By Aneeta Prem MBE
AI abuse in schools has changed the safeguarding test for photographs of children. That does not mean schools and charities should remove every image. It means the decision to publish a photograph now needs stronger judgement about consent, necessity, identification and risk.
Real photographs can show achievement, community and impact. Children and young people should not become invisible because technology can be misused. But good intentions are no longer enough on their own.
Why pupil photographs carry a different risk
AI tools make it easier to copy, alter and sexualise ordinary images. A photograph that once looked harmless can be scraped from a website, combined with a name, school uniform or location, and used for humiliation, coercion or extortion.
That does not make every image unsafe. It changes the questions organisations should ask before publication.
The old question was often: Do we have permission to use this photograph?
The better question now is: Is this image necessary, proportionate, properly consented to and safe enough to publish in the current digital environment?
Consent still matters, but it is not the whole test
Schools and charities should explain where an image may appear, whether a name will be used, how long the image may remain online, and how someone can request removal.
Identifiable school photographs used for official purposes can involve personal data. The Information Commissioner's Office and government guidance both stress that organisations need to explain how images will be used and handle them in line with data-protection law.
Consent should therefore be clear and meaningful rather than treated as a one-off signature that lasts forever regardless of context.
Why this matters to Freedom Charity's education work
Freedom Charity's safeguarding work includes school resources, professional awareness, But It's Not Fair and Cut Flowers.
The education distinction needs to be precise. The PSHE Association says it worked with Freedom Charity to produce two lesson packs on forced marriage and FGM for Key Stages 3 and 4. Freedom Charity states that those accompanying lesson resources received the PSHE Association Quality Mark.
The Quality Mark applies to the teaching resources, not to the novels themselves.
That matters because good safeguarding education should be described accurately. Stories and lesson resources can work together, but they are not the same thing.
AI image abuse is a safeguarding issue
This is not simply a question of website design or online etiquette. Image manipulation can be connected with child sexual abuse, bullying, coercion, sexual extortion and violence against women and girls.
The Internet Watch Foundation's 2025 reporting highlighted the growth of AI-generated child sexual abuse imagery and the gendered nature of that harm. A fake image can still create real fear, shame and pressure.
The image may be artificial. The coercion is not.
What safer image use looks like
Schools, charities and community organisations should review public images rather than delete everything indiscriminately.
Useful questions include:
- Does this image still serve a clear purpose?
- Does the person need to be identifiable?
- Is a full name necessary?
- Does the image reveal a school, location, routine or sensitive service unnecessarily?
- Is the consent current and specific enough for the way the image is being used?
- Is there a straightforward route to request removal?
- Could a less identifying image achieve the same purpose?
Safer alternatives can include group images, wider shots, photographs from behind, carefully cropped scenes, hands at work, displays, books, artwork or other images that show activity without exposing unnecessary personal detail.
Do not blame the person in the image
If a photograph is manipulated or misused, responsibility belongs with the perpetrator, not the child, parent, student, volunteer or organisation that acted responsibly.
That point matters because shame helps abusers. Safeguarding should reduce shame, not redirect it towards the victim.
The law is moving, but practice has to move too
UK law has continued to develop around intimate-image abuse and AI-enabled child sexual abuse material. Legal change matters, but it cannot replace practical safeguarding.
Schools and charities still need clear image policies, trained staff, incident-response routes and a process for removing material quickly when concerns arise.
A practical image audit
An image audit does not mean deleting a website overnight. It means checking what is public, why it is public and whether it still needs to be there.
Start with images that are old, unnecessary, clearly identifiable, linked to full names, uniforms or locations, connected with vulnerable people, or published without a clear record of why consent was obtained.
Then update the policy. Explain how photographs may be used, how long they may remain online, whether social media is included and how consent can be withdrawn or reviewed.
The new safeguarding test
Before publishing an image, I think every organisation should ask:
Would we still use this photograph if we understood how easily it could be copied, altered, sexualised or used to threaten the person in it?
If that question raises concern, stop and review the image before publication.
This is not about fear. It is about judgement.
Children, students, patients, survivors, volunteers and campaigners should not be made invisible. Their stories matter. Their dignity matters. Their safety matters too.
FAQs
Should schools remove every pupil photograph?
No. A proportionate approach is better: review images, minimise unnecessary identification, update consent processes and remove images that create avoidable risk.
Can charities still use photographs of children or people they support?
Yes, where the use is necessary, lawful, dignified and properly considered. Sensitive contexts and unnecessary identifying details need particular care.
Why is consent not enough by itself?
Because risk also depends on what the image shows, where it is published, how identifiable the person is and whether the original purpose still exists.
Do the novels But It's Not Fair and Cut Flowers have the PSHE Association Quality Mark?
No. The Quality Mark applies to Freedom Charity's accompanying teaching resources. The novels remain works of fiction that can be used alongside those resources.
About the author
Aneeta Prem MBE is an author, human-rights campaigner and co-founder of Freedom Charity with Lord Toby Harris. Her safeguarding work includes forced marriage, FGM, dishonour abuse, child protection and prevention.
Sources and further reading
- PSHE Association: Freedom Charity forced marriage and FGM lesson packs
- GOV.UK: taking and using photos and videos in schools
- ICO: school photographs and data protection
- Internet Watch Foundation: 2025 Annual Data and Insights Report
First published 9 May 2026. Substantively reviewed 21 August 2026.