Legal Framework
This policy follows UK safeguarding legislation and relevant data protection law, including:

• Children Act 1989 & 2004
• Working Together to Safeguard Children
• UK GDPR and Data Protection Act 2018
• Guidance from the NSPCC and Information Commissioner’s Office (ICO)

Safeguarding Responsibilities
Kirsty Bowen Photography holds an Enhanced DBS certificate and is subscribed to the Update Service. Evidence can be provided to schools on request.

Safeguarding responsibility during sessions is shared in a defined way:

• The school or nursery retains overall safeguarding responsibility for pupils at all times.
• Kirsty Bowen Photography works under school safeguarding procedures while on site and does not take responsibility for safeguarding decisions or pupil supervision outside agreed arrangements.
• At no point is the photographer left with unsupervised access to children, and all work takes place under the supervision of school staff.
• Visible identification is worn at all times while on school premises.

Safeguarding Practice
Safeguarding is embedded into how photography sessions are conducted. This means children are always photographed within normal school routines and never placed in situations that increase risk.

School staff remain responsible for supervision and general pupil behaviour throughout all sessions.

No child is excluded from activities for photographic reasons.


Consent and Safeguarding Controls
Photography only takes place where the school or nursery has confirmed that appropriate consent status has been recorded and is in place.

The school or nursery is responsible for identifying:

• pupils who must not be photographed
• Any restrictions on photography or image use
• Any safeguarding-related considerations affecting participation

Children without consent or with restrictions are managed discreetly in line with school instructions and are never singled out or identified.

Full consent processes are set out in the Image Consent Policy.


Responding to Safeguarding Concerns
If a safeguarding concern arises during a session, it will be reported immediately to the school’s Designated Safeguarding Lead (DSL) or appropriate safeguarding officer.

Where there is immediate risk of harm, statutory safeguarding procedures will be followed.

The photographer does not investigate safeguarding concerns but reports them to the appropriate safeguarding lead.


Professional Boundaries and Conduct
Professional boundaries are maintained at all times.

Photography sessions are conducted in a way that ensures appropriate and professional interaction with pupils and staff.

This includes working only within the context of school-led activities and avoiding any unnecessary physical contact with children.


Health, Safety and Operational Control
Photography sessions may be paused or stopped if conditions are unsafe or if school safeguarding staff request adjustments.

School staff remain responsible for site safety, pupil supervision, and operational control within the school environment.


Insurance
Kirsty Bowen Photography holds:

• Public Liability Insurance
• Professional Indemnity Insurance

Evidence can be provided to schools on request prior to or during commissioning.


Safeguarding Priority
Where there is any conflict between this policy and school safeguarding procedures, school safeguarding procedures take precedence during all on-site activities.


Policy Review
This policy is reviewed regularly and updated where required.

Policy last reviewed: May 2026
Signed: Kirsty Bowen