Why photo use approvals need verified identity
An organisation may receive an email saying, “Yes, you may use my photo.” But a year later, several questions may arise:
- Who gave the answer?
- What does that person look like?
- Which photo was the answer about?
- Where did the person allow the photo to be used?
- Is the permission still valid?
This is why MyFaceGuard uses authenticated user accounts. A person’s decision is linked to a profile whose identity has been verified using a trusted electronic identity method.
This makes the photo-use process clearer and easier to manage for both the organisation and the person in the photo.
Authentication shows who gave the answer
Signing up with a regular email address does not always prove a person’s identity. The address may contain a mistake, be shared by several people, or be used by someone else.
With MyFaceGuard, users verify their identity using an available eID, BankID, or mobile identity method. Verification takes place in the environment of the selected identity service provider.
Learn more about the identity layer behind the process in MyFaceGuard’s partnership with eID Easy.
After verification, the organisation can link the photo-use decision to a verified user profile. This creates a clear record of:
- who made the decision;
- which photo the decision applied to;
- where the person allowed the photo to be used;
- when the answer was given;
- whether the decision was later changed or withdrawn.
Article 7 of the GDPR requires organisations to be able to prove consent when consent is used as the legal basis for processing personal data. Read the official GDPR text on EUR-Lex.
What does this mean for employers?
Employee photos are often used on company websites, social media, recruitment campaigns, internal communication channels, and event materials.
The situation can become more complicated when an employee leaves the company. Can the company still use the person’s photo? Can it keep the photo in its company archive?
MyFaceGuard helps organisations check the person’s current decision and its limits. If a former employee has allowed a specific photo to be used for a specific purpose, and that permission is still valid, the organisation has a documented basis for continuing that use.
This does not mean that consent given during employment is automatically valid forever. The employer must still consider the purpose, storage period, and legal basis for processing the photo.
The Latvian Data State Inspectorate points out that employee consent must be voluntary, and refusing consent must not lead to negative consequences. Read the DVI explanation about consent in employment relationships.
A clearer process for clients and event participants
The same process can be used for photos of clients, potential clients, business partners, conference participants, and speakers.
The organisation sends a specific request. The person verifies their identity, views the photo, and makes a decision.
If a question, objection, or complaint arises later, the organisation does not need to search through emails, messages, or paper forms. The consent history shows what was allowed and what the current status is.
This is not an absolute legal solution for every possible situation. However, it is a more reliable and transparent process than an anonymous form or a verbal agreement.
Recognition helps find the right person to ask
In a large or remote organisation, the communication team may not know every employee by face.
If a person gives permission in their MyFaceGuard settings, the organisation can use face recognition to find that person in uploaded photos. This allows the organisation to send a consent request even when it did not previously know who was shown in the photo.
In this case, face recognition helps find the person who should be asked. The person still makes the final decision about whether the photo may be used.
Permission to use recognition can be changed separately for each organisation.
See how the optional recognition process works in Find and share event photos faster with facial recognition.
Available identity verification methods
See the currently available all identity verification methods.
MyFaceGuard supports trusted electronic identity methods available in different European markets. The current list is updated as coverage expands.
| eParaksts mobile | Smart-ID |
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