Photos at the company party: consent, privacy and what organisers should settle beforehand

Why this is a topic at all

Photos in which people are recognisable are personal data under the GDPR. In an employment relationship there is the added fact that employees are in a position of dependence – consent therefore has to be particularly voluntary, and nobody may suffer a disadvantage for not wanting to be photographed. That sounds like a lot of bureaucracy, but in practice a few clear rules solve it.

Before the party: five things to settle

These points belong in the preparation, ideally agreed with the data protection officer and, where there is one, the works council:

• Purpose: what are the photos for – a memory for the team, the intranet, the newsletter, social media? Every purpose beyond that needs its own consent.
• Voluntariness: whoever does not want to be photographed must be able to say so without giving a reason. A note in the invitation and a visible sign (for example a coloured name badge) have proven useful.
• Storage and access: where are the pictures kept, who can see them, who may download them? A shared messenger chat is not a good answer to that.
• Deletion deadline: when are the photos deleted? A fixed date is easier to explain than “at some point”.
• Contact person: whom does someone turn to who wants a photo of themselves removed?

Consent in practice

For the purpose “a memory for the participants”, a clear note in the invitation that answers the five points above, plus the option to object to being photographed, is enough in many organisations. For publications – intranet, website, social media – you are better off obtaining explicit consent from the people shown, ideally per photo.

A shared album helps twice over: whoever uploads a photo confirms before the first upload that the people shown agree. And the organising team sees all photos in one place, can hide individual ones and ask for consent specifically before anything is published.

Storage: what you should know about the provider

Whichever tool you use, you should be able to answer these questions:

• Where are the servers? For European organisations, a location in the EU is the simplest case.
• Are the photos used for advertising, for training AI models or for face recognition? The answer should be a clear no.
• Who can see the pictures – only the organising team or all participants? Can that be configured?
• How are photos deleted, and is there a recycle bin in which they live on?
• Is there a data processing agreement if your organisation needs one?

With Festatelier, photos, videos and album data are stored with Google Cloud in Frankfurt am Main. There are no ads, no data sales and no face recognition; deleted files are removed from the server immediately. Whether participants see each other’s photos is set by the organising team, and every picture can be hidden individually. The details are in the privacy policy (in German) – send it to your data protection officer before you set up the album.

On the day of the party

Put out the table cards with the QR code and announce once where the photos go and who sees them. Appoint one person from the organising team to keep an eye on the album during the party and hide what does not belong on the screen or the intranet. If you show a live slideshow: it only shows what is not hidden, and pictures that someone reports disappear immediately.

After the party

Review the photos, mark a selection for the intranet and obtain consent from the people shown for those pictures. Download the memory for the team as a ZIP and store it where your retention policy says. Then: delete on the announced date – the album too. With Festatelier the album expires after the plan’s retention anyway and is deleted; before that it reminds you to download everything.