The Information Commissioners Office has a helpful Good Practice Guidance Note at http://www.ico.gov.uk/upload/documents/library/data_protection/practical_application/taking_photos.pdf (version 4, June 2010). The Note distinguishes photographs taken:
- for personal use (e.g. by relatives and friends) to which the Data Protection Act does not apply
- for institutional use by the school (or by extension BCS) where the advice is that this will be personal data but will not breach the Act as long as the children and/or their guardians are aware this is happening and the context in which the photo will be used.
- by the media in which case as long as the school ( or BCS) has agreed to this, and the children and/or their guardians are aware that photographs of those attending may appear in the media, this will not breach the Act.
The Note repeatedly uses the term “the children and/or their guardians are aware” without any implication that written permission is required or even advisable. Advance notices of the event should advise attendees that photos may be taken by BCS and/ or media (as appropriate).