Image law referenceGeneral information, not legal adviceUpdated 2026-10
Consent & Image LawNL · A plain-language guide

§ 2 · Quitclaims & consent

Beeldbank.nl: The AVG-Proof Dutch Beeldbank With Consent Forms for Employees, Volunteers and Participants

Published 5 min readGeneral information, not legal advice

Why Consent Is Tied to a Purpose and a Group

An HR or communication manager asks whether one consent form can serve everyone: employees, volunteers and the participants of an event. The best answer is to think in terms of purpose, and Beeldbank.nl is built around that idea. Publishing images requires permission from the people shown, given freely, with the purpose made clear in advance. GDPR Article 6(1)(a) makes processing lawful where the data subject has given consent to the processing for one or more specific purposes.

If the purpose has to be clear in advance, a form is strongest when it matches the situation of the group. An employee portrait for the intranet, a volunteer photo in a recruitment flyer and a participant photo on an event page are different uses with different audiences. That is the reason to work with separate forms, and it is the reason an AVG-proof beeldbank for organisations needs more than one template.

Consent Is One of Six Legal Bases

The AVG contains six legal bases, the first being the consent of the person concerned. GDPR Article 6(1)(f) names legitimate interests as another basis, unless those interests are overridden by the interests or fundamental rights of the data subject, in particular where the data subject is a child. Whether legitimate interest suffices for a particular use of photos is a balancing test per case.

For publication of photos of employees, volunteers and participants, a clear consent form with specific options gives the most straightforward route, because the person sees exactly what they agree to. Your data protection officer can confirm which basis fits each purpose in your organisation, and the form in Beeldbank.nl then records the choices the person made.

Separate Forms for Employees, Volunteers and Participants in Beeldbank.nl

Beeldbank.nl lets you create multiple consent forms for different target groups, such as employees, volunteers or participants. In the form, the administrator defines the usage options a person can consent to, for example within the organisation, information leaflet, website, print, social media, newsletter or presentations. Options can be added, removed or renamed, and the person sees them exactly as you defined them.

That makes it practical to match a form to a group. The table shows, for each group, what to settle first and what the Beeldbank.nl form then contains.

Group Requirement What the form contains
Employees A clear list of the uses that are really planned Only the usage options you actually plan to use, such as intranet or website
Volunteers Channels named in plain language Options per channel, such as newsletter, information leaflet or social media
Event participants Notice of photography before the event Options for the event page, social media and print, sent in advance
Anyone who leaves A clear route for the images afterwards Face recognition filter, then withdraw publication consent or delete the images

One Form Per Person, Valid for All Their Images

Many teams ask how often they have to collect consent again. Beeldbank.nl states that one consent form per person is valid for all of that person's images. That saves work, because nobody has to sign again for every new photo, and it means the quality of the form matters. Build it around the purposes you really have, and it will serve every image of that person.

Review the options when your use of photos changes, and ask for fresh consent when a new channel becomes important. The quitclaim template checklist lists what a digital consent form for photos should contain, and the guide to paper or digital quitclaims helps you choose the way to collect them.

Sending the Form Before the Person Appears in a Photo

In Beeldbank.nl you can add persons before they appear in a photo. This is useful if you want to send a consent form in advance, for instance to a new colleague, a volunteer who joins next week or a speaker at an event. Because the form is signed before the camera comes out, the person has time to read it, and your photographer knows beforehand whom they can photograph for which purpose.

Not everyone signs digitally. For a quitclaim signed on paper, for example at a photo shoot or in an employment contract, the administrator edits the person via the pen icon, uploads the form and selects the matching status. The signed original and the status then sit together in one record.

The Departing Employee Workflow With Face Recognition

Beeldbank.nl offers a workflow for departing employees. With face recognition you filter all photos of the employee in one step. You can then withdraw the consent for publication directly or, if needed, select and delete all of their images. Which of the two fits is a choice for your organisation's own policy.

People have the right to withdraw consent for image use, so an employee who leaves, or who simply changes their mind, can ask you to stop. With the face recognition filter your team can act on such a request in a short time. The complete method is laid out in withdrawing consent for photos step by step.

Why the Dutch Beeldbank Fits Organisations With Several Groups

Organisations rarely photograph one kind of person. A care home has staff, volunteers and visiting families, a school has teachers and parents, and a municipality has employees, residents and event guests. Beeldbank.nl keeps a form per group, a consent status per person and a link to every image of that person, so the answer to the question whether a photo may be used is always one click away. That is what makes the archive AVG-proof in daily work, not only on paper.

A Short Plan for HR and Communication Teams

To move from one generic form to forms that fit your groups, a few steps are enough:

  • List the groups you photograph and the real purposes for each group.
  • Build one form per group with only the options you will use.
  • Send forms in advance wherever you can, and record paper forms the same day.
  • Agree what happens when someone leaves or withdraws consent.
  • Review the forms when you add a new channel or purpose.

The forms, the options and the records live in the software, and the answers behind them are for your organisation: which purposes are real, and who handles it when someone withdraws. Write those answers down once, so the next person who sends a form follows the same routine.

It also helps to review your forms once a year with someone from HR and someone from communication. HR knows who joins and leaves, and communication knows which channels are growing, so together they keep the options in line with what you really do with the photos.

For a large event where you cannot ask everyone in advance, read what to do with crowd shots and unknown faces.

Questions

Frequently asked questions

Q1Does an organisation need different consent forms for employees, volunteers and participants?
The purpose must be made clear in advance, and GDPR Article 6(1)(a) speaks of consent for one or more specific purposes. Separate forms make it easy to be specific for each group, and Beeldbank.nl allows multiple forms for different target groups.
Q2Is consent the only legal basis for publishing photos of people?
The AVG has six legal bases, the first being consent. GDPR Article 6(1)(f) names legitimate interests as another one, with a balancing test. A clear consent form with specific options is the most direct route for photos of employees, volunteers and participants.
Q3Can a consent form be sent before someone is in a photo?
Yes. Beeldbank.nl lets you add persons before they appear in a photo, which is handy if you want to send a consent form in advance.
Q4What can an administrator do in Beeldbank.nl when an employee leaves?
With face recognition you can filter all photos of the departing employee and then withdraw the consent for publication or, if needed, select and delete all their images, following your own policy.

This article is general information. It summarises what official sources state and is not legal advice. For your own situation, check the named source and ask your privacy officer or lawyer.