Images and GDPR

A photo or video containing an identifiable person is considered personal data, and the persons depicted have rights that you need to take into account.

Photographing and filming events

When photographing or filming events, the lawful basis is public interest, as the Higher Education Act requires us to collaborate with the surrounding society. The purpose of photography is to inform the public about our activities. It is also often part of the experience for invited guests to have access to mingle pictures from the event. The people in the photos have rights and the organiser of the event has an obligation to inform the public that there will be photography.

Inform before and during the event

When inviting people to attend the event, inform them at that time that it will be photographed or filmed, e.g. in the email invitation, calendar event and the like. You should also inform people on site during the event with clear signage that photography or filming is taking place.

For example, you can download these notices as PDFs in Swedish and English and post them in several places in the venue:

Information notice Swedish + English with figure
Information notice Swedish + English without figure

Be accommodating

As far as possible and reasonable, you should accommodate people who contact you and do not want to be photographed. However, this does not mean that you have to refrain from photographing or filming the event.

If the person contacts you in advance or on site, you can advise them of the best place in the venue to avoid being photographed, but be sure to state that there is no guarantee that this can be avoided when the camera is panned over the audience. Also inform the photographer where the person is sitting.

Individuals can also be offered the opportunity to eliminate pictures they are in afterwards. In such case, remember to delete images from all the places they might be found – for example, your computer, Mediabanken, the internet and social media.

Images of employees

The lawful basis public interest also applies when photographing staff. Having your image published on the internet can be perceived by many as particularly sensitive. You must therefore always ask before photographing or publishing images of employees.

When Inhousebyrån photographs portraits of employees in the studio, the client is always informed by email that the portraits will be uploaded and stored in Mediabanken, that they may be used for future online publications or as press images, and that the person pictured may notify us that they do not wish to have their image stored in Mediabanken.

Images on personal pages on

Employees themselves decide whether they want a portrait picture on their personal page on and also upload it. It is desirable, but not compulsory, that contact persons on our external website have an accompanying picture. If a person does not want their picture presented, but their manager deems this necessary because e.g. they have a public role, one of the University's legal officers should be consulted.

Images of employees in other contexts

Sometimes you may take photos of employees in connection with a communication initiative, such as news report or online feature story. The natural thing to do is reach an agreement on photography when making arrangements with the person to do the article or equivalent.

Inform them how the images will be used and that they will be stored in Mediabanken. If the person later wants to eliminate images of themself from the web or from Mediabanken, you must make all reasonable efforts to accommodate this. This may mean that the article becomes unusable and that you may even need to unpublish it.

Images of students and external persons

When you photograph or film students and external persons, the lawful basis applied is consent. The person pictured must be asked whether they consent to Umeå University photographing them and using the image in their communication. The person pictured can withdraw their consent at any time.

When we photograph a student or external person, it is usually for a specific purpose, such as an interview, feature story or news report about the person. But the purpose can also be to collect environment images for future use, in cases where we want to have people in the environment as part of the motif. The image will then be used as a genre image. It is important that the person pictured is made aware of this and consents to it.

Always obtain the name of the person you are photographing, and enter their name in the "Medverkande i bild" [Participants in the image] field when uploading it to Mediabanken and tick "Ja" [Yes] at the "Samtycke från studenter och externa personer" [Consent from students and external persons] field.

Verbal consent is the general rule

Umeå University works with verbal consent when photographing persons aged 13 and up.

At each photo-taking occasion when one or more people are the focus of the image, the photographer must ask the following question, formulated like this or in a similar way in spoken language:

"Do you consent to Umeå University taking photos of you and publishing the images in its communication channels and on social media, and to storing the images in its image data bank?"

If the image will be used as a press image, you must also ask for consent for this. Also inform those being photographed what they need to do if they decide to withdraw their consent. It is a good idea to supplement your verbal information by handing out the following consent card, which is available to print as a PDF:

Consent card Swedish + English

Photographing children under the age of 13 – written consent

Written consent is required when photographing children under the age of 13. This is obtained using a consent form that is signed by the child's guardian. In other respects, you label the images the same way as for verbal consent when uploading them to Mediabanken.

Consent form for children under the age of 13 (signed by guardian)

Use participation agreements in certain cases

If you want to use images or filmed material in marketing, videos or printed material, a withdrawal of consent may be difficult to manage. In such case, it is better to draw up a more binding participation agreement.

Read more about agreements (contracts) in the "Lawful bases" section (Swedish)

When people are in the background

Sometimes other people are in the background when you are photographing people in the environment. And sometimes people are spending time in the area or passing by when you are taking environment photos. A judgment call must be made in such circumstances. How close do you get to the people? If you get too close, they become part of the focus of the image and you should obtain their consent. If it is a wide shot with a lot of people passing by, obtaining consent may be practically impossible.

One possibility here, as in the case of event photography, is to post signs to inform people that photography or filming is taking place, for what purpose, during what time period, and who to contact.

When a person withdraws their consent to be depicted in an image

If someone wants to withdraw their consent to appear in an image, you must delete it from all places it is published.

Via Mediabanken, you can see which websites the image is used on. Search for the image and click on "View". If the image has been used on social media, there is no such link. A separate search for the image must be performed in each channel. If the image can still be found on computers, servers or in cameras, it must be deleted from these places as well.


Consent card  – Swedish + English
Consent form for children under the age of 13 (signed by guardian) – Swedish 
Information notice about photography (without figure) – Swedish + English
Information notice about photography (with figure) – Swedish + English

Participation agreement
A copy of the signed agreement must be sent to the Registrar.

Participation agreement – image and video
Participation agreement for persons under the age of 18 – image and video (signed by guardian) – Swedish

Anja Axelsson