PHOTOGRAPHY AND MEDIA POLICY

Zora Skin and Aesthetics Group

Document reference

POL-004

Version

1.0

Effective date

19 July 2026

Review date

19 July 2027

Document owner

Marina King

Approved by

Marina King

1. Purpose

This policy explains how Zora Skin and Aesthetics Group takes, stores and uses photographs and videos connected with consultations, treatments, clinical records, education and marketing. It is intended to protect client privacy, dignity and choice while supporting safe treatment documentation and responsible business promotion.

2. Scope

This policy applies to all photographs, videos and other visual media created or received by the clinic, including images taken on clinic devices, a business mobile phone, the Faces platform or another approved system. It applies to clients, models, visitors, contractors and anyone acting on behalf of the clinic.

3. Our principles

  • Images will only be taken for a clear and legitimate purpose.
  • Clients will be told why an image is required and how it may be used.
  • Clinical-record images and marketing images will be treated as separate purposes.
  • A client may refuse promotional photography without affecting their treatment or standard of care.
  • Only the minimum necessary area will be photographed, and dignity will be maintained at all times.
  • Images will not be edited in a way that misrepresents treatment results.

4. Clinical photographs

Clinical photographs may be recommended or required to document the treatment area, support assessment and treatment planning, record progress, monitor outcomes, provide continuity of care, manage complications, respond to concerns and meet insurance or professional requirements. Where clinical photographs form part of the treatment record, they will be stored confidentially with the relevant client record and will not automatically be used for advertising or social media.

5. Marketing and promotional photographs

Identifiable photographs or videos will only be used for the website, social media, advertising, printed materials, training content or other promotional purposes where the individual has given specific and informed consent for that use. Consent will identify the agreed channels or purposes wherever reasonably possible.

Promotional consent is optional and separate from consent to treatment. No client will be pressured to agree, and declining promotional use will not affect access to treatment, prices or care unless a clearly advertised model arrangement expressly requires content creation as a condition of the reduced rate.

6. Model appointments

Where a reduced model rate is offered specifically for content creation, this will be made clear before booking. The client will be told what type of images or video are required and where they may be published. Separate treatment consent and photography or media consent will still be obtained. The clinic will not use material outside the agreed scope without obtaining further consent.

7. Obtaining and recording consent

  • Consent must be freely given, specific, informed and unambiguous.
  • The person giving consent must understand what will be photographed, why, where it may appear and whether their face or other identifying features will be visible.
  • Consent will be recorded in writing or electronically, normally through Faces or another approved consent record.
  • Separate choices should be offered where appropriate, for example clinical record only, website, Instagram, Facebook, TikTok, printed marketing or professional education.
  • Consent will be checked again where the proposed use changes materially.

8. Withdrawal of marketing consent

A person may withdraw consent for future marketing use at any time by contacting the clinic through Business WhatsApp. The clinic will stop making new uses of the material and will remove it from channels under its direct control where reasonably practicable. Withdrawal does not affect lawful use that occurred before consent was withdrawn.

Once an image has been published online, shared, downloaded, indexed by search engines or reproduced by others, complete removal from the internet cannot be guaranteed. This limitation will be explained before promotional consent is obtained.

9. Children and vulnerable adults

The clinic does not normally use identifiable images of anyone under 18 for promotional purposes. Where visual media involving a child or a person who may lack capacity is considered necessary, the clinic will assess capacity, best interests, safeguarding and legal authority carefully and obtain appropriate consent before taking or using the image.

10. Taking photographs and videos

  • Images should be taken in a private and appropriate setting.
  • The background should be clear of unnecessary personal information, other clients and confidential material.
  • Before-and-after photographs should use consistent positioning, lighting and camera settings where possible.
  • Only clinic-approved devices and systems should be used.
  • Images should be transferred promptly to the approved record or storage system and removed from temporary device storage when no longer needed.
  • Personal filters, beauty filters or misleading alterations must not be applied.

11. Storage, access and security

Images will be stored securely with appropriate password protection, access controls and confidentiality safeguards. Access will be limited to people who need the material for treatment, administration, legal, insurance or approved marketing purposes. Images must not be stored in personal photo libraries, personal cloud accounts or private messaging accounts unless temporarily unavoidable and then only for the shortest possible period before secure transfer and deletion.

12. Sharing with third parties

Images will not be shared with another organisation, practitioner, prescriber, insurer, legal adviser, regulator, website developer, marketing provider or training body unless there is a lawful reason and the sharing is necessary, consented to where required, or legally required. Third-party providers must protect the information and use it only for the agreed purpose.

13. Retention and deletion

Clinical images will normally be retained as part of the client treatment record for the period required by law, insurance terms and professional guidance. Promotional media will be reviewed regularly and kept only while it remains relevant, accurate and supported by a valid lawful basis. When images are no longer required, they will be securely deleted or anonymised where reasonably possible.

14. Client rights and complaints

An identifiable photograph or video is normally personal information. Individuals may have rights to ask for access, correction, restriction, objection or erasure, depending on the circumstances and any legal or clinical reason for retaining the record. Requests or concerns should be raised with Zora Skin and Aesthetics Group through Business WhatsApp. Individuals may also complain to the Information Commissioner’s Office.

15. Breaches and inappropriate use

Any lost device, unauthorised disclosure, mistaken publication, access by the wrong person or other suspected misuse of visual media must be reported immediately to the document owner. The clinic will assess the risk, take steps to contain the incident, document the response and notify affected individuals or the Information Commissioner’s Office where legally required.

16. Monitoring and review

This policy will be reviewed at least annually and sooner if legislation, guidance, technology, systems or clinic practices change. Consent records and published content may be checked periodically to ensure that use remains within the agreed permissions.

17. Related documents

  • Website Privacy Policy
  • Consent Policy
  • Data Protection and Confidentiality Policy
  • Social Media Policy
  • Complaints Policy
  • Faces photography and media consent record, where used  

18. Version control

Version

Date

Changes made

Author

1.0

19 July 2026

Initial issue

Marina King