Purpose and Scope
ATTP regularly creates photographs, video recordings, live streams, and written testimonials featuring participants, volunteers, staff, and guests at events, programmes, and other activities. This policy sets out how ATTP obtains, records, and respects consent for the use of such media, in line with the Nigeria Data Protection Act 2023 (NDPA), the United Nations Convention on the Rights of the Child (UNCRC) Article 16, and the principles of the General Data Protection Regulation (GDPR) where applicable.
This policy applies to all ATTP programmes, events, and activities, whether in person or online, and to all individuals who capture or publish media on ATTP's behalf, including staff, volunteers, contractors, and programme partners.
What "Media" Means Under This Policy
For the purposes of this policy, "media" includes:
(a) Photographs (still images), whether captured by ATTP staff, volunteers, contractors, or automatic event photography. (b) Video recordings, including footage captured for social media, impact reports, documentary content, or archival purposes. (c) Audio recordings where an individual is identifiable. (d) Written testimonials, quotes, or case studies that identify an individual by name, photograph, or sufficient contextual detail. (e) Live streams or real-time digital transmissions of events.
Consent Requirements
ATTP will not photograph, film, or quote any individual without first obtaining their free, specific, informed, and unambiguous consent, consistent with section 25 of the NDPA 2023. Consent must be obtained before the activity, not during or after.
Consent forms are issued: (a) At programme application stage, as part of the standard application form. (b) At event registration, via a physical or digital consent form provided before the event begins. (c) Before any planned media production (such as an impact documentary or brand shoot), via a dedicated consent form covering the specific use case.
Ticking a box marked "I agree to ATTP's terms" is not sufficient consent for media use. A specific, separate consent question must be asked.
Under-18 Participants
Where a participant is under 18 years of age:
(a) Consent must be obtained from a parent or legal guardian before any image or recording of that participant is captured or used. (b) The consent form must clearly describe how the media will be used, where it will be published, and for how long. (c) Consent forms for under-18s must be signed and returned before the participant attends any ATTP event at which photography or filming will take place. (d) Where a parent or guardian provides consent on behalf of a child, they retain the right to withdraw that consent at any time. (e) Children who are able to form and express their own views should also be asked individually whether they are comfortable being photographed or filmed, regardless of parental consent. A child's clear discomfort must be respected, even if parental consent has been given. (f) ATTP will never publish a photograph or video that identifies a child in a context that could expose them to harm, embarrassment, or exploitation, regardless of consent.
What Consent Covers
Consent forms will specify the following, and ATTP will only use media in the ways consented to:
(a) The format of media (photography only, video only, or both). (b) The purpose of use (for example: social media, annual report, grant application, documentary, press release). (c) The channels of publication (for example: Instagram, website, printed materials, press). (d) The duration of use (for example: for the duration of the programme, or indefinitely). (e) Whether the individual is identifiable by name, face, or role.
Withdrawing Consent
Any individual, or the parent or guardian of a child participant, may withdraw their consent to media use at any time by writing to info@attpglobal.com. ATTP will:
(a) Acknowledge the withdrawal within five working days. (b) Remove or anonymise the individual's image from any materials that can practically be edited or taken down. (c) Note that media already printed and distributed (such as a published report) may not be retrievable, but the image will not be used in any future material.
Storage and Retention of Media
All photographs and videos featuring identifiable individuals are personal data and will be handled in accordance with the ATTP Data Retention Schedule and Data Protection Policy (Internal). Media is stored on password-protected ATTP systems and is not accessible to the public except as specifically published. Raw footage and unpublished images will be retained for no longer than two years from the date of capture, after which they will be securely deleted. Published media may be retained for longer, provided consent was given for indefinite use.
Social Media and Third-Party Sharing
ATTP staff and volunteers must not:
(a) Post photographs or videos of other participants, volunteers, or staff on personal social media accounts without the express permission of those individuals. (b) Tag individuals in social media posts without checking with them first. (c) Share ATTP media files with third parties, including partner organisations, funders, or press, without authorisation from the Founder or a designated communications lead.
Breaches
A breach of this policy includes publishing media without consent, sharing media with unauthorised third parties, and photographing or filming minors without parental consent. Breaches by staff or volunteers will be treated as a disciplinary matter and may result in the termination of engagement. Breaches that constitute unauthorised processing of personal data will be reported to the relevant regulatory authority in line with the ATTP Data Protection Policy (Internal).