Use of images and voice by Utrecht University

Audiovisual material (such as portrait photos, atmospheric images, podcasts, films and reports) is a natural part of our world. As a visitor of the Utrecht University (UU), you may be recognizable in this material. It is important that you’re aware of this. Perhaps it is the reason you’re reading this webpage.  

This pages describes three subjects: 

  1. What we do with audiovisual material. 
  2. Why we do that. 
  3. What you can do when you disagree.  

First a few basics: 

When you’re identifiable in material, it is personal data. When an organization uses personal data, the organization must have a so-called legal basis. A legal basis is a legal approval to do what this organization would like to do. What it wants to do is called the processing purpose. The retention period is how long the data is needed for this. Because the data concerns you, you are referred to as the data subject. As a data subject, of course you have rights. You can read more about your rights at the bottom of this page. 

Legitimate interest 

Legitimate Interest is a legal basis. It is very important for the UU to use audiovisual material. That’s why we’ve carefully examined what is legally allowed. But more importantly what we consider to be ethically correct. The result is that we’re allowed to use audiovisual material: 

  • for the processing purposes below; 

  • in the publication formats below; 

  • with the usage and retention periods mentioned below. 

Even though we have Legitimate Interest as a legal basis, if you don’t want to be recognizable in audiovisual material, you don’t have to. On site, you can always refuse having a picture or film taken from you.  

Processing purposes  

Material may only be used if it serves one or more of the following purposes:    

  1. to attract potential staff and students.  
  2. to promote the university’s public spaces (such as University Museum Utrecht or Botanical Gardens).  
  3. to build UU’s image and reputation within both society and academia.  
  4. to decorate UU’s buildings.  
  5. for publications of relevance to society. This means news reporting or academic forms of expression, such as scientific publications. 

The exceptions to this are: 

  • We won’t publish on the legal basis Legitimate Interest if it pertains to sensitive topics. 

  • We won’t publish if it could have a detrimental effect on individuals. 

  • We won’t publish if it is not relevant to the content of a publication.  

Publication formats  

To achieve the processing purposes, we may publish the material both online and offline. For the first four processing purposes, the material may be published in any of the following formats:   

  1. newsletters and magazines, both internal and external, both digitally and in print.  
  2. websites encompassed by the uu.nl domain. 
  3. UU Intranet.  
  4. social media channels belonging to UU (LinkedIn, Twitter, Facebook, YouTube, Instagram, etc.).  
  5. reports, books and journals.  
  6. paid content/academic advertorials*.  
  7. flyers and brochures.  
  8. posters and signs in UU buildings or at UU events.  
  9. Invitations.  
  10. information screens in UU buildings.  
  11. advertisements.  

For processing purpose five, ‘Publishing of relevance to society’, the material may only be published in formats one-seven. The material may be stored in UU’s image database for the retention periods specified below.   

Usage and retention periods  

It is not easy to determine the usage and retention period.  

We are balancing between what is acceptable to you and what is minimally necessary for us. After all, we want to avoid having no suitable audiovisual material available. Based on this dilemma, we’ve arrived at the following usage and retention period: 

For most audiovisual material, the usage and retention period is set at five years and one month. 

An exception to this is material on which you feature alongside a public person who visits UU in a professional capacity (e.g. an actor, secretary of state, mayor or famous scientist). Because these are usually special moments, the usage and retention period is ten years. 

At the end of its usage and retention period, material of historical relevance will be selected for archiving. Material with historical relevance include, for example, the opening of a new building, characteristic atmospheric images of a certain time, nominations of prominent persons and events. We may keep historical material in our archive forever. Access to the archive is reserved for a select group of employees, making use of this material more tightly controlled. The material is also used for far fewer processing purposes, namely only for use in the context of our university’s history or for publications of relevance to society. 

Rights 

The above sets out what kind of things UU is entitled to do with audiovisual material. We have tried to find a good balance and to explain this clearly. However, we may have missed something. For general questions and comments you can always contact us via ubd.cm.privacy@uu.nl. 

If we cannot reach agreement in an informal manner, then you always have the option of invoking your formal rights. You have the following rights under the GDPR: 

  • Right of access by the data subject; 

  • Right to rectification; 

  • Right to restriction of processing; 

  • Right to object; 

  • Right to erasure ('right to be forgotten')*, on the proviso that the objection is sustained. 

As these are statutory rights for which the GDPR also sets requirements, we may ask you to invoke your rights in accordance with https://uu.nl/privacy bullet 9.