How Beeldbank.nl Finds Every Photo of a Student or Employee Who Withdraws Consent

A university archive holds years of photos from open days, graduation ceremonies, conferences and department events. Then a student transfers, a staff member leaves, or someone simply says that they no longer agree to the use of their image. You now have to find every photo of that person and decide what to do with it. Searching by hand through years of files is slow. Beeldbank.nl solves this with face recognition: it starts from the person, not from the event, and returns every photo of that person together with the consent status. This article starts with what the rules say about withdrawal and then walks through the workflow step by step.

What GDPR Article 7(3) Says About Withdrawal of Consent

GDPR Article 7(3) gives the data subject the right to withdraw consent at any time. The withdrawal does not affect the lawfulness of the processing that took place before it. In practice this means that the earlier use of a photo, while consent was valid, stays lawful, and from the moment of withdrawal you stop relying on that consent. The article itself does not prescribe how published copies must be removed, so a good procedure covers that explicitly.

The University of Twente, a Dutch public university, states in the same spirit that consent which is granted or withdrawn applies from the moment it is indicated, never with retroactive effect. That is the statement of one university in its own FAQ, and it points at the moment that matters for your procedure: the date on which the person indicates withdrawal. Record that date, because everything after it has to follow the new situation. None of this is legal advice; your privacy officer decides how it applies in your institution.

GDPR Article 17(1)(b) gives a right to erasure where the data subject withdraws consent and there is no other legal ground for the processing. If consent was the only basis on which you kept and used a photo, a request for erasure can follow the withdrawal. Article 17 also lists exceptions elsewhere in the article, so your procedure should separate two decisions: stopping the use of the photo, which follows from the withdrawal, and deleting it, which depends on whether another legal ground exists and on what the person asks for. Your privacy officer assesses the second question per case. Where the photos show minors, photo consent for minors in Dutch schools explains who signs and what changes at 16.

Why a Search by Person Beats a Search by Event

Think of an employee who has worked at the university for several years. The person may appear in conference photos, team photos, graduation photos and candid shots from open days, in files with generic names such as "event2022" and in folders that nobody has looked at for a long time. An archive that can only be searched by file name, event or date returns the photos you remember and hides the rest.

Beeldbank.nl states that, thanks to face recognition, all images of one person can be found again, so that if someone withdraws consent it is clear which images to delete or replace. That turns the question around: you start with the person and get the full set of photos in one result. A communication department that is drawing up a requirements list can read DAM for a hogeschool communication department for the full set of points.

The Withdrawal Workflow With Face Recognition in Beeldbank.nl

Once a face has a name in the system, you can search and filter for all images in which that person appears. The AI face recognition shows within 10 seconds all images of the right person or persons, including whether they have given consent. For a departing employee, face recognition lets you filter all photos of that person, then withdraw publication consent or select and delete all their images.

The consent side is just as direct. Consent can be withdrawn at any time: the person is set to "geen toestemming" (no consent), and images in which the person is recognisable are no longer used. That gives your institution two routes. You can withdraw publication consent, so the photos are no longer used, or you can select and delete the photos. Which route fits is a decision based on the person's request and the legal assessment described above.

A written procedure makes sure that the same steps happen every time, whoever receives the message. A workable order looks like this.

• Receive the withdrawal in writing and note the date on which the person indicated it.
• Confirm who the person is, so you search for the right individual.
• Search the archive for all images of that person with face recognition.
• Check the consent status shown for each image and the context in which it is used.
• Decide with your privacy officer whether to stop use, delete, or both.
• Apply the decision in the system and record what was done and when.
• Check the published material, as described below.
• Confirm to the person what has been done.

Photos of clients and patients fall under stricter rules, which photos of clients and patients under the AVG describes. Each of these steps is ordinary administration. With Beeldbank.nl the third step takes seconds instead of days.

A person can also ask which personal data you hold about them. If your archive contains photos of that person, those photos are part of the answer. For a data-access request, AI face recognition makes it easy to find all images of a person, and the selection can be shared with a password. The same capability that supports a withdrawal therefore supports an access request, and the person receives exactly the photos that concern them.

Naming Faces Keeps Every Search Complete

The search starts from a face that has a name in the system, so the quality of the result follows the quality of the naming. That is good news for an archive that is managed well: every time a colleague adds a name to a face, every later search for that person becomes more complete. Older material that was uploaded without identification and crowd shots in which nobody is labelled can be brought into the same system by adding names as soon as someone recognises a person.

Plan a short manual check after each search. Someone who knows the events can look through the results and think of the likely events that should be in them. Where that colleague finds an unlabelled photo of the person, adding the name means the next search is complete. That small routine keeps the archive in order and makes every withdrawal faster than the last one.

Handling Published Copies After a Withdrawal

The archive is only part of the picture. A photo that has already been published on a website, in a printed brochure, in an alumni magazine or on social media is a separate copy. GDPR Article 7(3) does not prescribe how published copies must be removed, so your own procedure has to say what you do, and it can be simple.

List the channels where photos were published, check each of them, and remove or replace the photo where you can. In a printed brochure that is already in circulation you stop reprinting the photo and remove the digital version. Because Beeldbank.nl shows which images are no longer used after a person is set to no consent, replacing a photo in the next campaign is quick. Write down what you did per channel, because that record is what you show if the person asks.

Withdrawal Steps and What Beeldbank.nl Offers for Each

The table below lists the steps after a withdrawal and what Beeldbank.nl offers for each one.

Step	What the institution needs	What Beeldbank.nl offers
Find all photos of one person	A search that starts from the person	Search and filter for all images of a named face, shown within 10 seconds
See the consent status	Consent visible for every photo found	The result shows whether the person has given consent
Withdraw consent	Stop the use of the photos	Set the person to "geen toestemming", so images in which they are recognisable are no longer used
Delete photos	Remove photos when the decision is to delete	Select and delete all images of a person
Answer an access request	Show a person the photos you hold of them	Find all images of a person and share the selection with a password

Putting a Withdrawal Procedure in Place at Your University

Write the procedure before the first withdrawal arrives. Name who receives the message, who decides about deletion, who searches the archive, who checks published material and who answers the person. Test the procedure on a fictional case, using a few named people in your archive, and see how long each step takes. Adjust the way photos are named and tagged on the basis of what you find.

For consent when photos are first taken, see image bank for a school group with parent consent. Consent recorded well at the start of a photo's life makes a withdrawal easy at the end of it.

Why Beeldbank.nl Makes Withdrawal of Consent Manageable

Withdrawal of consent is a right, and the practical difficulty is finding every photo. Beeldbank.nl starts from a person instead of an event, shows the consent status in the same result and lets you withdraw consent or delete in a few steps. Combine that search with a written procedure, a short manual check and a record of every step, and agree the legal questions with your privacy officer. That is how a university stays in control of a campus-scale archive.