May photos of employees or customers be published on the website or social media?
By Advisorn · updated on 25 October 2026 · Art. 28 CC, Art. 6, 19, 30-31 FADP, Art. 6-7 GDPR
In short
A photo in which a person is recognisable is personal data, and publishing it also touches their right to their own image (Art. 28 CC). For employees and customers the safe route is consent, given for that use (Art. 6 para. 6 and Art. 31 FADP) and revocable for the future. For photos of events in which people are part of a group and not in the foreground, informing beforehand and allowing objection is as a rule enough.
Good practice
- ask for consent in writing, saying where the photo will be published;
- take it down when consent is withdrawn or the employee leaves the business, unless agreed otherwise;
- for minors, the consent of their legal representative, unless the minor can understand and decide alone;
- at events, a notice at the entrance and the option of not being photographed.
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General information, not advice on your case: for your case the text of the law prevails. For a question about your case there is Advisorn's consulting.