Thanks to the new National Model Code and upcoming regulatory changes under the National Quality Framework (NQF), early childhood services across Australia must now implement robust policies for the taking, use, storage, and destruction of images and videos of children. Here's a sample policy template aligned with the latest updates, effective from 1 September 2025.
Purpose
To safeguard children’s privacy, dignity, and safety by regulating the capture, use, storage, and destruction of images and videos in accordance with:
- The National Model Code (July 2024)
- NQF Child Safety Reforms (effective 1 Sept 2025)
- National Quality Standard (NQS) refinements (effective 1 Jan 2026)
Scope
Applies to:
- All educators, staff, volunteers, and visitors
- All centre-based early childhood services under the NQF
- All devices capable of image/video capture (phones, tablets, cameras, smartwatches, etc.)
Image and Video Capture
- Only service-issued devices may be used to take images/videos of children.
- Personal devices (phones, smartwatches, etc.) must be stored away and not carried while working directly with children.
- Images/videos may only be taken for approved educational purposes, documentation, or with explicit parental consent.
Consent and Authorisation
- Written parental/guardian authorisation must be obtained prior to:
- Capturing images/videos
- Using images/videos for documentation, displays, portfolios, or promotional materials
- Consent forms must specify:
- Purpose of use
- Duration of storage
- Right to withdraw consent
Storage and Access
- All images/videos must be stored:
- On secure, encrypted service-approved platforms
- With restricted access (only authorised staff)
- No use of personal cloud storage, USBs, SD cards, or external hard drives
- Metadata and location data must be disabled on devices
Destruction and Retention
- Images/videos must be deleted:
- Upon child’s exit from the service (unless retained for legal or educational recordkeeping)
- When consent is withdrawn
- After the documented retention period expires
- Destruction must be irreversible (e.g., secure wipe protocols)
- Use of optical surveillance devices (e.g., CCTV) must be:
- Clearly disclosed to families
- Used only for safety and security purposes
- Governed by separate surveillance policies
Staff Training and Accountability
- All staff must complete annual training on:
- Child-safe digital practices
- Privacy and data protection
- Ethical documentation
- Breaches of this policy will trigger disciplinary action and may be reported to regulatory authorities
Review and Continuous Improvement
- This policy will be reviewed annually or upon regulatory updates
- Feedback from educators, families, and children will inform revisions
- Policy implementation will be monitored through internal audits and quality assessments
Further Reading
Policies And Procedures In Early Childhood Services
Policy Development In Early Childhood Settings
How To Get Ready For The New Child Safety Changes
Mobile Phone & Smart Watch Policy Example
Four Eyes Policy
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