Sharing Images of Children: Reflecting, Reviewing, Rethinking Policies and Practices

For Parents & Caregivers, Early Childhood Education and Care Services, Family Day Care, Schools, Sporting Clubs and Child-Serving Organisations

Images of children painting, reading, performing, playing sport, celebrating or graduating are routinely shared in newsletters, on websites and across social media. Twenty years ago, a school newsletter was printed on paper and tucked into a school bag. Today, a single photograph can be uploaded to social media, copied, downloaded, screenshot, altered using artificial intelligence or shared with thousands of people within seconds.

Once an image is online services, schools, clubs, organisations, families and children lose control over where it travels and how it may be used. This isn't about assuming the worst, it's about recognising that technology has changed dramatically, while many of our policies and practices haven't.

Even when a photograph seems harmless, it may unintentionally disclose information about a child. While each piece of information may appear insignificant on its own, together they can build a surprisingly detailed picture. In an age where information is easily collected, copied and connected these details deserve greater consideration.

As our understanding of online safety and child protection evolves, it's time to ask an important question, Do our current image sharing practices still reflect what we know about keeping children safe? When it comes to children's safety, reviewing long-standing practices and policies in light of new evidence isn't overreacting, it's responsible child safeguarding.

Children's Images: You Own It, But Do You Control It?

When words, photos or videos are posted on social media, the owner generally retains copyright (ownership), but by uploading them you agree to the platform's Terms of Service. This usually grants the platform a broad licence to host, copy, distribute, modify, display and sometimes use your content for purposes such as operating, improving and promoting the service.

The most important takeaway isn't just ownership, it's control. Even if you legally own the content, once it's online it can be:

• copied or downloaded

• screenshotted

• reshared without your knowledge

• used to train AI (depending on the platform and your settings)

• difficult or impossible to completely remove from the internet

In 2024 Meta announced it would use public Facebook and Instagram content dating back to 2007 to train AI. That included information and images shared about children, including content posted by services, schools, clubs, organisations and parents/caregivers.

This is why it's worth asking yourself before posting a child's photo "Am I comfortable with this image existing online indefinitely and potentially beyond my control?"

Generative AI

The Australian Human Rights Watch reported personal photos of Australian children are being used to create powerful artificial intelligence (AI) tools without the knowledge or consent of children or their families. These photos are scraped off the web into a large data set that companies then use to train their AI tools and this includes photos shared by services, schools, clubs, organisations and parents/caregivers.

Analysis by Human Rights Watch found that a data set used to train popular AI tools and built by scraping most of the internet, contains links to identifiable photos of Australian children. They capture young children blowing bubbles or playing instruments in preschools, children dressed as their favourite characters for Book Week and girls in swimsuits at their school swimming carnival.

Some children’s names are listed in the accompanying caption or the URL where the image is stored. In many cases, their identities are easily traceable, including information on when and where the child was at the time their photo was taken.

One such photo features two boys, ages 3 and 4, grinning from ear to ear as they hold paintbrushes in front of a colourful mural. The accompanying caption reveals both children’s full names and ages, and the name of the preschool they attend in Perth, Western Australia.

Online Child Sex Offender Networks

When most people think about child sexual abuse material, they imagine illegal images that depict the direct sexual abuse of children. While these horrific crimes remain a significant concern, law enforcement agencies around the world have repeatedly highlighted another reality, child sex offenders do not rely solely on explicit images.

Everyday photographs of children, images that most people would consider entirely innocent, can also be collected, categorised, manipulated and shared within child sex offender communities. Images of children swimming, playing sport, dancing, eating, sleeping, wearing school uniforms or simply going about their daily lives may be viewed through a sexualised lens by offenders.

Investigations have uncovered vast collections of publicly available images sourced from social media, school websites and other online platforms. In some cases, offenders digitally alter images using editing software while others curate collections of non-explicit photographs for their own sexual interest or to exchange with like-minded offenders. Artificial intelligence has added another layer of concern. Images can now be altered in ways that were unimaginable only a few years ago.

The overwhelming majority of people viewing a school's Facebook page or newsletter are parents, grandparents and community members. But public platforms do not allow users to choose their audience. Once an image is shared online, it may be downloaded, copied, screenshot, redistributed or manipulated without the knowledge or consent of the services, schools, clubs, organisations, parents/caregivers and children.

This doesn't mean services, schools, clubs, organisations and parents/caregivers should stop celebrating children's achievements or documenting their life. Nor does it mean every publicly shared image will be misused. It does, however, challenge us to consider whether practices developed in a very different digital landscape still represent best practice today.

School Blackmailed by Online Criminals

Recently, a UK school experienced a blackmail attempt after criminals used the schools website or social media accounts to take photos of school children and then using AI tools turned them into child sexual abuse material. The blackmailers sent the images to the school and threatened to publish them online if they did not receive money.

While the intention may have been to celebrate the students, inform families/communities or promote the school, the unintended consequence is that children's digital footprints have been drawn into technologies they never opted in to and can easily be accessed, used and misused by cyber criminals.

St Hilda's Anglican School For Girls in Perth announced from January 2026 they are adopting a new Social Media Strategy that removes identifiable images of students from public social media channels.

Is Bundled Consent Still Fit for Purpose?

Parents and caregivers are asked to sign an image sharing consent form. In many cases a single signature authorises a wide range of uses for their child's image, such as classroom displays, newsletters, school websites, social media, promotional brochures and media coverage. This approach is commonly referred to as 'bundled consent'.

Rather than allowing families to choose which uses they are comfortable with, bundled consent combines multiple purposes into a single decision. Parents are often faced with an "all or nothing" choice, either consent to every proposed use or decline them all.

One unintended consequence of bundled consent is that children whose parents decline permission may be excluded from photographs altogether. These children may be asked to step out of group photos, miss opportunities to be included in celebrations or simply become invisible.

For families, this can feel like an unfair trade-off, choosing to protect their child's privacy can come at the cost of their child's inclusion. While schools are often doing their best to manage consent in practical ways, it raises an important question. Should families have to choose between their child's privacy and their child's participation? A more flexible, granular approach to consent may help reduce this tension, allowing children to be included in school memories and internal communications while respecting a family's decision not to share images publicly.

The Office of the Australian Information Commissioner (OAIC) recognises that bundled consent has the potential to undermine genuinely voluntary consent because it may not provide individuals with meaningful choice. The OAIC recommends that, where practicable and reasonable, organisations should allow people to consent to some collections, uses or disclosures of their personal information while declining others. Consent should also be informed, current, specific and not broader than necessary.

Granular Consent

An alternative approach is granular consent, where parents and caregivers can make separate decisions about different uses of their child's image. For example, families might choose to consent to:

✓ Classroom learning documentation

✓ Printed newsletters distributed within the school community

✓ Yearbooks

✓ Secure parent communication platforms

But decline consent for:

✗ Public websites

✗ Public social media accounts

✗ Marketing and promotional materials

This approach recognises that not all image sharing carries the same level of privacy risk. A photograph shared within a secure parent portal is fundamentally different from one published on a publicly accessible social media platform that can be viewed, downloaded and redistributed worldwide in seconds.

Granular Consent Is Not Without Challenges

For larger services, schools, clubs and organisations granular consent presents genuine administrative and practical challenges.

Managing hundreds or even thousands of individual consent preferences requires robust systems, staff training and clear processes. Educators and volunteers need to know which children can appear in which contexts, and those preferences need to be accurately recorded, easily accessible and regularly updated. There is also the practical reality that this increases the burden on already stretched staff and volunteers.

These challenges should not be dismissed, however convenience should not be the sole factor determining how children's personal information is managed. The question may no longer be whether granular consent is possible, but whether it is becoming an important part of contemporary safeguarding.

Ultimately, the goal is not to make the job harder for schools, services, clubs and organisations, it's to ensure that consent is meaningful, informed and reflects the diverse needs and circumstances of families.

For some children, such as those in out-of-home care, subject to family violence orders or with safety concerns, greater flexibility around image sharing may be more than a matter of preference, it may be a matter safety.

Children's Rights and Privacy

Image sharing isn't simply a communications and posting decision, it is also a children's rights consideration.

Australia is a signatory to the United Nations Convention on the Rights of the Child (UNCRC), which recognises that every child has the right to privacy. Article 16 states that "No child shall be subjected to arbitrary or unlawful interference with his or her privacy ..."

The Convention also recognises that the 'best interests of the child' should be a primary consideration in all actions concerning children (Article 3).

The UNCRC reminds us that the best interests of the child should be a primary consideration in all decisions affecting them. With that in mind, are our image-sharing practices primarily protecting children's rights to privacy, dignity and safety, or are they driven by organisational communication and marketing needs?

The answer isn't always straightforward, but the question is worth considering.

Children's Online Privacy Code

The Office of the Australian Information Commissioner (OAIC) is currently developing Australia's Children's Online Privacy Code, a landmark set of rules that will require many online services, including social media platforms, apps, games and websites likely to be accessed by children, to put children's privacy and best interests at the centre of how they collect, use and disclose personal information.

The Code is currently in draft form and proposes 14 child-specific privacy protections. These include stronger privacy defaults, greater transparency and a proposed 'right to delete', allowing children to request the deletion of their personal information in certain circumstances.

The final Code is due to be registered by December 2026. When it comes into effect, it will represent the most significant reform of children's online privacy protections in Australia since the internet became part of everyday life. It reflects a growing recognition that children deserve greater control over their digital footprint and that services, schools, clubs, organisations and parents/caregivers have a responsibility to prioritise their privacy by design, rather than as an afterthought.

What Could Better Practice Look Like?

Services, schools, clubs, organisations and some parents/caregivers understandably want to celebrate children's achievements. Reviewing image sharing policies doesn't mean banning photographs and videos altogether. Instead you might consider questions such as:

• Do we really need to publish identifiable images publicly?

• Could more content be shared through secure parent portals instead of public social media?

• Can children be photographed from behind or at a distance where appropriate?

• Are names removed from accompanying posts?

• Are we minimising unnecessary disclosure?

• Do staff understand the child protection considerations around digital images?

• Are image policies and practices reviewed regularly as technology changes?

A Final Thought

The question isn't whether services, schools, clubs, organisations and some parents/caregivers should stop sharing images of children. The question is whether current policies and practices still reflect what we now know about digital permanence, artificial intelligence, online child sexual abuse and exploitation, children's rights to privacy and contemporary safeguarding.

This isn't about suggesting educators or organisations are acting inappropriately. Most are following long-established practices with the very best of intentions. Rather, it's an invitation to reflect, review and rethink those policies and practices in light of rapidly evolving technology, changing community expectations and our growing understanding of child safety in digital environments.

Effective safeguarding isn't built on fear or the assumption that every image will be exploited. It is built on recognising foreseeable risks, respecting children's rights and taking reasonable and proportionate steps to reduce opportunities for harm wherever possible.

The strongest child protection practices have always evolved as our understanding of risk has evolved. Image sharing should be no different, because when it comes to protecting children, asking thoughtful questions, reviewing long-standing practices and adapting to new evidence isn't an overreaction, it's responsible safeguarding.

About Kayelene Kerr & eSafeKids

eSafeKids is a social enterprise founded by Kayelene Kerr. Kayelene is recognised as one of Australia’s most experienced specialist providers of Protective Behaviours, Body Safety, Cyber Safety, Digital Wellness and Pornography Literacy education workshops. Kayelene has featured on Australian and international television broadcasts, radio programs and in print media.​

eSafeKids books can support educators teaching protective behaviours and child abuse prevention education that aligns with the Western Australian Curriculum, Australian Curriculum, Early Years Learning Framework (EYLF) and National Quality Framework: National Quality Standards (NQS).