Legal

Photography consent

Version 2 · Updated Monday, 5 October 2026

Last updated: October 2026

# In short

  • You tell us, for each child, whether a provider may photograph or film them during sessions.
  • You can make an exception for an individual class — for example, “not at this class” or “yes, just at this one” — without changing your usual answer.
  • Saying no does not affect your child's place, booking or ability to attend.
  • Tumble does not publish your child's photograph or video.
  • Your preference is shown to the provider for the relevant session so that the provider can follow it.
  • The provider is responsible for deciding how it uses photographs and video and for having the appropriate legal basis and permissions for that use.

# 1. Your photography and video preference

When you add a child to Tumble, you can tell us whether you are happy for providers to photograph or film them during activities.

You can choose:

Yes

You agree that the provider may photograph or film your child during its sessions and use those images or recordings for the purposes it has told you about, which may include showing families what happens in its classes, including on the provider's own website or social-media accounts.

No

The provider should not use your child in photographs or video for its own purposes.

Your choice does not affect your child's ability to attend an activity.

Not answered

Until you make a choice, the provider should treat the preference as no.

# 2. Your preference is child-specific

Your photography preference applies to the individual child rather than automatically to every child in your household.

You can therefore choose a different answer for each child.

For example:

  • one child can have “yes”;
  • another can have “no”; and
  • you can change either answer later.

# 3. Exceptions for individual classes

You can override your usual preference for a particular booking.

For example, if your usual answer is no, you can choose:

> Yes, just for this class.

If your usual answer is yes, you can choose:

> Not at this class.

The exception applies only to the relevant booking or session.

It does not change your child's general photography preference.

Where you make an exception, the provider can see the applicable preference on the register or booking information for that session.

# 4. Changing your preference

You can change your general preference from your child's Tumble profile.

You can change a class-specific exception from the relevant booking where that functionality is available.

A change applies from the time you make it.

Changing your preference does not automatically undo something that has already happened.

For example, if a provider has already taken a photograph or published an image lawfully before you changed your preference, changing the setting does not technically erase the photograph from every place it may already exist.

If you ask a provider to remove an image, the provider should consider and respond to that request in accordance with its own privacy obligations and the circumstances in which the image was taken and used.

# 5. What saying “yes” means

If you say yes, your preference tells the provider that you permit photography and video of your child for the purposes covered by the provider's photography arrangements.

Depending on the provider, this may include:

  • photographs taken during a class;
  • video taken during a class;
  • photographs showing an activity in progress;
  • photographs used on the provider's website;
  • photographs used on the provider's social-media accounts; and
  • other promotional or informational uses explained by the provider.

The provider remains responsible for explaining its own uses of photographs and video and for complying with applicable data-protection law.

A “yes” on Tumble does not give the provider permission to use the image for an unlimited range of purposes.

# 6. What saying “no” means

If you say no, the provider should not intentionally include your child in photographs or video for the provider's own use.

The provider should take reasonable steps to follow the preference during the session.

Saying no does not:

  • affect your child's place;
  • affect whether you can book;
  • affect the price you pay;
  • reduce the activity your child receives; or
  • otherwise disadvantage your child.

# 7. What Tumble does not do

Tumble does not:

  • publish your child's photographs;
  • sell your child's photographs;
  • use your child's photograph for Tumble advertising;
  • give your child's photograph to other providers; or
  • give your child's photograph to third parties for their own promotional use merely because you have selected “yes”.

Tumble may display photography preferences to the provider responsible for the relevant booking so that the provider can manage its session.

# 8. Group photographs

Activities often involve groups of children.

If a provider wants to take a group photograph, it should take reasonable steps to identify which children can be photographed and which cannot.

Where a child has a “no” preference, the provider should either:

  • leave that child out of the photograph;
  • position the child so that they are not identifiable; or
  • otherwise use an appropriate method of respecting the child's preference.

A provider should not deliberately include a child who has opted out merely because other children in the group have opted in.

The provider remains responsible for deciding how to take and use group photographs lawfully.

# 9. People other than the provider

Your Tumble photography preference is about the provider's own photography and video.

It does not give Tumble control over photographs taken by:

  • other parents or carers;
  • members of the public;
  • professional photographers;
  • journalists;
  • venues; or
  • other third parties.

A provider must also consider any third-party photography arrangements it controls or commissions.

# 10. Naming a child

A photography preference does not automatically mean that the provider may publish your child's name alongside an image.

The provider remains responsible for deciding whether it needs separate permission or another lawful basis to identify a child by name.

If a provider wants to use a child's name alongside a photograph, it should make that use clear to the family and comply with applicable law.

# 11. When your child leaves a provider

Your photography preference on Tumble is intended to help the provider understand your wishes while your child attends its activities.

It does not automatically control what happens to images that the provider lawfully created or published before your child left.

The provider remains responsible for its own retention and continued use of photographs and video.

If you want a provider to stop using an existing image after your child has left, you can contact the provider and ask it to consider your request.

The provider should deal with that request under its own privacy arrangements and applicable data-protection law.

# 12. If you change your mind

You can change your preference at any time.

If you withdraw a previous “yes”, Tumble will update the preference we show to the provider.

That change applies going forward.

It does not guarantee that an image already taken or published can be recalled from:

  • a website;
  • social media;
  • another person's device;
  • screenshots;
  • cached copies; or
  • other places where it may already have been copied.

Where you ask a provider to remove an existing image, the provider should consider the request promptly and in accordance with applicable law.

# 13. Older children

Tumble's photography setting is designed primarily for parents and carers managing a child's activity account.

As a child becomes older and more able to understand and make decisions about photography and their personal information, their own views may become increasingly important.

Providers remain responsible for considering the child's age, maturity, understanding and applicable legal requirements when deciding how to obtain and rely on permission for photography.

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# Open items for legal review

1. Lawful basis: confirm whether providers should rely on consent, legitimate interests or another lawful basis for each category of photography/video use.

2. Special-category data: confirm whether any photography involving identifiable children creates additional considerations where the image reveals health, disability, ethnicity or other special-category information.

3. Tumble's role: confirm that Tumble is acting as controller for the photography preference itself while the provider is independently responsible for its photography and video processing.

4. Provider instructions: confirm exactly what Tumble's provider-facing terms should require providers to do when a child's photography preference is displayed on a register.

5. Consent wording: confirm whether the “yes” setting should legally be described as consent, permission, preference or another concept.

6. Withdrawal: confirm the effect of withdrawing consent where an image has already been taken, published or otherwise disseminated.

7. Existing images: establish a practical and legally appropriate process for provider requests to remove previously published images.

8. Group photography: confirm the appropriate wording where a provider photographs a group but excludes or obscures children who have opted out.

9. Third-party photographers: confirm whether the provider terms should expressly require providers to pass photography restrictions to photographers, venues and other processors.

10. Children's own views: establish an age/maturity approach for older children, including whether Tumble needs additional functionality or guidance.

11. Children's Code: confirm whether the Children's Code affects the design, defaults, presentation or changeability of this preference.

12. Provider privacy notices: ensure providers are required to explain their photography purposes, retention periods, publication channels and applicable rights in their own privacy information.

13. Marketing: distinguish ordinary documentation of sessions from promotional use on provider websites, social media, advertising or paid campaigns.

14. Tumble's own use: confirm that Tumble does not currently use provider-uploaded or provider-created child photography for its own promotional purposes, and ensure the Privacy Notice reflects the actual product.

15. Default setting: confirm that treating an unanswered preference as “no” is both operationally accurate and appropriate from a privacy/consent perspective.