be (but not limited to) directed towards the platform, pulpit, worship area or other designated areas rather than unnecessarily focusing on members of the congregation.
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9. CHILDREN AND YOUNG PEOPLE
WILLTAB recognises the need for additional care when photographing, filming or publishing images of children and young people.
For identifiable images intended for official Church publicity, social media, website or promotional purposes, appropriate parental or guardian permission will be obtained in accordance with Church procedures where required.
When deciding whether an image or recording is appropriate, the Church will consider factors including:
• the child's age and understanding;
• the child's circumstances;
• the purpose for which the image will be used;
• where the child appears in the image;
• whether the child is identifiable;
• any known safeguarding concerns;
• whether publication is appropriate and proportionate; and
• whether publication could create a foreseeable risk.
Previous permission does not prevent the Church from deciding not to use a particular image if circumstances have changed or a safeguarding concern has subsequently arisen.
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10. LOOKED-AFTER CHILDREN AND CHILDREN WITH SPECIFIC RESTRICTIONS
Some children may have circumstances in which photographing, filming or publicly identifying them could create a risk.
This may include children who:
• are looked after;
• are in foster care;
• are subject to a court order;
• have publicity restrictions;
• have identity or location restrictions;
• may be at risk from a particular individual;
• have adoption or care-related confidentiality requirements; or
• have another specific safeguarding or confidentiality restriction.
Responsibility to notify the Church
Parents, guardians and foster carers have an important responsibility to inform the Church of any relevant restriction known to them that applies to the child.
Wherever possible, this should be done before an activity or service where photography, filming or livestreaming may take place.
For a looked-after child, foster carers should notify the Church of known restrictions and, where appropriate, provide confirmation of restrictions identified by the placing authority, social worker, local authority or person with appropriate parental responsibility.
The Church should also be informed promptly if circumstances or restrictions change.
Restrictions may include:
• no photography;
• no filming;
• no livestreaming;
• no social media;
• no publication of the child's name;
• no identifiable online presence; or
• no publication of location or identifying information.
Important safeguarding principle
A child should never be expected to tell the photographer, camera operator or media team about their own restriction.
Once the Church has been notified of a restriction, responsibility also rests with the Church to take reasonable steps to implement and respect that restriction.
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11. CHURCH RESPONSIBILITY WHEN A RESTRICTION IS KNOWN
Where WILLTAB has been notified of a photography, filming or publicity restriction, the Church will take reasonable steps to protect the individual.
Depending on the circumstances, this may include:
• securely recording the restriction;
• informing relevant members of the media team on a need-to-know basis;
• providing or directing the individual towards a designated camera-free area;
• positioning the individual away from planned filming where appropriate;
• avoiding identifiable photographs;
• excluding the individual from group photographs;
• reviewing images before publication where appropriate;
• ensuring the individual's name is not published alongside an image where this is restricted; and
• consulting the Safeguarding Lead where necessary.
Known restrictions will be communicated appropriately without unnecessarily disclosing sensitive personal or safeguarding information.
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12. CAMERA-FREE AREA
Where practical, the Church may provide a clearly identified Camera-Free Area.
Parents, guardians, foster carers and individuals who do not wish to appear in photographs or recordings are encouraged to use this area where available.
The Church will make reasonable efforts not to deliberately direct cameras towards a designated Camera-Free Area.
These are currently the Mother & Baby section on the ground floor and the back centre 4 rows of the balcony. Should you choose to sit on the front rows of the centre and sides of the balcony, you may be caught on camera, albeit at a reasonable distance.
* Please note the Mother & Baby section may only be used if seats are vacant. This section is a priority seating area for parents and carers with babies and/ or small toddlers. If you yourself do not have a baby or small toddler with you, you may be asked to move in order for us to accommodate them)
The Camera-Free Area is an additional safeguard but does not replace the Church's responsibility once a specific restriction has been formally notified to the Church.
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13. ADULTS AT RISK
WILLTAB recognises that some adults may be particularly vulnerable to abuse, exploitation, unwanted exposure or other harm.
Where an adult at risk has a restriction concerning photography, filming, publicity or the publication of their identity, the Church will take the concern seriously.
A carer, representative or other authorised person may notify the Church where appropriate.
The Church will consider:
• the individual's wishes;
• dignity and privacy;
• safeguarding considerations;
• capacity where relevant;
• the purpose of the photography or filming; and
• the potential consequences of publication.
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14. SOCIAL MEDIA AND ONLINE CONTENT
WILLTAB may use platforms including:
• Facebook;
• Instagram;
• YouTube;
• TikTok;
• the Church website; and
• other platforms adopted by the Church.
Content may include:
• photographs;
• video clips;
• service highlights;
• worship;
• sermons and teaching;
• testimonies;
• interviews;
• event promotion;
• celebrations; and
• community activities.
Social media content can reach a wide audience and may be copied, shared or redistributed.
The Church will therefore take reasonable care before publishing content, particularly where it contains:
• identifiable images of children;
• individuals for whom restrictions have previously been notified;
• personal information; or
• information that could reveal someone's location or circumstances.
The Church will seek to avoid unnecessary identification of children and unnecessary details such as:
• full names;
• addresses;
• schools; or
• precise locations,
alongside an image where such information is not necessary.
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15. LIVESTREAMING
Where services or events are livestreamed, the Church will provide reasonable notice wherever practicable.
Cameras will primarily focus on the platform, pulpit, worship area or other designated areas.
The Church will seek to:
• avoid unnecessary close-up shots of the congregation;
• communicate known restrictions to the media team;
• avoid deliberately singling out children without appropriate permission;
• provide a Camera-Free Area where practical; and
• respect known restrictions.
Anyone with a specific restriction should notify the Church before the relevant service or event and use the Camera-Free Area where available.
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16. PHOTOGRAPHY BY MEMBERS AND VISITORS
Members and visitors may take photographs for personal use, subject to Church rules and safeguarding requirements.
People should not photograph or film children, young people or adults at risk where doing so could compromise their privacy, dignity or safety.
The Church may restrict photography or filming during particular activities where necessary for:
• safeguarding;
• privacy;
• confidentiality;
• pastoral sensitivity;
• children's activities; or
• another legitimate purpose.
Members and visitors should exercise care before posting photographs of other people on personal social media, particularly photographs involving children.
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17. STORAGE AND SECURITY
Photographs, videos and recordings held by the Church should be stored securely as reasonably practicable.
Access should be limited to people who require access for an appropriate Church purpose.
Media workers and volunteers should:
• use appropriate passwords and security measures;
• keep Church accounts secure;
• not share login details unnecessarily;
• avoid storing sensitive material on unsecured devices;
• not use Church images for personal purposes;
• report lost devices or suspected breaches promptly; and
• follow Church instructions concerning storage and deletion.
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18. USE OF PERSONAL DEVICES
Where Church workers or volunteers use personal devices for Church photography, filming or media activities, they remain responsible for handling the material appropriately.
Images and recordings should:
• be used only for an appropriate Church purpose;
• be transferred to approved Church storage or media systems where applicable;
• not be unnecessarily retained; and
• not be shared outside authorised Church channels.
Safeguarding-sensitive images or information should not be retained unnecessarily on personal devices.
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19. RETENTION AND DELETION
The Church will seek not to retain personal information, photographs or recordings for longer than is reasonably necessary for the purpose for which they are held.
Some information may need to be retained for longer because of:
• safeguarding requirements;
• legal obligations;
• accounting or administrative purposes;
• historical records; or
• another legitimate Church purpose.
Information should be reviewed periodically and securely deleted or archived when it is no longer required.
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20. WITHDRAWING PERMISSION AND CONTENT PUBLISHED IN BREACH OF A KNOWN RESTRICTION
An individual, parent or guardian may contact the Church if they no longer wish their child to be included in future photographs or videos used for Church publicity.
Where appropriate, the Church will take reasonable steps to stop future use of content on its own platforms.
The Church does not undertake to remove historical content simply because permission is later withdrawn where the content was lawfully published and no previous restriction had been notified to the Church.
However, where content has been published contrary to a photography, filming or publicity restriction that had already been notified to WILLTAB, the matter will be treated as a privacy and/or safeguarding concern.
The Church will take appropriate and proportionate action, which may include:
• removing or replacing the affected content from Church-controlled platforms;
• reviewing how the breach occurred;
• reviewing relevant procedures; and
• taking steps to reduce the likelihood of recurrence.
If content has already been copied, downloaded or reposted by another person or organisation, the Church cannot guarantee its removal from platforms outside its control.
Where a safeguarding concern exists, the Church will prioritise the safety of the individual and take appropriate action.
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21. SAFEGUARDING CONCERNS
Any concern relating to photography, filming, social media or privacy that may involve safeguarding should be reported promptly in accordance with the Church Safeguarding Policy.
Concerns may include:
• abuse or neglect;
• exploitation;
• grooming;
• inappropriate behaviour;
• inappropriate photography or filming;
• inappropriate online communication;
• unauthorised publication of an image;
• bullying or harassment;
• concerns about a Church worker or volunteer; or
• any other concern that someone may be at risk of harm.
Individuals should not investigate safeguarding concerns themselves unless this forms part of their authorised role.
Concerns should be referred to the Safeguarding Lead or another designated person in accordance with Church procedures.
Where necessary, concerns may be referred to children's social care, adult social care, the police or another appropriate statutory or professional body.
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22. CONFIDENTIALITY
Sensitive personal and safeguarding information will be treated respectfully and securely.
Information will only be shared with people who have a legitimate reason to receive it.
Confidentiality does not prevent the Church from making a lawful and necessary safeguarding disclosure where sharing information is required to protect someone from harm.
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23. DATA BREACHES
A data or privacy breach may include:
• a lost phone, camera or other device;
• sending information to the wrong person;
• unauthorised access to a Church account;
• accidental publication of confidential information;
• publication of an image of a child subject to a known restriction;
• loss of safeguarding records; or
• unauthorised disclosure of personal information.
Any suspected breach should be reported immediately to Church Leadership or the person responsible for data protection.
Where a breach involves safeguarding, the Safeguarding Lead should also be informed immediately.
The Church will assess the incident, take reasonable steps to contain it and determine what further action is required.
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24. CHILDREN'S BEST INTERESTS
The welfare and best interests of children will be an important consideration in decisions concerning photography, filming and online publication.
The Church will not assume that a child can safely be photographed simply because they are attending a public Church service or event.
Where the Church has been informed that publication could create a safeguarding, confidentiality or other significant risk, reasonable steps will be taken to prevent inappropriate publication.
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25. RESPONSIBILITIES OF CHURCH WORKERS AND VOLUNTEERS
Church workers and volunteers are expected to:
• follow this policy and the Church Safeguarding Policy;
• respect known photography and filming restrictions;
• maintain confidentiality;
• access personal or safeguarding information only where necessary;
• report safeguarding and data protection concerns;
• use images and recordings appropriately;
• follow Church instructions concerning photography, filming, storage and publication; and
• act in a way that protects the dignity and safety of others.
Anyone working with children or adults at risk must meet applicable safeguarding requirements, including recruitment, training and DBS requirements where applicable.
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26. DATA PROTECTION RIGHTS
Subject to applicable law, individuals may have rights including the right to:
• be informed about how their information is used;
• access their personal information;
• request correction of inaccurate information;
• request deletion in appropriate circumstances;
• request restriction of processing;
• object to certain processing; and
• withdraw consent where processing is based on consent.
These rights may be subject to legal exceptions, particularly where safeguarding, legal obligations or another lawful purpose applies.
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27. SAFEGUARDING AND INFORMATION SHARING
Data protection and safeguarding responsibilities should work together.
The Church will not use data protection as a reason to withhold information where there is a lawful and necessary need to share information to protect someone.
Where appropriate and lawful, information may be shared with:
• the Safeguarding Lead;
• Church Leadership;
• the relevant denominational safeguarding body;
• children's social care;
• adult social care;
• the police; or
• another appropriate statutory or professional body.
Information sharing should be necessary, proportionate and limited to what is appropriate for the purpose.
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28. CONTACTING WILLTAB
New Testament Church of God – Willenhall Tabernacle
5 Upper Lichfield Street
Willenhall
West Midlands
Email: Info@ntcgwillenhalltab.org
Telephone: __________________________
Safeguarding Lead: Mavis Wright
Safeguarding email: __________________________
Safeguarding telephone: __________________________
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29. RAISING A CONCERN OR COMPLAINT
Privacy concerns should be raised with Church Leadership.
The Church will consider concerns fairly and appropriately.
Where a concern relates to safeguarding, it will be dealt with under the Church Safeguarding Policy rather than being treated solely as a data protection complaint.
Where an individual remains dissatisfied, they may have the right to raise a concern with the Information Commissioner's Office (ICO), subject to the circumstances of the matter.
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30. POLICY REVIEW
This policy will be reviewed at least annually and sooner where necessary.
A review may also take place following:
• significant changes to Church activities;
• changes to relevant law or guidance;
• a serious incident;
• a data breach;
• a safeguarding concern involving photography, filming or social media;
• significant changes to digital or social media activity; or
• another event indicating that the policy should be amended.
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31. APPROVAL
Policy: Privacy, Photography, Filming & Safeguarding Policy
Effective date: 1 April 2026
Approved by: ____________________________________
Position: ________________________________________
Date approved: ___________________________________
Next review: April 2027
Signature: _______________________________________
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APPENDIX 1
PHOTOGRAPHY, FILMING & LIVESTREAMING NOTICE
PLEASE NOTE
Photography, filming and/or livestreaming may take place during Church services and events.
Images and video may be used on official Church channels, including the website and social media.
DO NOT WISH TO APPEAR?
Please speak to Church Leadership or the Media Team before the service or event.
Please use the designated CAMERA-FREE AREA where available.
PARENTS, GUARDIANS & FOSTER CARERS
If a child:
• must not be photographed or filmed;
• must not appear on livestream;
• must not appear on social media;
• is looked after;
• is subject to a court or care restriction;
• has a confidentiality or publicity restriction; or
• could be placed at risk through online identification,
please notify Church Leadership or the Safeguarding Lead before the service or event.
Do not rely on the child telling the camera operator.
Once the Church has been notified, the Church will take reasonable steps to respect known restrictions.
If you are unsure, please speak to the Safeguarding Lead.
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APPENDIX 2
PARENT/GUARDIAN/FOSTER CARER PHOTOGRAPHY & FILMING NOTIFICATION
Child's full name:
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Parent/Guardian/Foster Carer's name:
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Contact number:
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PLEASE TICK AS APPROPRIATE
The child may:
☐ Appear in general Church photography
☐ Appear in Church video recordings
☐ Appear in livestreams
☐ Appear on official Church social media
The child must NOT:
☐ Be photographed
☐ Be filmed
☐ Appear in livestreams
☐ Appear on social media
☐ Have their name published alongside an image
☐ Have identifying or location information published
☐ There is a specific safeguarding, care or confidentiality restriction.
ADDITIONAL INFORMATION
Please provide any information the Church needs to know in order to respect the restriction:
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CONFIRMATION
I confirm that I have informed the Church of any relevant restrictions known to me concerning the child's photography, filming, publicity or online presence.
Name:
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Relationship to child:
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Signature:
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Date:
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For Church use – received by:
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Date received:
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Action/notification required:
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APPENDIX 3
MEDIA TEAM SAFEGUARDING CHECK
Before publishing a photograph, video or other media content, consider:
☐ Is appropriate permission in place where required?
☐ Are there any known photography or filming restrictions?
☐ Has the Safeguarding Lead identified anyone who must not appear?
☐ Does the content contain unnecessary identifying information?
☐ Is the person shown appropriately and with dignity?
☐ Does the caption contain unnecessary personal information?
☐ Is there any foreseeable safeguarding risk?
☐ Is the image/video appropriate for its intended purpose?
☐ Has the content been reviewed where appropriate?
☐ If there is any doubt, has the matter been referred to Church Leadership or the Safeguarding Lead?
IF IN DOUBT, DO NOT PUBLISH UNTIL THE CONCERN HAS BEEN RESOLVED.
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KEY PRINCIPLE
TELL US AND WE WILL TAKE REASONABLE STEPS TO PROTECT.
Parents, guardians and foster carers have an important responsibility to notify WILLTAB of known restrictions concerning a child's photography, filming or online presence.
However, once the Church has been notified, the Church also has a responsibility to take reasonable steps to respect that restriction and protect the individual.
A child should never be expected to manage or explain their own photography restriction.
SAFEGUARDING IS A SHARED RESPONSIBILITY.