Children's Photos at School: Consent, Sharing and What AI Changes

In the first week of October 2026, private schools in Dubai and Sharjah wrote to parents asking them to stop photographing and filming on campus where other children could be captured, and to stop sharing such images on social media and in WhatsApp groups. Headlines called it a ban. The detail is narrower than that, and more interesting.

The question underneath is one every school now faces, wherever it is: who decides what happens to a child's image once it has been taken? The answer used to matter mainly for privacy and courtesy. Generative AI has turned it into a safeguarding question, because an ordinary photograph of a child in uniform is now enough raw material to create a sexual image of them.

What did UAE schools tell parents?

Schools asked parents and visitors not to take photographs or videos on school premises where other pupils or staff may be captured without their consent, and not to share such images online. Parents can still photograph their own child at designated events, and official school photography continues. It is a consent rule about other people's children, not a ban on cameras.

One circular, quoted by Khaleej Times, reads: "In line with UAE privacy requirements and recent guidance being reinforced across private schools, we kindly ask parents and visitors to refrain from taking photographs or videos on school premises where other students or staff may be captured without their consent." The request covers classrooms, corridors, playgrounds, assemblies and drop-off and pick-up areas. Gulf News named schools in Dubai and Sharjah, and reported that one went further: no photos or videos on regular school days at all, and a request to delete earlier images that show other pupils. Emirates 24|7 reported that schools also want parents to avoid images that reveal a school's name or logo, a child's grade or the times children arrive and leave.

Two points are easy to miss. First, the reports we reviewed describe circulars from individual schools. They refer to guidance "being reinforced across private schools" and to existing protocols from the Knowledge and Human Development Authority, Dubai's private school regulator, which treat photographing pupils in vulnerable situations as a violation of their privacy. None cites a newly published regulation. Second, the legal footing is federal law that already existed: the Personal Data Protection Law (Federal Decree-Law No. 45 of 2021), under which personal data generally cannot be processed without consent, and Article 44 of the cybercrime law (Federal Decree-Law No. 34 of 2021), which makes it an offence to photograph other people, or to share or keep such images, in breach of their privacy. That offence carries at least six months' detention, a fine of AED 150,000 to 500,000 or both.

Can a parent photograph or post other people's children?

It depends on where you are. The UAE treats taking and sharing images of others without consent as a possible offence. England leaves parents' personal photos outside data protection law. France and Italy have moved to limit what parents may post even of their own children. No two systems draw the line in the same place.

England: The Department for Education's guidance says data protection law "does not usually apply when people take and use photos for personal use", such as pictures kept in a family album or shared privately with friends. That does not leave schools powerless. The same guidance says a school can set rules so that photography does not disrupt an event, include pupils who should not be identified or cause safeguarding or welfare concerns. It also tells schools not to publish images of pupils who should not be publicly identified, such as those with safeguarding concerns or under court orders.

France: Law No. 2024-120 wrote the child's image into the Civil Code's rules on parental authority. Parents protect their child's image right together, with respect for the child's private life, and involve the child in decisions according to age and maturity. Where parents disagree, a judge can bar one from publishing without the other's agreement. Where sharing seriously harms the child's dignity or moral integrity, a court can hand the exercise of the image right to someone else.

Italy: In a decision of 29 April 2026, the data protection authority upheld a father's complaint about photos of his two children posted by their mother. It held that publishing images of children under 14 on social media requires the prior consent of both parents, issued a warning and prohibited further posting without that consent. It rejected the argument that a private profile made the sharing safe: the closed nature of a profile cannot be proved, and its settings can be changed at any time.

Read together, these rules point the same way from different starting points. The French and Italian measures are about a parent's own child. The UAE circulars are about everyone else's. England relies on each school to set its own terms. All four treat a child's image as something that belongs to the child, held in trust by the adults around them.

What does AI change about a school photo?

A clear, front-facing photo of a child was once a privacy matter. It is now also an input. Nudify tools and other generative AI can turn a clothed, ordinary picture into sexual imagery in seconds, and the result can be used to humiliate, threaten or extort a child who never took or shared an intimate image.

The scale is no longer speculative. UNICEF reported in February 2026 that at least 1.2 million children across 11 countries said their images had been manipulated into sexually explicit deepfakes in the past year, citing research with ECPAT International and INTERPOL. In some of those countries that is one child in 25. In UNICEF's words: "When a child's image or identity is used, that child is directly victimised."

Schools are already targets. The Internet Watch Foundation and the UK's National Crime Agency have described a case in which criminals took images of pupils from a school website, used AI to create more than 100 sexual images and then attempted to extort the school. In response, the UK's online harms early warning working group, which includes the IWF and the National Crime Agency, advised schools to use images that are "harder to misuse or abuse, for example those taken from a distance or blurred", to apply privacy settings, strip metadata and train staff, as Schools Week reported. Australia's eSafety Commissioner has published advice for schools on sharing photos and videos in the age of AI and deepfakes, asking them to weigh purpose, consent, identification, audience, alternative images and privacy settings before anything is published.

This is why we need to put a spotlight on AI. AI is the strongest reason to take a child's image seriously. It also shows the limit of a rule aimed at parents. In that UK case the images came from the school's own website. Peer-on-peer abuse can draw on pictures children have posted themselves. Restricting parents' phones closes one source of images and leaves the larger ones open.

What should a school image policy cover?

A school image policy should cover every route by which a child's image is created, stored and published: the school's own channels, staff, contractors, parents, visitors and pupils. It should say whose consent is needed for what, which children must never be identifiable, and what happens when an image is misused. It belongs inside the school's safeguarding policy framework, not in a newsletter.

• Purpose: Why each kind of image is taken, where it will appear and for how long. An image taken for a classroom display has not been cleared for Instagram.
• Specific, renewable consent: Separate choices for internal use, newsletters, the website, social media and the press, renewed each year and easy to withdraw. Ask the child as well as the parent, and give the child's view more weight as they grow older.
• Children who must not be identified: A current list, shared on a need-to-know basis, of pupils who cannot appear in any published image, for example because of a court order or a safeguarding concern.
• The school's public channels: Prefer group shots, images taken from a distance and pictures of the activity over close-up portraits. Never pair a face with a full name. Leave out details that locate a child, such as class, timetable or travel routes. Remove metadata, review the archive and take down what no longer needs to be public.
• Parents and visitors: Say where and when photography is welcome, state plainly that images showing other children are not to be posted or forwarded without consent, and say that this includes class messaging groups. Make clear that covering other children's faces with an emoji or sticker does not replace consent.
• Staff and contractors: School devices and school storage only, no personal phones or personal cloud accounts, and written terms for external photographers covering storage, reuse and deletion. This sits naturally in the staff code of conduct.
• Pupils: The acceptable use policy should cover taking, sharing and altering images of others, including with AI, and say that creating a fake sexual image of another child is a safeguarding matter, not a prank.
• Retention and deletion: How long images are kept, who can access them and how they are removed when a child leaves or consent is withdrawn.
• Incident response: A defined route for when an image is misused or manipulated: who is told, how the child is supported, how takedown is requested and when the police are involved.

How the policy is introduced matters as much as what it says. A circular that announces a restriction without explaining it invites resentment and quiet non-compliance. Parents who understand that the rule protects their own child from a stranger's camera, and from what AI can now do with a single frame, are far more likely to keep it. Child Safe ME helps schools and organisations write and test these policies as part of its safeguarding policy and framework work, and trains staff to apply them.

What can parents do?

For parents, taking photographs of special school moments is completely understandable. But safeguarding asks us to think beyond our own child. A photograph of our son or daughter may also capture classmates, teachers, school uniforms, locations and other information about children whose families may not have agreed to that information being shared. Before you click, post or forward, consider a few simple questions:

• Whose child is in the photograph? Look beyond your own child. Are other children identifiable in the image or background?
• Do I have consent? We should not assume that because a photograph was taken at a school event, everyone pictured has agreed to have their image posted online.
• What does my child think? Children have a right to privacy too. As they grow older, we should increasingly involve them in decisions about what we share about them and help them understand their own digital footprint. French law now expects this, and the IWF and National Crime Agency guidance for parents suggests revisiting the conversation as children grow.
• Where am I sharing it? A class WhatsApp group can feel private, but digital images can be downloaded, screenshotted and forwarded. Once shared, our control over an image is significantly reduced. Italy's data protection authority made the same point about private profiles.
• What information does the photograph reveal? It is not only a child's face that matters. A photograph can reveal a school name or uniform, location, classmates, activities and potentially aspects of a child's routine.

Parents can also ask the school how their child's image is used, on which channels and for how long. They can limit or withdraw consent.

A heart or bunny emoji is not safeguarding

One practice we increasingly see is parents sharing a class or group photograph while placing hearts, bunny faces or other emojis over children who are not their own. The intention may be good, but an emoji should not be confused with a safeguarding measure.

It may prevent friends or followers from seeing a child's face, but it does not necessarily protect all the information contained in or associated with that photograph. Depending on how the photograph is edited and uploaded, the digital platform may still receive and process the image and associated data. And even with a face covered, a child may potentially be identifiable through their uniform, clothing, surroundings, school, event or context.

Most importantly, covering someone's face does not create consent to publish an image in which they appear. Hiding a child from the viewer is not necessarily the same thing as protecting that child's data. An emoji can hide a face. It cannot replace consent, privacy or responsible digital safeguarding.

Pause before you post

This should not be about frightening parents or suggesting that parents taking photographs have harmful intentions. In most cases, they simply want to capture happy memories. Good safeguarding is about creating sensible boundaries around those memories. Before posting, parents can ask themselves three simple questions: Do I have permission? What information am I sharing? Does this really need to be online? A beautiful moment in your child's life can still be captured without compromising another child's privacy.

If a child's image is misused

If a child's photo has been altered into a sexual image, or used to threaten them, treat it as a safeguarding concern from the first moment. Do not share, forward or save the image, even to report it. Reassure the child that they are not to blame, keep messages and usernames as evidence, and report through the school's safeguarding lead, the platform and the police. Our guide to AI-generated child sexual abuse material sets out the steps in full, including the reporting and removal services available in different countries and what schools should do when the image was made by another pupil.

Frequently asked questions

Has the UAE banned parents from taking photos at school?

No. Private schools in Dubai and Sharjah have asked parents not to photograph or film other pupils or staff without consent, and not to share such images online. Parents can still photograph their own child at designated events. Some individual schools have gone further and prohibited photography on ordinary school days.

Can a school stop parents taking photos at events?

Yes, a school can set conditions for its own events. In England, government guidance says data protection law does not usually apply to parents' personal photos, but that schools can still set rules to prevent disruption, protect pupils who must not be identified and address safeguarding concerns. UAE schools are doing the same by circular.

Do I need permission to post a photo that shows other children?

In the UAE, schools now ask for consent, and sharing images of others without it can be an offence. Elsewhere the law may not require it for a private family photo, but a public post is different from a family album. Asking first is the safe and considerate course everywhere.

Does a private account make it safe to share children's photos?

No. Italy's data protection authority rejected that argument in April 2026: a profile's settings can be changed at any time, and anyone who can see an image can copy or forward it. Treat anything posted to a group or a profile as something you no longer control.

Does covering a child's face with an emoji make a photo safe to post?

No. An emoji may stop friends or followers seeing a face, but the child may still be identifiable through their uniform, surroundings or the event. Depending on how the image is edited and uploaded, the platform may still receive and process it. Covering a face does not create consent to publish.

Should schools remove pupil photos from their websites?

Not necessarily all of them, but every public image should be there for a reason. UK advice after a blackmail case is to use images that are harder to misuse, such as those taken from a distance, and to remove names, identifying detail and metadata. Old posts deserve the same review as new ones.

Legal details cited here are accurate as of October 2026 and should be checked against the primary sources before being relied on. This article is general information, not legal advice.

Sources

1. Dubai schools tighten photography rules as parents told not to capture other students, Khaleej Times, 5 October 2026.
2. Dubai schools tighten photo and video rules to protect pupil privacy, The National, 5 October 2026.
3. UAE schools ban parents from taking photos and sharing them on WhatsApp, social media, Gulf News, 5 October 2026.
4. UAE private schools ban parents from taking photos on campus, and from sharing old ones on WhatsApp, Emirates 24|7, 1 October 2026.
5. Federal Decree-Law No. 34 of 2021 on Combatting Rumours and Cybercrimes, UAE Legislation, accessed October 2026.
6. Taking and using photos and videos, and using CCTV in schools, Department for Education, updated 9 July 2026.
7. LOI n° 2024-120 du 19 février 2024 visant à garantir le respect du droit à l'image des enfants, Légifrance, 20 February 2024.
8. Provvedimento del 29 aprile 2026, n. 314, Garante per la protezione dei dati personali, 29 April 2026.
9. Deepfake abuse is abuse, UNICEF, 4 February 2026.
10. New guidance for parents and carers as AI-manipulated images of children become a growing concern, Internet Watch Foundation and National Crime Agency, 3 July 2026.
11. More schools fear blackmail over pupil images posted online, Schools Week, 18 June 2026.
12. Sharing school photos and videos in the age of AI and deepfakes, eSafety Commissioner, accessed October 2026.

Last reviewed October 5, 2026. The UAE position rests on school circulars as reported by the press, not on a published regulation; check the primary sources before relying on any legal detail here.