Image rights and GDPR at corporate events: what your company should know
How to inform attendees, handle people who prefer not to be photographed and agree image use with your agency. A practical guide, not legal advice.
By Juanjo Vega Santa-Cruz · Noomadik
When you book photography or video for an event, the images of the people attending are personal data, and your company needs to handle them with care. That does not mean turning every event into a legal problem, but it does mean preparing properly: informing attendees, making it easy for anyone who prefers not to appear to stay out of the photos, and agreeing clearly with the agency how the images will be used.
Important: this guide is practical and for general guidance only. It is not legal advice. Every company and every event is different, so specific decisions should be approved by your data protection officer (DPO) or your legal team.
The general framework, briefly
In Spain, two sets of rules overlap. On one side, the General Data Protection Regulation (GDPR), under which the image of an identifiable person is personal data. On the other, Spain’s Organic Law 1/1982, which protects the right to one’s own image.
In practice, this comes down to three ideas: inform people, respect those who do not want to appear and use the images only for what you have communicated. Which legal basis applies in each case (consent, legitimate interest or another) is a decision for your DPO.
If your company is based outside Spain, your own legal team may also have internal policies that apply. Share them with the agency before the event.
1. Inform people at registration
The best moment to tell attendees is before the event, in the registration form. A short, clear notice can explain:
- That there will be photography and video during the event.
- What the images will be used for: internal communications, website, social media, press, annual report.
- Who is responsible for the data and how to get in touch.
- How someone can say they would rather not appear and how to exercise their rights.
If the event is run by an events agency or another third party, it is worth having your legal team review the wording too, so it is consistent with your privacy policy.
2. Signage at the event
Even if people were informed at registration, it is good practice to remind them on the day:
- Signs at the entrance and at the doors to each room, stating that photos and video are being taken and where to find more information.
- A brief mention at the start of the plenary, if the format allows.
- A point of contact (registration desk or a member of the organising team) for anyone with questions.
3. People who prefer not to appear: lanyards and coloured badges
This is the most practical solution and the one that works best for the photo and video crew. It consists of discreetly identifying anyone who has asked not to appear:
- A different-coloured lanyard or a coloured dot on the badge.
- A sticker on the badge for those who decide on arrival.
For it to work:
- Explain the colour code to the photo and video crew before the event starts.
- Offer the option at the registration desk as well, not only in the online form.
- Accept that some atmosphere shots may include that person in the background. During selection and editing, those images are left out or recropped.
On our side, when a client gives us a code like this, we keep it in mind during coverage and again when selecting the gallery.
4. Cases that need extra care
Children
If there are minors at the event (a family day, an open day, an activity with employees’ children), precautions should be stricter. The usual approach is to obtain authorisation from parents or guardians and to be particularly restrictive about publishing. Check with your DPO how to handle it before the event.
Employees
Working for the company does not mean any use of a person’s image is covered. At an internal convention it is normal to photograph staff, but it is advisable to inform them in the same way as other attendees and offer the same option not to appear. If the photos will be used in external campaigns, such as employer branding or advertising, the prudent approach is to deal with it separately with each person.
Speakers
Speakers are usually the most photographed people at an event. The simplest approach is to include in their speaker agreement or confirmation that their session will be photographed and filmed, and what the images and footage will be used for.
VIP guests, press and clients
Some guests may have their own restrictions (because of their role or their company’s policies). If you know in advance, share it with the crew at the briefing.
5. The usage licence between agency and client
As well as your relationship with attendees, there is another one worth putting in writing: what your company can do with the photos and video the agency delivers. A good agreement should clarify:
| Aspect | What to specify |
|---|---|
| Included uses | Internal communications, website, social media, press, annual report |
| Additional uses | Paid advertising, campaigns, large-format displays |
| Third parties | Whether you can share photos with sponsors, speakers or partners |
| Duration and territory | Whether use is unlimited or restricted |
| Credit | Whether the agency or photographer must be credited |
| Personal data | The role of each party in processing the images |
At most corporate events, the usual communications uses are included. If the photos will be used in paid advertising or shared with sponsors, mention it when you request a quote so it is covered in the licence from the start.
Quick checklist before the event
- Information notice in the registration form, reviewed by your DPO or legal team.
- Signs at the entrance and in each room.
- A system for people who prefer not to appear (lanyard, coloured dot, sticker).
- Colour code explained to the photo and video crew.
- Children: authorisations arranged, if applicable.
- Speakers: image use included in their confirmation.
- Usage licence agreed with the agency, including third parties and advertising.
In short
Informing people properly, offering a simple way not to appear and agreeing uses in writing covers the vast majority of situations. What should never happen is the photo crew arriving on the day without knowing that some attendees did not want to be photographed.
If you are planning the event, our checklist on what to photograph at your company’s annual convention may also help. And if you would like to cover this in the proposal, take a look at our corporate event photography in Barcelona page or get in touch.
