Especially to communication staff

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).

Use of images and videos

If you publish images of persons, it is important to be aware 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. 

When you publish an image that depicts persons, you must carefully evaluate whether the image will be used in the context for which it is intended, and whether you need the consent of the person depicted. This also means that the image must not be too old. If you are in any doubt, you should use another image. 

The Danish Data Protection Agency does not have any written rules concerning videos, but in this case you should follow the rules for images. 

The Danish Data Protection Agency distinguishes between two types of images of persons – portrait images and situational images. The two types indicate which images you may use freely, and which images you must have permission to use.

Please notice that all images on the internet basically are protected by copyright, so you must not download images you find there without permission. There are, however, a number of collections of images that may be used freely, but always read the terms and conditions carefully. Find more information. 

Situational images

Situational images are images where an activity or situation is the actual purpose of the image.

Situational images may normally be published without the persons in the image having granted their permission. The decisive factor determining whether you may use an image without permission is that the persons depicted do not feel that they are being exposed or exploited. This must be based on a case-by-case assessment, and if you are in any doubt at all, you should obtain the permission of the persons depicted in the images before you publish them. 

When you publish an image that depicts persons, you must always carefully evaluate whether the image will be used in the context for which it is intended. 

See examples of situational images and images ‘in between’.

Some situational images can normally never be published without consent:

  • Images of employees at work in a private company or public authority.
  • Images of customers in a shop, in a bank, or at the post office, etc.
  • Visitors to a bar, nightclub, disco or similar venue.


Portrait images

The purpose of portrait images is to depict one or several specific persons. Portrait images normally always require consent to publication on the Internet. This is because some people may feel uncomfortable about having such images published, possibly together with their name or other details. You must therefore always obtain the permission of the person(s) depicted in any image that you wish to publish. 


Examples of portrait images and images ‘in between’



In Cumulus, there is a wide selection of both portrait images and situational images.

Find more information about Cumulus. 


Images from closed events

AU Photo is often requested to take pictures at closed events, such as graduation ceremonies. Remember to inform the participants that a photographer will be present, and if you wish to publish portrait images, remember to request consent to use the images in the right context prior to the event.

Updating of Cumulus 

Cumulus will be updated at the end of 2018, and in this connection the access to download images in Cumulus will be tightened. All employees can view images in Cumulus, but in future, only employees in the communication departments will be able to download the images. These employees will also receive a personal user name and password.  



Portrait images in PURE

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.

Use of images and videos for marketing purposes

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 videos

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.

Contacting a YouTube channel 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.

Storage of images and videos

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.

Do you work with the press?

Ritzau news agency

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.

Press contact in general

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.

Are you a web editor?

Find guidelines for web editors


Are you a newsletter editor? 

Find information about Campaign Monitor. 

Are you a Facebook page administrator?

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.