Protecting Children Must Include Protecting Their Digital Likeness

When parents choose a child-centered business, such as a play space, learning studio, sports program, or community event, they expect that environment to prioritize safety. Traditionally, that expectation has focused on physical safety: clean facilities, trained staff, and secure check-in procedures.

But in the modern world, safety must also include digital safety.

Every time a business posts identifiable images of children online, those images enter an ecosystem that the business no longer controls. Photos can be copied, scraped by automated systems, archived indefinitely, altered through AI tools, or redistributed on platforms the original organization never intended.

This concern is no longer theoretical. Law enforcement agencies around the world have warned about the growing problem of AI-generated child sexual abuse material (CSAM), in which real children’s faces are extracted from publicly available photos and manipulated into explicit imagery. In many cases, the original image was a perfectly ordinary photo: a school event, a sports game, a birthday party, or a promotional image posted by a well-meaning organization.

Despite this reality, many businesses, schools, museums, city programs, and nonprofit organizations still rely on broad and outdated photography policies that treat attendance at an event as automatic consent to image use. Instead of offering meaningful opt-out protections, some organizations justify posting identifiable images of minors by claiming attendance is equivalent to being in a public place, such as walking through a grocery store or visiting a theme park and accidentally appearing in someone else’s photo.

This comparison is misleading. Casual background appearance in a stranger’s photo is not the same as an organization intentionally capturing, storing, and distributing identifiable images of minors for marketing and promotional purposes. When institutions knowingly operate under policies that allow the routine publishing of children’s faces without meaningful consent protections, those practices move beyond outdated convenience and into ethically negligent territory. Families should not have to hide their children from participation in community activities simply to avoid long-term digital exposure.

Children cannot meaningfully consent to a permanent digital footprint, and parents are often unaware that broad “we may use your image” policies may allow organizations to publicly share their child’s identifiable likeness without further notice. While these clauses may be legally permissible, they are increasingly ethically outdated given current technological realities.

Protecting children’s privacy does not require eliminating photography altogether. Businesses and institutions can adopt protective practices such as:

• Photographing children from angles that do not reveal identifiable faces
• Using depth, lighting, or framing to highlight activities rather than identities
• Blurring minors’ faces before posting images publicly
• Creating clear opt-in media consent specifically for minors rather than relying on blanket participation waivers
• Establishing public commitments to avoiding the use of minors’ identifiable faces in promotional materials

These changes require minimal operational effort but signal something meaningful: protecting children extends beyond physical spaces and into the digital environments where images now live indefinitely.

If an organization truly wants to be known as a place that cares about children, protecting their digital footprint must become part of that commitment. Children should not have to disappear from public life in order to remain safe online. Institutions must instead evolve their practices to ensure participation does not come at the cost of permanent digital exposure.