Photo Media Policy
1. Purpose
This policy outlines how communicationZZ collects, uses, stores, and shares photographs and videos of students, staff, and participants during both online learning sessions and in-person activities, such as summer outings. It ensures compliance with Hong Kong’s privacy and copyright laws.
2. Scope
This policy applies to:
a. All students (including minors), parents/guardians, staff, contractors, and volunteers
b. All media captured during online classes, virtual events, and physical activities (e.g. summer courses, workshops)
c. All platforms used for communication and sharing (e.g. WhatsApp, Zoom, Instagram, Facebook)
3. Legal Compliance
This policy complies with:
a. Personal Data (Privacy) Ordinance (Cap. 486)
b. Copyright Ordinance (Cap. 528)
c. Protection of Children and Juveniles Ordinance (Cap. 213)
d. Control of Obscene and Indecent Articles Ordinance (Cap. 390)
4. Consent Requirements
a. Written consent is required before capturing or using identifiable images of individuals
b. For minors, parental/guardian consent is mandatory
c. Consent forms must specify: Purpose of the photos/videos
d. Platforms where they may be shared (e.g. WhatsApp, Zoom, Instagram, Facebook)
e. Duration of use
f. Right to withdraw consent (with limitations)
5. Use of Photos & Videos
Photos/videos may be used for:
a.Sharing student progress and highlights with parents via WhatsApp groups
b. Internal documentation and educational records
c. Marketing (only with explicit opt-in consent)
Photos/videos must not be:
a. Shared publicly without prior consent
b. Used for commercial purposes unless explicitly agreed
c. Altered in misleading or inappropriate ways
6. Online Learning Considerations
a. Screenshots or recordings of online classes will only be taken with prior notice and consent
b. Students and parents will be informed of any data collection during virtual sessions
c. All recordings will be stored securely and used only for educational purposes
d. Occasionally, group classes and individual lessons may be live streamed for instructional or transparency purposes. Only the instructor’s face and voice will be recorded. Students will not be recorded, identified, or made visible or audible in any way.
e. Students (or their parents/guardians, if minors) may request to stop the live stream at any time during the session. Such requests will be honored immediately and without consequence.
7. Data Protection & Storage
a. All media is treated as personal data
b. Stored securely on encrypted or access-controlled systems
c. Retained only as long as necessary for the stated purpose
d. Access limited to authorised personnel
8. Withdrawal of Consent
a. Consent may be withdrawn at any time in writing
b. However, photos already shared (e.g. via WhatsApp) cannot be retracted due to technical limitations
c. No further use of the individual’s image will occur after withdrawal
9. Staff & Contractor Responsibilities
a. Must obtain and document consent before capturing or sharing images
b. Must follow this policy and report any misuse or breach immediately
10. Review & Updates
a. This policy will be reviewed annually or upon changes in legal requirements or operational practices
b. Last updated: 15 September 2025