Do Traditional Photo Days Still Belong in a Child-Safe ECEC Sector?

I have had a number of questions lately around photographers coming into early childhood education and care services to take photographs of children within their learning environments.
It has prompted me to stop and reconsider a practice that has existed across our sector for many years.
Annual photo days are often viewed as a positive tradition. Families receive a special keepsake, services capture memories and children may enjoy participating in the experience.
But in the context of the current child safety reforms across the ECEC sector, I believe we need to ask a more important question:

Would we introduce this practice today if it was not already something we had always done?

My thinking around this has shifted.
This is not because I believe photographers are automatically unsafe or because services should never capture photographs of children. It is because child-safe decision-making requires us to look beyond a person’s intentions and consider the systems, access and potential risks surrounding the practice.

The expectations around children’s images have changed

From 27 February 2026, changes to the National Law introduced stronger restrictions on digital devices in centre-based education and care services. These include prohibiting personal devices in many circumstances and limiting the devices that can be used to capture, store or transmit images of children.
Services must also have policies and procedures addressing the safe use of digital technologies and online environments. These must consider the taking, use, storage and destruction of children’s images and videos, as well as how parental authorisation will be obtained and managed.
This creates a significant question for traditional photo days.
When an external photographer enters a service, they will generally bring their own:

• cameras
• memory cards
• laptops
• editing programs
• storage systems
• cloud-based platforms
• printing and distribution systems.

The service may supervise what happens while the photographer is physically on the premises, but does it genuinely understand and control what happens to every image after the photographer leaves?

Consent is important—but consent alone is not enough

A signed photography consent form is only one part of a child-safe process.
Parental consent does not remove the approved provider’s responsibility to assess and manage risk. It also does not answer questions about where photographs are stored, who can access them or how long they are retained.
Before engaging a photographer, services should be asking:

• What equipment will be used?
• Does the equipment automatically upload images to cloud storage?
• Where are the images stored?
• Who can access the original and edited files?
• Are other employees or subcontractors involved?
• Are overseas servers or third-party platforms used?
• How long are images retained?
• What happens to rejected or unused photographs?
• Are backup copies created?
• How is permanent deletion confirmed?
• Can images be used in portfolios, advertising, social media or competitions?
• Are facial-recognition or artificial-intelligence tools used at any point?
• What happens if there is a data or privacy breach?

A Working with Children Check may be one part of the service’s due diligence, but it does not assess the photographer’s cybersecurity, image-storage practices or internal access controls.

The question is not simply whether we trust the photographer. The question is whether the entire photography system is child safe.

Are we giving an external person unnecessary access?

We also need to consider the physical access traditionally provided to photographers.
In some services, photographers move between children’s rooms, photograph children during play and capture images in spaces that form part of the children’s everyday environment.
This can create several risks:

• children who do not have consent may appear in the background
• the service may struggle to maintain effective supervision
• the photographer may gain access to information about children’s routines and environments
• children may feel uncomfortable or pressured to participate
• images may capture identifying details about the service
• educators may assume someone else is responsible for overseeing the process.

Child-safe practice asks us to reduce unnecessary access to children, not simply manage that access once it has been granted.

Listening to children must also be part of the process

Parent or carer consent should not automatically mean that a child must participate.
Children should be told what is happening in a way they can understand. They should be able to decline, move away, change their mind or ask for the photography to stop.
A child should never be pressured to:

• smile
• pose
• sit close to another child
• change clothing
• remove a comfort item
• continue when they are distressed or uncomfortable.

Respecting children’s agency and bodily autonomy applies during photo day just as it does throughout every other part of the educational program.

Is there a safer alternative?

I am not suggesting that services need to respond with panic or immediately ban every form of professional photography.
I am suggesting that it is time to pause, critically reflect and redesign the process.
A lower-risk option may be an optional portrait session:

• held outside normal operating hours
• conducted with a parent or carer present
• held in one designated and visible area
• organised directly between the family and photographer
• separated from the service’s normal education and care program
• limited to children whose families have actively chosen to participate.

This approach allows families to continue receiving a valued keepsake while reducing the photographer’s access to other children, learning environments, routines and personal information.

When services decide to continue

Where a service chooses to continue professional photography during operating hours, it should not be managed through a simple booking and consent form.
The approved provider should have:

• a documented child safety and digital-security risk assessment
• a clear written agreement with the photographer
• verified information about image storage, access, transfer and destruction
• a designated photography area
• active educator supervision throughout the session
• a process for checking individual consent
• a process for seeking and respecting children’s assent
• controls preventing non-participating children from being photographed
• clear reporting requirements for any suspected breach
• written confirmation about when and how images will be destroyed.

ACECQA’s current guidance reinforces the need for service-specific risk assessments, strong procedures, appropriate supervision of visitors and controls over how images of children are taken, stored, transmitted and destroyed.

“We have always done it” is no longer enough

Many practices across the ECEC sector were introduced at a time when cameras, digital storage, cloud platforms and online image sharing looked very different.
That does not mean those practices were introduced with poor intentions.
It means the risks have changed.
A genuine child-safe culture requires approved providers and leaders to remain curious and willing to review practices that have become normalised.
We must be prepared to ask:

• What is the purpose of this practice?
• Who benefits from it?
• What risks does it create?
• Can we achieve the same outcome in a safer way?
• Can we genuinely control what happens to every child’s image?

And perhaps most importantly:

What would the child-safe decision be if we were designing this practice for the first time today?

For me, traditional photo days should no longer continue automatically.
Each service must carefully examine the purpose, necessity and complete image-handling process before allowing an external photographer to access children and their learning environment.
Photos are not necessarily the problem.

Unexamined access, unclear accountability and uncontrolled image systems are the risk.

At HGT EDU, we support approved providers and leadership teams to critically review their everyday practices through a child-safety lens. This includes strengthening risk assessments, digital technology procedures, visitor practices and governance systems so that child safety is not simply written into policy—it is visible in every decision the service makes.