Photography, Recording and Social Media Policy Template
Protect resident privacy in the digital age with a comprehensive policy governing consent for images, video, surveillance technology, and staff social media conduct.
Overview
The proliferation of smartphones, social media platforms, and remote monitoring technology has created significant new privacy risks in residential aged care. Residents may be photographed without consent, images may be posted online without authorisation, and covert recording devices may be placed without appropriate governance. This policy template establishes a clear consent framework for all forms of recording, robust staff social media guidelines, and a governance structure for facility-initiated monitoring technology.
What This Policy Covers
- Resident consent for photographs and video recording
- Use of resident images for care planning and documentation
- Facility use of photos for marketing or social media (explicit consent required)
- Staff personal device use and photography while on shift
- Staff social media conduct policy regarding residents and the facility
- Family-initiated recording devices in resident rooms
- Covert recording requests and legislative obligations (state-specific)
- CCTV and surveillance system governance
- Storage, access, and retention of recorded material
- Breach response and investigation procedures
Compliance Alignment
- Privacy Act 1988 – Australian Privacy Principles (APP 3, APP 6, APP 11)
- Charter of Aged Care Rights 2019 – Right 1 (privacy)
- Aged Care Quality Standard 1 – Consumer Dignity and Choice
- Surveillance Devices Act (state/territory specific)
- Australian Communications and Media Authority guidelines
Why This Policy Matters
Privacy breaches involving resident images — including staff posting photos to social media — have resulted in ACQSC investigations, media coverage, and significant reputational damage for providers. The Office of the Australian Information Commissioner (OAIC) has also issued findings against aged care providers for inadequate consent practices. A robust photography and social media policy is an essential privacy governance tool.
