Photos and privacy in childcare: consent and sharing choices

Decide about images of your child separately for each purpose and channel: a restricted parent app, a public website and an advertisement are different choices. Ask who can see the images, how they are used and how to change your choice. Read the accompanying explanation, not only the checkbox. You do not have to treat every form of use as one practical decision.

Start with an overview of image use

Ask what images the provider makes and where they appear. Consider an activity photo, a group photo, a video in the parent app or material for a website. For each, record the audience and purpose. 'For communication' gives you less to work with than 'visible only to parents in this group'. Ask for an explanation if the description remains too broad.

The Dutch data protection authority, the AP, explains that identifiable images can be personal data and an organisation needs a GDPR legal basis for using them. Consent is one legal basis. Do not assume every image is covered by the same contract provision. Ask how the organisation supports the particular use.

Make your preferences specific. You may welcome photos in the parent app while declining identifiable images on social media. Or you may want to understand which parents see a group photo before deciding. Write down your questions before completing the form. Keep the explanation you read together with confirmation of your choice.

Check consent when it is the legal basis

The AP says consent must be freely given, unambiguous, informed and specific. Withdrawal must be as easy as giving consent. Ask what a choice means in practice and where to change it later. If one question covers several purposes, ask how you can make separate choices.

You can discuss a form you do not understand with the provider. For example, ask whether 'publication' includes advertisements or only a newsletter for parents. Have explanations recorded when they determine your decision. Avoid relying on a spoken answer that does not appear in the confirmation; it should remain clear which use you actually discussed.

Questions for a parent app

• Do I see images only of my child, of the group or of the whole location?
• Who receives an account, and what happens to access when care ends?
• Can users save or forward images, and what arrangements apply?
• Who handles a question about an incorrectly posted image?
• How are images and account access managed when a staff member leaves?
• Where can I find the privacy statement and the organisation's contact person?

A login tells you something about access but does not answer every question about further sharing. Discuss parent expectations too. Use your own account carefully, keep login details private and log out of shared devices. Do not hand over a whole parent-app account to someone who only needs to collect once; ask the provider for an appropriate way to communicate that arrangement.

Assess public websites and social media separately

Public use has a different audience from a restricted parent environment. Check what accompanies the image: name, location, group or a recognisable daily routine. Ask whether a less identifiable alternative is possible, such as a picture of a child's artwork. This is a practical discussion suggestion; the provider decides how to organise its communication.

Ask what happens with reuse. An image for one update might later appear in a brochure or campaign. If the original request does not make this clear, ask before agreeing. Discuss how long material is used too. A specific choice is easier to follow than a general promise that images are treated 'carefully'.

Changing your consent

Use the channel the organisation identifies and describe the choice you are changing. Name the parent app, public website or social media without sending unnecessary additional personal information. Ask for confirmation and discuss how the change reaches the group. Staff making images need a workable way to follow your current preference.

The AP provides a sample letter for withdrawing consent to images of a child. Use it as a tool, identifying the images and locations involved. A reply date you select in a message is not a universal statutory deadline. Explain whether you want to change future use only or also raise existing published material.

A practical example involving two channels

Imagine you welcome images in the parent app at registration, but later find a photo of your child on the public website. This is an invented example. First check the saved consent and explanation. Then ask which purpose and channel the provider understood were permitted. Identify the particular page and explain your requested outcome, such as a review of the use or removal.

Do not circulate the image in a large parent group to prove your point. Keep the page address and date for yourself and send the details directly to the responsible contact. This keeps the request focused and avoids expanding the image's audience yourself. Ask how the organisation will prevent a similar mistake in future.

Do not casually republish other children's images

An image received in your app may show other children. Receiving it does not mean you should publish it without discussion. Check the arrangements first and, when unsure, use an image showing only your own child's artwork or belongings. The AP distinguishes personal use within a limited circle from wider publication; these are different situations.

Explain the arrangement to relatives who like sharing memories too. Before a party or performance, ask what the location expects from visitors. Point your own camera at the event without unnecessarily making other families identifiable. Discuss sharing a group image before posting it on a public channel.

When a request remains unresolved

Ask who is responsible for privacy questions and what follow-up is possible. Keep your message short: the image's location, what you checked, your request and the response received. Use the complaints procedure supplied by your provider if the matter remains unresolved. For privacy rights and next steps, consult the AP's current information.

When comparing childcare, include privacy in the conversation. During a tour, ask how image choices are recorded and followed. A clear working procedure is easier to assess than an attractive parent-app demonstration alone. Keep the answers with your other care arrangements.

Sources and review

Sources checked on 11 October 2026. The questions, channel overview and example are editorial tools for discussing the provider's procedure. The applicable GDPR basis and specific rights depend on the use. The sources below are in Dutch.

• Autoriteit Persoonsgegevens: images
• Autoriteit Persoonsgegevens: consent as a legal basis
• Autoriteit Persoonsgegevens: withdrawing consent to a child's images