Informing the congregation
By streaming images online you are transferring to third parties ‘sensitive personal data' (i.e. the images) of the people who are attending church and caught on camera.
Information should therefore be available to the congregation in advance of the proposed filming; for example, the dates, times and locations of filming. This will enable those attending to opt out if they wish and for consent forms to be completed by the parents/guardians/carers of the children, adults at risk and others attending the service who will be included in the footage.
If it has been decided that the filming/streaming is to happen e.g. once a month, those who do not wish to be/should not be filmed could decide not to attend that week or go to a different service or congregation.
Whilst it would be best practice to obtain specific written consent of those who will be in view of the cameras, this may be impossible to achieve in practical terms, particularly if filming/streaming is to occur each week. It is suggested that you follow the recommendations below to ensure that those attending are fully informed:
- A note should be included in the service intimation sheet informing the congregation that the cameras are in place and why they are there. The note should specifically describe the area/pews that will be in view of the camera. If all worship services are to be streamed, this should be a standing item on the intimation sheet.
- At the start of each service that is being filmed/streamed the Minister should not only welcome the congregation present in the building but also those tuned in/watching later online. This will further serve to inform and highlight that the cameras are there and transmitting images.
- Visible notices should be placed on the way into the church and in the areas the camera lens will focus, confirming the locations that will be within reach of the camera lens. This will allow those who do not wish to be ‘caught' on camera to select their seats appropriately.
- Unless prior consent has been obtained, the camera must avoid children/adults at risk and therefore be angled away should there be any involvement of children/adults at risk during the service. See further at 'Safeguarding considerations'.
- If the designated area also happens to be the only area that you have designated a wheelchair area, consider creating more spaces to provide a variety of places for wheelchair users to sit. It is vital that some are created within areas not picked up by cameras. You should contact the General Trustees to discuss how permission can be obtained for shortening, alteration or removal of pews to accommodate this.