Photography / Recording Policy
Policy Statement
Pembrokeshire Leisure is committed to providing safe, welcoming and inclusive environments where customers, visitors and employees can enjoy leisure, sport and wellbeing activities with confidence.
We recognise that photography, video recording and social media play an important role in celebrating personal achievements, promoting healthy lifestyles and building community engagement. This policy supports the responsible use of photography and recording devices while protecting the privacy, dignity, safety and wellbeing of everyone who uses our facilities.
The welfare of children, young people and vulnerable adults remains paramount and will always take precedence over photography or filming activities.
Images or recordings taken within Pembrokeshire Leisure facilities must not be manipulated or altered in a way that misrepresents individuals, activities or events.
Purpose
This policy aims to:
- Protect the privacy and dignity of customers, visitors and employees
- Safeguard children, young people and vulnerable adults
- Provide clear guidance regarding photography, video recording and live streaming within Pembrokeshire Leisure facilities
- Encourage responsible use of social media and digital content
- Ensure compliance with relevant safeguarding and data protection legislation
- Support positive promotion of leisure activities and customer achievements
Scope
The policy applies to all devices capable of capturing images, video or audio.
This policy does not apply to CCTV systems operated by Pembrokeshire Leisure for safety, security and operational purposes.
Pembrokeshire Leisure Values
All photography and recording activity within Pembrokeshire Leisure facilities should reflect our commitment to:
- Respecting the privacy and preferences of others
- Creating welcoming and inclusive environments
- Supporting community participation and positive experiences
- Promoting health, wellbeing and achievement
- Maintaining safe and enjoyable facilities for everyone
Personal Photography and Video Recording
Customers may take photographs and videos for personal, non-commercial purposes within permitted areas of the facility provided that:
- The primary focus is themselves, their family members, friends or individuals who have agreed to be photographed or recorded
- They do not intentionally photograph, record or identify others without their knowledge or consent
- They do not disrupt activities, obstruct equipment or interfere with staff duties.
- They comply with all instructions issued by facility staff
- The photography or filming does not create safeguarding, privacy or health and safety concerns
Pembrokeshire Leisure reserves the right to restrict or prohibit photography and recording where concerns are raised regarding privacy, safeguarding, customer welfare or enjoyment of the facility.
Sharing Content on Social Media
Pembrokeshire Leisure encourages customers to celebrate their achievements and share positive experiences through social media.
Customers are encouraged to:
- Tag @PembrokeshireLeisure where appropriate
- Use promotional hashtags promoted by Pembrokeshire Leisure
- Share content that reflects the values of the organisation
Before sharing images or videos online, customers must ensure:
- All identifiable individuals have agreed to the content being shared
- The content does not compromise the privacy or dignity of others
- The content does not contain inappropriate, offensive or discriminatory material
Where customers tag Pembrokeshire Leisure in social media content, the organisation may request permission to repost or share the content through official channels.
Tagging Pembrokeshire Leisure does not automatically constitute consent for promotional use.
Areas Where Photography and Recording Are Strictly Prohibited
Photography, filming, recording and live streaming are strictly prohibited within:
- All changing rooms and changing village facilities
- Toilet facilities
- Shower areas
- Sauna and/or steam room facilities
- First aid and treatment rooms
- Staff-only areas
- Any area where an individual would reasonably expect privacy
No exceptions will be granted for personal photography in these areas.
Any person found using recording equipment within prohibited areas may be asked to leave the facility immediately and the matter may be referred to the Police or appropriate safeguarding authorities where necessary.
Swimming Pools
Due to safeguarding and privacy considerations, photography and filming within swimming pool halls is generally restricted.
Photography, filming and recording are prohibited during public swimming sessions unless authorised in advance by facility management.
Exceptions may also be considered for:
- Organised club activities
- Galas and competitions
- Special events
- Approved promotional activities
All exceptions require prior approval from facility management and must be supported by appropriate safeguarding arrangements.
Events, Clubs and Organised Activities
Photography and filming during organised activities may be permitted where:
- Participants have been informed in advance
- Appropriate safeguarding arrangements are in place
- Necessary permissions and consents have been obtained
- Facility management has approved the activity where required
Event organisers may be required to complete a Photography and Filming Request Form before permission is granted.
The organiser remains responsible for ensuring compliance with safeguarding and data protection requirements.
Children, Young People and Vulnerable Adults
Pembrokeshire Leisure is committed to safeguarding all children, young people and vulnerable adults.
Photography or filming involving these groups must:
- Focus on participation, achievement and positive experiences
- Be appropriate and proportionate
- Avoid intrusive or unnecessary close-up images
- Comply with safeguarding procedures and best practice guidance
- Respect the wishes of participants, parents, guardians and carers
Management reserves the right to prohibit photography or filming where safeguarding concerns exist.
Commercial Photography, Filming and Content Creation
Any photography, filming or content creation undertaken for:
- Commercial purposes
- Marketing campaigns
- Advertising
- Journalism or media publication
- Business promotion
- Professional photography
- Influencer or content creator activity
must receive prior written approval from Pembrokeshire Leisure.
The organisation may require:
- Public liability insurance documentation
- Risk assessments
- Proof of qualifications or accreditation
- Participant consent documentation
- Compliance with safeguarding procedures
Live Streaming and Wearable Recording Devices
The use of live-streaming technology and wearable recording devices presents additional privacy considerations.
Pembrokeshire Leisure may restrict or prohibit the use of:
- Smart glasses
- Body-worn cameras
- Action cameras
- Continuous recording devices
- Live-streaming applications
Permission may be withdrawn where recording activity captures other users without their consent or creates safeguarding concerns.
Photography and Filming by Pembrokeshire Leisure
Pembrokeshire Leisure may occasionally undertake photography and filming for:
- Marketing and promotional campaigns
- Social media content
- Websites and publications
- Internal communications
- Customer success stories
- Community engagement initiatives
Where required, consent will be obtained and processing of images will be carried out in accordance with UK data protection legislation and Pembrokeshire Leisure procedures.
Individuals who do not wish to appear in promotional materials should inform a member of staff.
Complaints and Concerns
Any customer, visitor or employee who has concerns regarding photography or recording within a facility should report the matter immediately to a member of staff.
Staff will:
- Assess the concern
- Investigate where appropriate
- Request recording activity to stop if necessary
- Escalate safeguarding concerns
- Take appropriate action in accordance with organisational procedures
Enforcement
Pembrokeshire Leisure reserves the right to:
- Withdraw permission to photograph or film
- Require recording activity to cease
- Remove individuals from the facility
- Refuse future access or bookings
- Suspend or terminate membership in accordance with membership conditions
- Refer matters to safeguarding agencies, local authorities or the Police where appropriate
Failure to comply with this policy may result in disciplinary or legal action where applicable.