If you work with communication at Aarhus University, there are a number of things you must be aware of in relation to the data protection rules and the regulation (GDPR).
If you publish images of persons, it is important to note that the Danish Data Protection Agency normally considers this to be processing of personal data, and you must therefore comply with the data protection rules.
The Danish Data Protection Agency no longer distinguishes between situational images and portrait images. Furthermore, the Danish Data Protection Agency does not have any specific written rules concerning videos, but in this context you should follow the rules for images.
A. Consent or legal authority?
You must have a basis for publishing an image of people, e.g. consent or legal authority, because the publication constitutes a natural link in the tasks of the university according to legislation.
Carefully assess whether you need consent from the person in the image.
The determining factor behind whether you may use an image without permission is whether the people depicted could feel that they are being exposed or exploited. This must be based on a case-by-case assessment, but if you are in any doubt at all, you should obtain permission from the people depicted in the images before you publish them.
B. Tell people about publication
If you want to publish an image without having obtained consent, you should still make sure that the person(s) in the image are aware that you intend to publish the image on the internet so that they have a chance to let you know what they think, e.g. object to publication.
For example, at conferences and events you can brief people that photos are being taken, and that a number of these photos will be used to report on the event or describe a similar event. You can include your briefing as information in the programme, distribute a flyer, or display information on a large screen or similar. You should insert a link to the AU Privacy Policy (https://international.au.dk/about/profile/privacy-policy/), so that the participants can read about their rights.
C. Correct context
Think carefully about whether the image will be used in the intended context. This also means that the image must not be too old.
When you publish an image depicting people, think carefully about whether the image will be used in the context for which it was intended, and whether you need consent from the person depicted. Here are three examples of images used in an incorrect context.
You should also note that all images on the internet are basically protected by copyright, so you must not download and use images you find there without permission. Read more about copyright with respect to images.
However, there are a number of collections of images that may be used freely, but always read the terms and conditions carefully. Read more.
Portrait images in PURE may be used without consent when they are displayed as part of a PURE plug-in, but if you are to use a picture of a researcher for a news item, for example, you must ask for permission before you may use his or her PURE image.
If the researcher’s portrait image can be found in Cumulus, it may be used without consent.
If you use images and/or videos that depict persons for marketing purposes, you must always have obtained the written consent of the persons concerned.
The consent must state exactly what the images/videos will be used for, when they will be used, and for how long you will keep the material. You may only retain personal data for as long as there is a legitimate purpose (marketing is a legitimate purpose). Read more about storing personal data.
YouTube channel owners control the rights to the content displayed on the site. We encourage you to reach out to them directly if you find a video that you'd like to display and/or reference. When displaying a YouTube video in a broadcast or webcast, please provide both an in-screen and verbal attribution by showing the username or real name of the applicable content owner.
Clicking on a YouTube username will take you to the main page of the user's channel. From there, you can use YouTube's on-site messaging system to contact the channel owner, as long as you are logged in to your own Google account. Simply click on the 'About' tab, then select 'Send Message' and fill out the electronic form.
The same rules apply to the storage of images and videos that depict persons as to other types of personal data. Read about the processing and storage of personal data.
As a user of the Ritzau news agency, it is important that you are aware of how to handle and store personal data, such as journalists’ contact details.
As far as possible, you should avoid exporting personal data from Ritzau. If you have a legitimate purpose for the export of personal data from Ritzau, you must ensure that you process and store the data correctly and that you erase the data when the purpose of storage lapses. Read more about the processing and storage of personal data.
AU has a data processing agreement with the Ritzau news agency.
If you hold one or more lists of journalists’ contact details in printed or digital form, you must be aware of where and for how long you may store this information. Read about the processing and storage of personal data.
Remember to link to AU’s privacy policy and/or cookie policy from AU’s Facebook pages.
We are currently awaiting an update of “terms/policies that apply to Pages to clarify the responsibilities of both Facebook and Page admins and thereby make compliance easier for admins”. Read more.