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Why Personal Mobile Phones Have No Place in Photographing Children at School or Childcare

Updated: 6 days ago

Across Australia, many educators and carers are still using their personal phones to take photos of children—for learning documentation, quick parent updates, or spontaneous moments worth sharing.

Often, the intention is kind and the moment is genuine.

But with deep respect for the work you do, it’s time we acknowledge something important:

This practice, however well-meant, puts children, staff, and services at risk.

It’s Not Just a Policy Issue. It’s a Safety One.

Personal mobile phones are not designed for secure, professional use in educational settings. When photos of children are taken on a personal device—even just once—the data may:

  • Automatically upload to cloud platforms like iCloud or Google Photos

  • Sync across other personal devices—smartwatches, tablets, laptops

  • Be accessed by third-party apps, often without the user’s knowledge

  • Remain in backups or deleted folders for weeks, months, or longer

  • Create a digital trail that can’t be tracked, audited, or recalled

This isn’t about blame. It’s simply how the technology works.

Even with the best of intentions, once an image of a child is captured on a personal phone, the organisation loses control over where that image might go, or how long it might be stored.

Understanding the Legal Landscape

Under the Privacy Act 1988, any image that identifies a child is considered personal information. That means there are legal responsibilities under the Australian Privacy Principles (APPs) about how that information is collected, stored, and shared.

  • APP 3 – Collection: Must be lawful, fair, and necessary

  • APP 6 – Use and Disclosure: Limited to the original purpose, in authorised systems

  • APP 11 – Security: Organisations must take reasonable steps to protect personal data

Personal phones, no matter how careful we think we’re being, simply can’t meet that legal benchmark.

“An organisation must take reasonable steps to protect the personal information it holds from misuse, interference and loss.”— Office of the Australian Information Commissioner

What About Department Guidelines?

Most state and territory education departments now explicitly state that personal devices are not to be used for taking or storing photos of children.

For example, the Victorian Department of Education says:

“Schools must ensure that photographs, video or recordings of students are not taken or stored on personal devices.”— DET: Photographing Students Policy

This reflects a growing understanding of the need for consistent, secure, and professional systems when it comes to documenting children’s lives.

This Is About Child Safety, Not Just Digital Systems

The National Principles for Child Safe Organisations call on all of us—schools, centres, staff, and leadership—to do everything possible to protect children’s privacy, including how their images are captured and stored.

Using personal devices, no matter how informally, can:

  • Undermine institutional safeguards

  • Bypass accountability processes

  • Increase the risk of accidental breach or misuse

In child safety, it’s often not what goes wrong that matters most—it’s whether we had systems in place to prevent it.

“Child safe organisations need to have systems in place to protect children’s personal information, including images and recordings.”— Australian Human Rights Commission

Moving Gently Toward Best Practice

If your school or service is still using personal phones for images, know this: you are not alone. This has been standard practice in many places for years. Change is not about shame—it’s about moving forward with more awareness, better systems, and stronger safeguards.

Here’s what many centres and schools are now doing:

  • Providing organisation-owned devices for documentation

  • Updating internal policies to align with legal and departmental expectations

  • Training staff on privacy obligations and child safety implications

  • Ensuring any old or non-compliant images are reviewed, deleted securely, and reported where needed

  • Seeking support from digital safety professionals to strengthen systems

It’s Okay Not to Have It All Perfect—Yet


The important thing is to act now, with care and commitment. Our shared goal is to keep children safe—not just physically, but digitally and emotionally as well.

In today’s connected world, that includes protecting their images with the same diligence we bring to every other part of their wellbeing.

If you’re unsure whether your current practices are in line with:

  • The Privacy Act

  • The Australian Privacy Principles

  • Your state or territory’s education department guidelines

  • The National Child Safety Framework

Then now is a good time to pause, reassess, and reach out for support.

No blame. No judgement. Just a shared responsibility to do better, together.

Helpful References:

 
 
 

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