Photography Policy

The Echo Newspaper Photography Policy

Who we are:

Kennedy Echo Publishing Ltd T/A The Echo Newspaper and echo.ie are a local Newspaper. When we say The Echo, echo.ie, us, our or we, we are referring to Kennedy Echo Publishing Ltd. Our registered office is based in Tallaght Enterprise Centre, Main Road, Tallaght, Dublin 24.

Why we take photographs

The Echo is a weekly local newspaper, we take photographs to accompany news stories, at events we are invited to attend and at public events that we are either invited to or attend for public/our readers interest.
These photographs are printed in The Echo newspaper and/or published on echo.ie or Echo social media platforms.
The Photographs we take, published or not, are for sale to the public, this is advertised on all picture pages printed in The Echo and on page 2 of all editions.
The legal basis for our processing is based on article 6.1 (F) and article 85.2 GDRP. This provides where processing is necessary for the purposes of legitimate interests and journalistic purposes except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
When a Photo job is booked

When a job is booked the Echo Photography Policy or the link to the policy published on echo.ie must be emailed to the person/organisation booking the job with confirmation that we can or cannot attend. The staff member who takes the booking must ensure the policy has been emailed and acknowledged.

Taking photos of Minors/Children

Where any images are taken of children, it is our policy to protect the fundamental rights and freedoms of every child. If we attend a public event and an image is taken of a child, who is not the focus of the image e.g. in the crowd, it is not always possible to obtain parental consent. However, if we take a photograph where a child is the main focus of the image, we will ensure clear parental or guardian consent is obtained.
For School/Club events – where we are invited to attend any underage / school / club events, it is our policy to impose a pre-condition on all organisations to ensure they have the written consent of each parent for the child’s images to be taken. In some cases, we are considered to be a data processor.

Taking photos in a private/public place ie; shopping centre, pub, private party etc.

We are often engaged by entities to take photographs to promote their brand or product. The legal basis for our processing is to comply with our contractual obligations with this third party. As part of our contractual arrangement we impose a pre-condition to state that the third party who has commissioned us has obtained clear written consent from the data subject (individual) involved.
Where photographs are being taken at an event attended by large crowds, it is not possible to obtain the consent of all attendees. However, we promote and encourage all organisations to have clear signs around the venue indicating that publicity photos are being taken.
In the case of private parties such as Birthday parties, wedding anniversaries etc. we impose a pre-condition to state that the third party who booked the photographer has obtained clear written consent from the data subject/s involved.
The photography policy must be emailed to the owner/manager of the establishment or person who booked the photographer for a private party, when the job is booked or before we go to take the photographs.
The staff member who takes the booking must ensure the policy has been emailed and acknowledged.

Taking photos in a public place ie; Tallafest, St Patrick’s Day parade etc.

Where possible the Echo Photography policy must be emailed to the event organiser.
Where photographs are being taken at an event attended by large crowds, it is not possible to obtain the consent of all attendees. However, we promote and encourage all organisations to have clear signs around the venue indicating that publicity photos are being taken.
If a member of the public asks to see the Echo Photography Policy, the Echo photographer will have a copy or they can email dp@echo.ie to get a copy.

Photo’s not taken by Echo photographers

Photos that are sent in from a third party – we impose a pre-condition to state that the third party who has commissioned us has obtained clear written consent from the data subject (individual) involved. In some cases, we are considered to be a data processor as the image is taken under direction of another.
The third party must also get The Echo Photography policy emailed to them.
Agency photos – We expect these third parties to have the same levels of data protection that we have and that they have obtained consent from the data subject involved.

Deleting Photographs

Photographs that we take for journalistic purposes as outlined in Article 85.2 GDPR will not be automatically deleted on request and will be subject to an investigation before a decision is made.
If any parent or guardian requests an image of a minor to be deleted and not published or sold, we will do so without question.
If we take a photo of an individual, in a private/public place, who wishes to have the image deleted and not published or sold, we will immediately remove the material from our files and/or website and destroy the image.
If we take a photo of a sporting individual or team member of a sports club, at a sporting event/match for journalistic purposes Article 85.2 GDPR, we will not automatically delete the image on request as we expect these data subjects have signed media consent forms with their club and/or sporting body, i.e. GAA or FAI.
Selling/Sharing Photos with third parties

As well as transferring images to third parties as set out above, we also share information with core services providers required for this part of our business to function. This may include companies who we engage to provide IT support, make deliveries, print materials or the oragnisation/person who booked a photography job.
We expect these third parties to have the same levels of data protection that we have.
How long we keep Photographs

For journalistic archiving and selling purposes we file all photographs taken by Echo photographers indefinitely, unless they have been deleted as per the conditions outlined above.

Your rights relating to photographs we take of you

You have rights under the GDPR, in certain circumstances and subject to certain exemptions in relation to your personal data.
For further information on these rights or to make a complaint you can email any queries to dp@echo.ie. Please be assured that all requests and / or complaints received will be fully investigated and acted on without any delay.
Note: This policy will be reviewed and updated as required and is available to view on echo.ie or can be emailed on request.

Echo Data Compliance Officer; Peter Kennedy PH: 01-4685350 email: dp@echo.ie