Children’s Photographs, Social Media and AI: What Happens When Consent Changes?

By: Annabel Kaye, KoffeeKlatch

A parent asks for a photograph of their child to be removed from social media.

That sounds straightforward enough.

The child attended a class, club, activity or event. A photograph was taken with parental consent and later shared on a website, social media page or newsletter. Months later, the parent changes their mind and asks for the image to be removed.

Can they do that?

In many cases, yes. But the answer is not quite as simple as many people expect.

Consent can usually be withdrawn

Where consent has been relied upon for the use of a child’s image, parents generally have the right to withdraw that consent.

That means organisations should stop using the image in future where consent is the legal basis being relied upon.

For example, a provider may need to:

• Remove the image from their website.
• Stop using it in future marketing.
• Remove it from future publications.
• Update their records.

So far, so straightforward.

The internet has a long memory

The difficulty is that withdrawing consent does not operate like a magic eraser.

Once an image has been published online, there may already be copies elsewhere.

For example:

• Other people may have downloaded it.
• It may have been shared by third parties.
• It may have been screenshot.
• Search engines may have cached copies.
• Copies may exist in newsletters or printed materials already distributed.

This means an organisation may be able to stop its own future use of an image without being able to guarantee the removal of every copy that already exists.

Managing expectations is therefore just as important as managing consent.

Why this matters more in 2026 than it did a few years ago

Ten years ago, concerns about children’s photographs often focused on who could see them.

Today there are additional considerations.

Images can be:

• Shared instantly.
• Copied repeatedly.
• Manipulated.
• Used to create deepfakes.
• Combined with other information online.

The risks associated with children’s images have evolved, even where the original photograph was taken for entirely innocent reasons.

This does not mean organisations should stop taking photographs altogether. It does mean they should think carefully about why they are taking them, where they are being published and how long they remain available.

Do we need to stop using children’s photographs altogether?

Probably not.

We know that nothing beats photographs of real children genuinely enjoying the activities, clubs and events that you provide. Parents often want to see what activities look like in practice, and photographs can be an important part of showing the experience on offer.

Some organisations have responded to privacy concerns by avoiding photographs altogether. Others have moved towards photographs taken from behind, group shots where faces are not visible, or images with faces blurred.

These approaches may be appropriate for some organisations, but they are not automatically required.

What is important is that your approach is deliberate and documented.

Review your consent and photography release forms and make sure parents understand:

• Whether photographs will be taken.
• Where photographs may be published.
• Whether social media will be used.
• Whether posts may be publicly visible.
• How long images may remain available.
• How to withdraw consent.
• The practical limitations of withdrawing consent once an image has already been published online.

Being transparent about these issues from the outset can help avoid misunderstandings later and allows parents to make informed decisions about how their child’s image is used.

Practical steps for children’s activity providers

A good starting point is to review:

• Your photography consent wording.
• Where photographs are published.
• How long images remain online.
• Your procedure for handling withdrawal of consent.
• Whether old image galleries still need to be available.
• Whether children can be easily identified from accompanying information.

It is also worth making sure that consent forms explain what can realistically be removed and what may already be beyond your control once images have been shared online.

A practical rather than a perfect approach

Parents are increasingly aware of privacy, online safety and AI-related risks. Organisations working with children should be aware of them too.

The goal is not perfection. It is understanding the risks, setting realistic expectations and having sensible processes in place.

Because when it comes to children’s photographs, the most difficult question is often not whether consent can be withdrawn.

It is what happens after an image has already been shared.

Annabel Kaye, KoffeeKlatch children’s activity providers, clubs, franchises and service businesses on contracts, GDPR and practical data privacy compliance. If your photography consent forms, privacy documentation or procedures haven’t been reviewed recently, now is a good time to check that they still reflect how your organisation actually operates.