What you need to know as a safeguarding lead or welfare officer in sport to reduce the risk of AI-generated child sexual abuse material, respond safely and support a child's safety and wellbeing.
AI and images of children in sport
Photos and videos help sports organisations celebrate children and promote their work. But once an image is online, someone can copy it, add details that identify the child, or change it using artificial intelligence (AI). AI tools can turn an ordinary photo into almost anything, from swapping your kits or altering results to a realistic nude or sexual image.
The image may be fake, but the harm is real.
Creating, possessing or sharing sexual images of children, including those created or altered by AI, is a criminal offence. People may also use them to bully, threaten, groom or control a child.
AI can be used to change images in different ways. You may hear people call these images AI deepfakes, or deepfake images. When AI is used to create sexual content involving a child, we use the term AI-generated child sexual abuse material (AI-CSAM) because it reflects the abusive nature of the content.
Reduce the risk of children’s images being altered with AI
You cannot stop every possible misuse of images, but there are steps you can take to reduce the risk.
1. Make your policies and procedures stronger
- Name a lead for image safety. This could be the safeguarding lead or another member of staff. Make it clear this person can be contacted when anyone in the club has a query regarding the use of images. This person should be suitably trained.
- Know what happens to each image. Record who takes it, where copies are kept, who can see it, where it is shared and when it will be deleted. Delete images you no longer need.
- Update your risk assessment. Be sure to cover AI changes, public social media accounts, livestreams, event photography, player profiles, image libraries, personal devices and outside access.
- Update your online safety procedures and expectations. Say which devices and accounts people can use, what information can appear with an image, how children can opt out, how long images are kept and how to report a concern.
- Control the use of AI tools. Staff, volunteers and suppliers must not upload children’s images to AI, face-editing, background-removal or image-enhancing tools unless your organisation has checked and approved the tool. Use our digital checking tool to help make decisions about this and read our guidance on responsible use of AI in youth sports. Use our AI safe use policy template.
- Put the rules in contracts with photographers. If using photographers or videographers, make sure they meet your rules and expectations. Do not allow them to use children’s images to train AI or create new images. They must report any loss or misuse straight away.
- Train all staff and volunteers. Staff, volunteers, coaches, photographers and communications teams should practise how to respond, who to contact and when to call the police.
- Make reporting easy. Give children and adults simple ways to raise a concern. Include out-of-hours contacts and explain when to tell the national governing body. The NSPCC Helpline can also be contacted for advice and support or the Internet Watch Foundation have a reporting form that can also be used. See below for what to do when you discover an image has been misused.
- Check and improve data protection. Review permissions, the legal reason for using images, account access, and incidents at least once a year and after a major change or concern.
AI technology, safeguarding risks and legal frameworks continue to evolve. Review your policies and procedures regularly: at least every 12 months or after a major change in legislation, an incident or emerging risk.
2. Be careful when taking and using photos of children
- Check if you need the image. Before taking a photo or video, be clear about why you need it. Check whether you could use an image that makes the child harder to identify. It’s quite difficult to remove all traces of your sports club from images, but you can use action shots, backs of players or group photos that focus on the activity, where suitable. Illustrations or graphics could also be used. Avoid close-ups, poses that could be taken out of context or revealing clothing.
- Follow data protection law and ask permission. Tell children and their parents or carers what you will take, why you need it, where you will share it, who may see it and how long you will keep it. Always ask the child if they’re happy to be photographed, even if the parent has given permission. A child or parent agreeing to have their photo taken and used doesn’t mean they’ve agreed for that image to be changed or used with AI tools. Tell families, spectators, journalists and photographers what they can and cannot do at events. Have a private way to protect children who must not be photographed.
- Share as little information as possible. Do not publish a full name, fixture location, club name, travel plans or training time with an image. It’s hard to remove all information but publish as little as possible.
- Use approved systems. Do not keep images on personal phones, personal messaging apps or personal cloud storage. Only give access to people who need it. Remove access when their role ends.
When it comes to editing photos that feature children, think about whether the changes are improving the picture or changing the child. Edits like adjusting lighting, colour or sharpness are generally lower risk because they improve image quality. But changing an image of a child is not low risk and organisations should avoid altering a child's appearance or using tools that create new content from the child's image.
Before editing, make sure you understand what your software or app does by default and where the image is saved.
If you discover an image has been misused
Act quickly and calmly. Children may feel embarrassed, anxious, scared or worried about who has seen the image and what might happen next. Alongside taking safeguarding action, provide reassurance and appropriate emotional support. Only share information with people who need to know. Put the child’s safety and wellbeing first.
- Keep the child safe. Call the police if the child is in immediate danger. Tell your safeguarding or welfare lead straight away. Reassure the child that this is not their fault.
- Do not make another copy. Do not download, save, print, forward or screenshot a suspected sexual image of a child. Do not put it in an email, case record, presentation or staff chat. This creates a “copy” and could be interpreted as production of the material, which is a criminal offence.
- Write down safe details. Record who raised the concern, when they found it, the website or platform url address, the account name, and any threats or contact. Record any actions already taken.
- Protect possible evidence. Keep useful account logs, messages, publishing records and access details. Do not delete or change them before getting advice. Only let the people dealing with the incident see them.
- Report it. Report suspected online child sexual abuse material to the police and the Internet Watch Foundation. Report it to the website or platform on which it appears. Follow any reporting rules set by your governing body.
- Help the child ask for removal. Children and young people in the UK can use Childline’s Report Remove tool. Help the child to use it, but do not take over their account or make a copy of the content.
- Choose one person to lead the response. This person should keep in touch with the child and family, police, national governing body, data protection lead and communications team. Protect the child’s identity and avoid public statements where you can.
- Check whether the image came from your systems. If it may have come from your account or device rather than a public platform, tell your data protection leads straight away. Check whether you need to tell the Information Commissioner’s Office or the people affected by the breach.
- Keep supporting the child. Where you can, involve the child in decisions about next steps and tell them what is happening. Agree together how you’ll support their wellbeing, manage other children’s behaviour, deal with online contact, remove their photos and handle communications. Signpost the child and family to Childline, who can provide counselling and support. The NSPCC Helpline can also provide the family with advice about keeping their child safe.
For more guidance on using images of children in sport, read the rest of our photography and filming guidance.
Frequently asked questions about AI and children’s images in sport
Should sports organisations stop using photos of children?
Most organisations do not need to ban all photos of children. Images can celebrate children taking part and help families understand an activity. Use fewer, carefully chosen images for a clear reason. Focus on the activity rather than the child. Delete images when you no longer need them. Do not share an image if you cannot manage the risk or the child doesn't want you to use it.
Should organisations ban Meta glasses (or other wearable cameras) when people are working with children?
Limit the use of smart glasses that have a camera. You may not need to ban people from possessing or wearing them in every setting, but the same rules for phones and cameras should apply. Nobody should use them in changing rooms, toilets, overnight accommodation, or other private places. The Information Commissioner’s Office says organisations should look at why, where and how smart glasses are being used, rather than treating all uses as safe or unsafe.
Does this advice apply to older children in mixed-aged sports?
Yes. Young people aged 16+ can be more visible online because they may compete in mixed-age competitions, appear in player profiles, feature in media coverage or use social media themselves to promote their sporting achievements. Sports organisations should take a proportionate approach, while remembering that the same safeguarding and legal protections apply to all children under 18.
Can staff use AI tools to edit or improve photos of children?
Editing photos to improve lighting or image quality may be appropriate where the tool has been assessed and approved by your organisation. Avoid using tools that alter a child's appearance, generate new content or retain images for AI training. Uploading a photo may send it to another company, make extra copies or allow the company to use it for training AI.
Does blurring a child’s face make an image or video safe to publish?
No. A child may still be identified by their name, voice, kit, club badge, location, body, mobility aid, result or the people around them. The image may still be changed using AI.
Further guidance