Filming and Photography Protocol

1. Purpose of Filming and Photography

The University of Staffordshire records, livestreams, films (including aerial filming with drones) and photographs graduation ceremonies to:

• Provide graduates and their families with a commemorative record of the event.
• Promote our institution through public sharing of the ceremonies and produce daily highlights videos.
• Enable remote viewing via YouTube and other media appropriate for those unable to attend in person.
• Footage may include wide shots of the audience, graduates receiving awards, University campus and general event coverage.

2. Lawful Basis for Filming (UK GDPR)

Data protection legislation controls how personal information is used by organisations, including universities. In the UK, data protection is governed by the UK General Data Protection Regulation and the Data Protection Act 2018 (UK GDPR). In relation to the purpose of filming and photography activities as set out in Section 1 above the University relies upon the lawful basis of Legitimate Interests under Article 6(1)(f) of the UK GDPR. Legitimate interests means that the University needs to process personal information to fulfil the University objectives and we believe this will not adversely affect other parties. The University interests include:

• Documenting and celebrating achievements.
• Sharing the ceremony with families, friends and the public.
• Archiving content for future institutional reference.

These interests do not override the fundamental rights of attendees, and the University will take steps to minimise unnecessary data collection.

3. Notice and Transparency

The University informs attendees through the following routes:

• A clear statement on the graduation website.
• A clear statement in pre-event communication.
• On-site digital and printed signage in all buildings used for the event.
• Signage and notices state that filming and photography are in progress, and attendees may be visible in the live stream and archived footage.

If any attendee consents to a captioned photo or interview, the University will inform them of how this will be used, and document the terms of agreed use to ensure compliance if subsequently used. If someone does not wish to be filmed or photographed, they can email comms@staffs.ac.uk or identify themselves to the photographer/filming crew on the day.

4. Children and Vulnerable Individuals

Footage is focused on the stage and public areas with occasional shots of audience reactions. The University avoids filming individual close-ups, unless part of the ceremony. For the filming for the daily highlights and photography, where individuals are under the age of 16 and footage is to be used, consent will be sought from parent/guardian or carer.  

Where possible camera operators are instructed to avoid filming individuals who object. If a parent/guardian or carer requests exclusion of an image, the University will seek to accommodate this request. This must be identified with the film crew prior to the commencement of the event.

5. Data Access, Storage, and Retention

Graduation ceremonies are live streamed via YouTube, set to public visibility. Archived copies are stored securely on SharePoint. Access is limited to relevant staff (currently the members within the Broadcast, Content, Comms and Events Teams). The retention period is 10 years, unless there is a valid reason to retain these for longer.

6. Requests and Objections

Attendees can contact the University before, during, or after the event regarding concerns about being filmed, requests to avoid capturing themselves or dependents. Takedown or redaction requests will be assessed on a case-by-case basis. 

7. Review and Oversight

This protocol is reviewed annually or when a change in filming process occurs.