1. Policy Statement
Al-Waris Foundation uses photography, video and other media to:
- document charitable work;
- demonstrate accountability;
- provide evidence of project delivery;
- communicate impact;
- update donors;
- support fundraising;
- promote public awareness;
- maintain project records.
The charity recognises that images and recordings can contain personal information and can create safeguarding, privacy, security and dignity risks.
Obtaining compelling content must never take priority over the dignity, welfare or safety of beneficiaries.
2. Purpose
This policy establishes requirements for:
- photography;
- video recording;
- beneficiary consent;
- children;
- adults at risk;
- project documentation;
- fundraising content;
- social media;
- donor reporting;
- overseas operations;
- image storage;
- publication;
- withdrawal requests;
- AI-generated imagery.
3. Scope
This policy applies to media created, commissioned, collected or published by Al-Waris Foundation.
It applies to:
- trustees;
- volunteers;
- staff where applicable;
- photographers;
- videographers;
- project representatives;
- contractors;
- partner organisations;
- other authorised persons.
4. Core Principles
Al-Waris Foundation will seek to ensure that photography and video are:
- respectful;
- truthful;
- proportionate;
- appropriately authorised;
- safeguarding-conscious;
- privacy-conscious;
- securely handled;
- accurately contextualised.
The charity will not knowingly use imagery to fabricate charitable impact.
5. Dignity
Beneficiaries must be portrayed with dignity.
The charity should avoid content that unnecessarily:
- humiliates;
- degrades;
- stereotypes;
- exploits distress;
- exposes intimate circumstances;
- reduces a person solely to their hardship.
Poverty, emergency or vulnerability does not remove a person's right to dignity.
6. Necessity
Before recording identifiable people, the charity should consider whether identification is actually necessary.
Where the purpose can reasonably be achieved using:
- non-identifiable images;
- wider photographs;
- hands or activity;
- project infrastructure;
- supplies;
- faceless compositions;
these approaches may reduce privacy and safeguarding risk.
7. Consent and Other Lawful Bases
Consent may be an appropriate basis for photography or filming, particularly where identifiable beneficiary media will be used publicly.
However, not every photograph or recording is necessarily processed on the basis of UK GDPR consent.
The appropriate lawful basis should reflect:
- circumstances;
- purpose;
- reasonable expectations;
- vulnerability;
- publication method;
- applicable data-protection requirements.
Where the charity expressly relies on consent, that consent must meet the applicable standard.
8. Informed Consent
Where consent is sought, the person should receive a reasonable explanation of:
- who Al-Waris Foundation is;
- what is being photographed or recorded;
- why;
- where the content may appear;
- whether it may be used publicly;
- whether social media may be involved;
- whether refusal will affect assistance;
- how concerns can be raised.
The explanation should be provided in a language or manner the person can reasonably understand.
9. Voluntary Participation
A beneficiary must not be told or led to believe that receiving charitable assistance depends upon agreeing to photography or filming unless recording is genuinely necessary for a particular administrative purpose and this has been appropriately assessed.
Publicity consent should normally be separate from eligibility for assistance.
10. No Coercion
Consent must not be obtained through:
- threats;
- pressure;
- intimidation;
- deception;
- withholding ordinary assistance;
- exploiting dependency.
Particular care is required because beneficiaries may perceive charity representatives as holding power over access to assistance.
11. Refusal
A beneficiary who does not wish to participate in public photography or filming should normally still be able to receive assistance.
Reasonable arrangements should be made to avoid including that person in identifiable public content.
12. Forms of Consent
Depending on the circumstances, consent may be documented through:
- written consent;
- electronic consent;
- recorded verbal consent;
- appropriately documented verbal agreement.
More sensitive or extensive use should generally receive stronger documentation.
13. Consent Records
Where formal consent is obtained, records may include:
- person or responsible adult;
- date;
- project;
- type of media;
- permitted uses;
- restrictions;
- person obtaining consent.
Consent records should themselves be protected appropriately.
14. Children
Children require enhanced protection.
Photography or filming involving identifiable children should consider:
- age;
- safeguarding;
- parental responsibility;
- the child's own wishes;
- context;
- location disclosure;
- potential future harm.
15. Parent or Guardian Permission
For identifiable public-facing media involving a child, appropriate permission should normally be obtained from a parent, guardian or person with appropriate responsibility where reasonably practicable.
The child's own views should also be respected according to their age and understanding.
16. Child's Wishes
A child who clearly does not want to be photographed or filmed should not normally be forced to participate merely because an adult has agreed.
17. Identifying Children
Public content involving children should avoid unnecessarily publishing information that could identify or locate them.
Particular caution should be exercised with combinations of:
- full name;
- exact home address;
- school;
- precise GPS location;
- personal history;
- identifiable photograph.
18. Children in Groups
The fact that several children appear together does not remove safeguarding responsibilities.
Group photographs should still consider:
- permission;
- context;
- location;
- dignity;
- foreseeable risks.
19. Adults at Risk
Additional care is required when recording adults who may be at risk.
The charity should consider whether the person:
- understands the proposed use;
- can make an informed decision;
- is experiencing pressure;
- may face harm from publication;
- has communication or support needs.
20. Capacity
Capacity should not be assumed absent merely because a person:
- has a disability;
- is elderly;
- receives charitable assistance;
- has communication difficulties.
Where there is a genuine concern about decision-making capacity, appropriate safeguarding and legal considerations should be applied.
21. Sensitive Circumstances
Enhanced caution should be used for people affected by:
- domestic abuse;
- trafficking;
- persecution;
- displacement;
- conflict;
- serious illness;
- safeguarding concerns;
- homelessness;
- extreme financial hardship.
Identifiable publication may create risks beyond ordinary privacy concerns.
22. Emergency and Disaster Settings
Emergency situations can create particularly unequal power relationships.
A person's distress must not be treated as automatic permission to record or publish them.
Where immediate formal consent processes are impracticable, the charity should minimise identification and reassess content before publication.
23. Distribution Photography
Photographs and videos may be taken during distributions for:
- project evidence;
- monitoring;
- donor reporting;
- public communications.
Distribution should not be unnecessarily delayed or disrupted to create photographs.
24. Staged Photographs
Reasonable positioning for documentation is permissible.
However, the charity must not stage an event in a way that materially misrepresents what occurred.
For example, a package may reasonably be held for a photograph after distribution, but an event must not be fabricated and represented as genuine charitable delivery.
25. Repeated Handovers
Aid should not be repeatedly handed between people merely to manufacture the appearance of additional beneficiaries or distributions.
Project evidence must represent genuine activity.
26. Project Evidence
Media used as project evidence should be capable of being associated with the correct project where reasonably practicable.
Relevant records may include:
- project number;
- date;
- location;
- project type;
- photographer or source;
- related invoice or completion record.
27. Water Project Documentation
Completed Al-Waris Foundation water installations should normally have appropriate visual evidence.
This may include:
- completed installation;
- Al-Waris Foundation plaque;
- surrounding site;
- operation of the pump or water source;
- relevant construction stages where useful.
Where beneficiaries appear, this policy continues to apply.
28. Water Project Location
Internal project records may contain precise location or GPS information.
Precise coordinates should not automatically be published publicly where doing so could create:
- privacy risks;
- safeguarding risks;
- security concerns;
- risk to a household or individual.
29. Food Distribution Documentation
Food-distribution evidence may include:
- supplies before distribution;
- package preparation;
- transport;
- distribution activity;
- volunteers;
- appropriate beneficiary images.
Evidence should demonstrate genuine delivery without requiring every recipient to be identifiable.
30. Before-and-After Content
Before-and-after content must not exaggerate or fabricate outcomes.
The charity should ensure that:
- both images relate to the relevant activity;
- descriptions are accurate;
- changes are not misleadingly attributed to the charity.
31. Testimonials
Recorded beneficiary testimonials should be:
- genuine;
- voluntary;
- accurately represented;
- appropriately consented.
Beneficiaries should not be instructed to make false claims about assistance received.
32. Translation
Where a beneficiary speaks another language, translations or subtitles should preserve the substance of what they said.
Materially changing a statement to make the charity appear more successful is prohibited.
33. Editing
Reasonable editing may include:
- cropping;
- exposure correction;
- colour correction;
- audio cleanup;
- subtitles;
- privacy blurring;
- removing irrelevant footage.
Editing must not materially falsify the documented event.
34. Privacy Editing
Where appropriate, identifiable features may be:
- blurred;
- cropped;
- obscured;
- removed from the published frame.
This may allow useful documentation while protecting the individual.
35. Metadata
Photographs and videos may contain metadata including location information.
Before public release of sensitive content, the charity should consider whether metadata could reveal information that should remain confidential.
36. Names
The charity should not automatically publish a beneficiary's full name merely because their image is being used.
Where a name adds little value, alternatives may include:
- first name only;
- pseudonym;
- general description;
- no name.
Any pseudonym should not be presented as a verified real name.
37. Personal Stories
A photograph combined with a detailed personal story can increase identification risk.
The charity should consider the cumulative effect of information being published.
38. Medical Information
Images or stories revealing health information require particular care.
Medical details should not be disclosed merely because they may increase fundraising engagement.
39. Documents in Images
Photographs and videos should be checked for visible confidential information such as:
- identity documents;
- addresses;
- telephone numbers;
- beneficiary lists;
- bank information;
- medical records.
Such information should be removed or obscured before publication where necessary.
40. Vehicle Registration and Location Information
Content should be reviewed for incidental identifiers where they create meaningful privacy or security risks.
Examples may include:
- vehicle registrations;
- house numbers;
- precise addresses;
- location boards.
41. Social Media
Content published on social media may:
- spread rapidly;
- be copied;
- be downloaded;
- be reposted;
- remain available outside the charity's control.
This should be considered when deciding whether particular beneficiary media is appropriate for publication.
42. Website Publication
Media published on the Al-Waris Foundation website should use approved content-management processes.
Where appropriate, media should include sufficient context to avoid misleading visitors about:
- project;
- location;
- date;
- status.
43. Donor Updates
Donors may receive project photographs or videos where appropriate.
Donor-only distribution does not remove privacy and safeguarding obligations.
Sensitive beneficiary information should not be disclosed merely because a donor funded a project.
44. Donor Recognition
Where donor names or dedications appear on project plaques or related media, the charity should ensure the wording is appropriate.
Beneficiary information should not be unnecessarily combined with donor information.
45. Fundraising
Real project media may be used for fundraising where:
- use is appropriate;
- context remains truthful;
- consent or another appropriate basis exists;
- safeguarding concerns have been considered.
46. Reusing Media
Media originally created for one purpose should not automatically be reused indefinitely for unrelated purposes.
Before materially different reuse, the charity should consider:
- original expectations;
- consent;
- age of content;
- sensitivity;
- context.
47. Reusing Project Images
A photograph from one project may be used to illustrate a broader area of the charity's work where this would not mislead a reasonable viewer.
It must not be falsely described as evidence of another specific project.
48. Stock Photography
Stock photography may be used for general illustrative purposes where appropriate.
It should not be represented as:
- an actual Al-Waris Foundation beneficiary;
- evidence of a completed project;
- an actual Al-Waris Foundation distribution;
unless that is genuinely the case.
49. AI-Generated Imagery
Al-Waris Foundation may use AI-generated illustrations for purposes such as:
- social-media design;
- educational content;
- conceptual imagery;
- general campaign graphics;
- visual storytelling.
AI-generated imagery must not be presented as genuine documentary evidence.
50. AI Images and Beneficiaries
A fictional AI-generated person must not be described as an actual beneficiary.
Where there is a realistic possibility of confusion, appropriate context should make clear that the image is illustrative.
51. AI Project Evidence
AI-generated images must never be used to fabricate:
- completed water installations;
- aid distributions;
- beneficiaries;
- project locations;
- construction;
- disaster-response delivery;
- other evidence of charitable activity.
52. Image Manipulation
AI or conventional editing must not be used to materially alter genuine project evidence in a misleading way.
Prohibited examples include:
- adding beneficiaries who were not present;
- increasing the apparent number of aid packages;
- inserting charity branding onto a project after the fact and claiming it physically existed;
- changing the location to imply work occurred elsewhere.
53. Branding
Al-Waris Foundation may add legitimate branding to media, including:
- logo;
- project number;
- captions;
- watermark;
- campaign information.
Digital branding should not be presented as a physical project plaque if no such plaque existed.
54. Photographers and Videographers
External photographers or videographers should receive appropriate instructions concerning:
- safeguarding;
- consent;
- dignity;
- confidentiality;
- permitted use;
- ownership;
- storage;
- delivery of files.
55. Contractors and Partners
Where contractors or partner organisations collect project evidence, Al-Waris Foundation should communicate its expected evidence and safeguarding standards.
Receiving images from a contractor does not automatically mean every image is suitable for public publication.
56. Volunteer Photography
Volunteers should only photograph beneficiaries where this forms part of authorised charity activity.
They should not use access obtained through the charity to create inappropriate personal content.
57. Personal Social Media
Volunteers and representatives must not assume that photographs taken during charity activity may be published on their personal accounts.
Beneficiary content should normally be published through authorised charity channels unless specific permission exists.
58. Personal Devices
Authorised photography may be undertaken using personal devices where necessary.
Where personal devices are used:
- files should be protected;
- sensitive media should not remain unnecessarily on the device;
- automatic cloud sharing should be considered;
- files should be transferred to appropriate charity storage where required.
59. Live Streaming
Live streaming involving beneficiaries creates increased risk because content cannot be fully reviewed before publication.
Live streaming should therefore receive appropriate prior consideration.
It should be avoided in sensitive beneficiary situations unless risks are adequately controlled.
60. Interviews
Before a recorded interview, the person should reasonably understand:
- that recording is occurring;
- who is recording;
- intended use;
- whether publication is expected.
Surprise recording of vulnerable beneficiaries should be avoided.
61. Hidden Recording
Covert recording should not be used for ordinary charity publicity or donor content.
Exceptional use would require a compelling lawful reason and appropriate assessment.
62. Public Events
At public charity events, photography may reasonably be expected in some circumstances.
Where practical, attendees should be informed that photography or filming may occur.
People requesting not to be featured should be accommodated where reasonably possible.
63. Crowd Images
Wide crowd photographs where individuals are incidental may present lower privacy risk than close identifiable portraits.
However, context still matters, particularly at:
- sensitive events;
- beneficiary distributions;
- safeguarding activities.
64. Private Locations
Photography inside:
- homes;
- shelters;
- medical environments;
- private accommodation;
- sensitive community locations;
requires additional consideration.
Permission to enter a location does not automatically constitute permission to publish images taken there.
65. Places of Worship
Photography in places of worship should respect:
- local rules;
- religious practices;
- privacy;
- dignity.
66. Cultural Sensitivity
Local cultural expectations concerning photography should be respected where compatible with safeguarding, law and the charity's principles.
What is acceptable in one location may be inappropriate in another.
67. Conflict and Persecution
Media must not be published where identification could reasonably expose a person to:
- retaliation;
- persecution;
- violence;
- discrimination;
- exploitation.
Anonymisation should be considered.
68. Humanitarian Neutrality and Security
In sensitive humanitarian environments, photographs should avoid unnecessarily revealing information that could:
- endanger beneficiaries;
- expose aid routes;
- identify vulnerable locations;
- compromise staff or volunteers.
69. Refusal During Filming
If someone objects while filming is taking place, the photographer should respond respectfully.
Where reasonably possible, filming should:
- stop;
- move away;
- exclude the person;
- use a different composition.
70. Withdrawal of Consent
Where the charity relies on consent, an individual may withdraw that consent.
Al-Waris Foundation should make reasonable efforts to stop future use where withdrawal applies.
71. Limits of Withdrawal
Once media has been publicly:
- distributed;
- downloaded;
- reposted;
- printed;
- shared by third parties;
complete retrieval may be impossible.
The charity should explain this honestly where relevant.
Withdrawal should still be applied to future uses under the charity's control where required.
72. Deletion Requests
Requests to remove photographs or videos should be assessed according to:
- applicable data-protection rights;
- lawful basis;
- safeguarding;
- legal obligations;
- legitimate record-keeping requirements;
- technical feasibility.
A request should not automatically be rejected merely because content was previously published.
73. Internal Evidence
Removal from public channels does not necessarily require destruction of every internal project record.
The charity may have legitimate reasons to retain restricted evidence for:
- financial accountability;
- fraud prevention;
- regulatory requirements;
- legal claims;
- project verification.
The applicable lawful basis and retention requirements should be considered.
74. Media Library
Approved media should, where practicable, be managed through a central charity media library or other controlled storage.
Records may include:
- file;
- project;
- date;
- source;
- publication status;
- consent information;
- restrictions.
75. Access Control
Access to unpublished or sensitive beneficiary media should be restricted according to legitimate operational need.
Not every CMS or administrative user requires access to all media.
76. Original Files
Original project files may be retained where they have legitimate evidential value.
Publicly optimised copies may be separate from originals.
77. File Security
Media containing sensitive personal information should not be stored indefinitely in:
- public folders;
- unsecured messaging applications;
- unrestricted shared links.
78. Messaging Applications
Messaging services may be used to receive project media where operationally necessary.
Important media should be transferred into appropriate charity records rather than relying indefinitely on message history as the sole record.
79. Media Retention
Media should be retained only for as long as reasonably necessary for its legitimate purpose.
Retention should reflect:
- project evidence requirements;
- safeguarding;
- consent;
- fundraising use;
- historical value;
- legal obligations.
See the Records Retention and Disposal Policy.
80. Disposal
Media no longer required should be securely deleted or otherwise disposed of appropriately according to its sensitivity.
Copies should be considered where reasonably practicable.
81. Copyright
The charity should have appropriate rights to use media it publishes.
This may arise through:
- creation by the charity;
- assignment;
- licence;
- permission;
- appropriately licensed stock media.
An image being available online does not automatically mean it is free to use.
82. Photographer Rights
Where external photographers are used, agreements should clarify appropriate rights concerning:
- charity use;
- editing;
- publication;
- archiving;
- third-party use.
83. Beneficiary Consent and Copyright
A beneficiary consenting to appear in an image does not necessarily own copyright in the photograph.
Similarly, copyright ownership does not remove the need to consider privacy, safeguarding and data protection.
84. News and Media Organisations
Requests from journalists or media organisations to photograph beneficiaries should be appropriately managed.
The charity should not provide unrestricted access to vulnerable beneficiaries merely because media coverage may benefit fundraising.
85. Sharing Media With Third Parties
Before providing identifiable beneficiary media to another organisation, consideration should be given to:
- purpose;
- permission;
- safeguarding;
- data protection;
- further publication;
- control over reuse.
86. Public Downloads
Where beneficiary media is publicly downloadable, the charity may have limited control over subsequent third-party use.
This increased risk should be considered before publication.
87. Facial Recognition and Biometric Processing
Ordinary photographs should not automatically be subjected to facial-recognition or biometric identification technologies.
Any proposed biometric processing requires specific legal and privacy assessment before implementation.
88. Geolocation
Exact geolocation should not be attached publicly to beneficiary media unless there is a legitimate reason and the associated risks have been considered.
Project-level location information may often be communicated without identifying a specific household.
89. Content Review
Sensitive media should be reviewed before publication.
Review should consider:
- accuracy;
- dignity;
- safeguarding;
- consent;
- privacy;
- visible personal information;
- location;
- caption;
- project attribution.
90. Publication Approval
The level of publication approval should reflect risk.
Routine low-risk project images may follow normal CMS workflows.
Higher-risk media involving:
- identifiable children;
- safeguarding;
- sensitive personal stories;
- emergencies;
- serious medical circumstances;
should receive enhanced review.
91. Captions
Captions should be accurate.
They must not knowingly misstate:
- location;
- project;
- date;
- beneficiary circumstances;
- assistance provided;
- outcome.
92. Fundraising Headlines
Emotionally compelling fundraising language may be used where truthful.
Headlines must not deliberately misrepresent the person shown or their circumstances.
93. No Fabricated Quotes
A quote attributed to a beneficiary must not be invented.
Where wording has been translated or lightly edited for clarity, the meaning must remain faithful to what the person communicated.
94. Safeguarding Disclosures During Filming
If a beneficiary makes a safeguarding disclosure during an interview or recording, safeguarding procedures take priority over content production.
The disclosure should not be published merely because it was captured on camera.
95. Distress During Recording
Recording should stop or be reconsidered where a participant becomes materially distressed.
A person's emotional reaction should not be exploited to create stronger fundraising content.
96. Death and Bereavement
Images or stories concerning deceased people or recently bereaved families require particular sensitivity.
The charity should consider:
- dignity;
- family wishes;
- cultural expectations;
- necessity;
- potential harm.
97. Graphic Content
Graphic images of:
- serious injury;
- death;
- severe medical conditions;
should not normally be used for ordinary fundraising.
Exceptional publication requires compelling justification and enhanced review.
98. Complaints
Complaints concerning photography, video or publication should be handled under the Complaints Policy.
Where appropriate, disputed content may be temporarily removed while the matter is assessed.
99. Data Breaches
Loss, unauthorised disclosure or publication of sensitive beneficiary media may constitute a personal-data breach.
Such incidents should be handled under:
- the Data Protection and UK GDPR Policy;
- the Information Security and Cybersecurity Policy.
100. Serious Incidents
A serious media-related safeguarding or privacy failure may require consideration under the Serious Incident Reporting Policy.
101. Reporting Concerns
Anyone concerned about inappropriate photography or media use should report the matter promptly.
Concerns may include:
- lack of consent;
- exploitation;
- unsafe publication;
- fabricated evidence;
- inappropriate volunteer behaviour;
- disclosure of sensitive information.
102. Policy Breaches
Breaches may result in:
- removal of content;
- restriction of media access;
- deletion of inappropriate copies;
- volunteer management action;
- withdrawal of photography authority;
- contractual action;
- governance action;
- safeguarding investigation;
- data-breach assessment;
- regulatory reporting where required.
103. Training
People regularly collecting beneficiary media should receive proportionate guidance concerning:
- dignity;
- safeguarding;
- consent;
- privacy;
- accurate documentation;
- secure handling.
104. Project Briefing
Where contractors or overseas representatives are asked to provide media evidence, the project brief should explain relevant requirements.
This may include:
- required photographs;
- project identifiers;
- prohibited sensitive content;
- beneficiary consent expectations;
- file transfer method.
105. Monitoring
The charity should periodically review its published and stored media to identify:
- outdated content;
- inappropriate identification;
- consent restrictions;
- inaccurate captions;
- safeguarding risks;
- unnecessary retained files.
106. Related Al-Waris Foundation Policies
This policy should be read alongside:
- Constitution;
- Safeguarding Children Policy;
- Safeguarding Adults at Risk Policy;
- Data Protection and UK GDPR Policy;
- Confidentiality Policy;
- Information Security and Cybersecurity Policy;
- Fundraising Policy;
- Social Media and Digital Communications Policy;
- Overseas Operations and Partner Due Diligence Policy;
- Volunteer Policy;
- Complaints Policy;
- Serious Incident Reporting Policy;
- Records Retention and Disposal Policy.
107. Review
This policy will be reviewed:
- at least annually;
- following a significant safeguarding concern involving media;
- following a significant privacy or data-protection incident;
- following material changes to the charity's media practices;
- following major changes in technology or AI use;
- where existing controls are found to be inadequate;
- following relevant legal or regulatory developments.
108. Approval
Version: 2.0 Status: Approved Approved by: Board of Trustees Approval date: 25/08/2026 Next scheduled review: 24/08/2027
