How we use photos and video at Wakehurst.
We take photos at matches, training days, and club events. We're proud of what our families do on and off the field โ and we want to share it. This policy explains exactly how we use those images, what technology we use, and how you stay in control.
What we capture
Wakehurst Rugby Club takes photographs and video at the following club activities:
Photos and short video clips during games, warm-ups, and post-match. Taken by club-appointed photographers, volunteer team managers, or parents contributing through our photo submission portal.
Annual team and individual photos by a professional photographer. Used on the website, in club communications, and as the primary seed for our face-recognition library.
End-of-season presentations, the 60th Anniversary celebrations, volunteer events, and community activities at Wakehurst Rugby Park.
Occasional training photos for coaching purposes and club promotion. We do not photograph changing rooms, toilets, or private spaces โ ever.
How consent works
We use a comms-and-opt-out model for photos of club activity. This means:
- Photos of club activity (matches, training, events) are taken and used for club purposes by default โ this is standard practice for community sports clubs.
- You can opt out at any time โ for yourself or for your child. We'll update your record and stop using your images in new publications. We'll also remove your tagged images from member-visible areas on request.
- The legal basis for this is legitimate interests under Australian Privacy Act 1988 โ the club has a legitimate interest in documenting and sharing its community activities, balanced against your right to opt out.
For face recognition specifically, we use a stricter model โ explicit opt-in. We do not run face recognition on any player unless a parent or guardian has given active consent. No default. No assumed consent.
Face recognition
We use AWS Rekognition โ Amazon's face-recognition service โ to automatically match players across photos. This is what allows us to say: "These 47 photos from 2019 to 2025 are all of the same player."
What it does
- A seed photo (typically a team photo) is indexed against the player's name and member ID.
- Rekognition then searches our photo library โ thousands of match-day photos โ for faces that match the seed.
- Matches are flagged for human review. A committee member confirms or rejects each suggestion before any tag is attached to a player's record.
- Confirmed matches appear in the player's /myclub member portrait โ their personal career photo library.
What data is stored
- A face vector (mathematical representation) โ not a photo. Rekognition converts a face into a set of numbers (a "feature vector") that can be compared against other vectors. The original image is not stored inside the Rekognition system.
- The face vector is stored in a Rekognition Collection hosted in the AWS ap-southeast-2 (Sydney) region โ Australian data residency.
- The member ID associated with each vector โ so a match can be linked back to a named player in our system.
Who can see face-matched photos
- The player themselves and their parent or guardian via /myclub (authenticated by magic link โ no public access).
- Club administrators with a committee-level login.
- Photos are not publicly searchable by face.
How to opt in
Email privacy@wakehurst.rugby or speak to your team manager before photo day. We'll note your consent in your member record and include your child in the face-matching run after team photos are taken.
Children & minors
Most of our members are children. We take their privacy seriously and apply age-appropriate controls.
All consent decisions โ photos on website, photo notifications, face recognition โ rest with a parent or guardian. Children under 13 have no independent consent standing. If both parents have conflicting instructions, the more restrictive preference applies.
From age 13, players receive their own /myclub login and can view their record, but consent decisions still require parental confirmation. The player can flag that they want to change a setting โ but the change doesn't take effect until a parent confirms it.
From age 15, players can set and change their own privacy preferences independently. Parents retain read access to the record but no longer control consent. This reflects the NSW law position on children's capacity to consent (consistent with the Privacy Act and Children's Guardian guidance).
At 18, the member record converts to an adult account. Parents no longer have access. The member controls all consent and data preferences directly.
Historical photos
Wakehurst is building a 60-year photo archive. Many of these photos were taken before digital privacy frameworks existed โ typewritten team lists, scanned newsletters, black-and-white match-day prints from the 1970s and 1980s.
We apply the following consent model to historical content:
- Pre-2001 photos are treated as club archive material (
archive-impliedconsent). They are preserved as historical records. We will not publish individual members' faces prominently without consent, but group/team photos are treated as club heritage. - Post-2001 photos follow the standard comms-and-opt-out model โ included by default, opt-out on request.
- Face recognition on historical photos requires the same explicit opt-in as all other face matching. A life member who wants their 1984 season photos found and linked to their member portrait needs to opt in.
If you are a former player or life member and have photos you'd like to contribute to the archive โ or if you appear in historical photos and would like to be identified โ contact us. Contributions go through our photo submission portal and our Our Story form (coming with /myclub).
How to opt out
All opt-out requests are handled within 5 working days. We'll email confirmation when your record has been updated.
Send your request to privacy@wakehurst.rugby. Include your name, your player's name (if opting out on behalf of a child), and what you'd like to change. You don't need to give a reason.
Open pre-filled opt-out email โYour team manager has a direct line to the committee privacy contact. They can submit a preference update on your behalf before or on photo day.
The self-serve member portal will allow you to manage all preferences in one place โ without emailing us. Expected: mid-2026 season.
What happens when you opt out
- Your member record is updated immediately with your new preference.
- New photos will not be published on the website with you prominently featured.
- Existing published photos: we'll remove identified/tagged images from member-visible pages. Group photos where you appear incidentally (crowd, sideline) may remain as club records unless you specifically request their removal.
- Face recognition opt-out: your face vector is deleted from the Rekognition collection within 5 working days. No new matches will be made. Existing confirmed matches are removed from the member portal.
- Photo notifications stop immediately on opt-out.
Data storage & security
Photos โ Microsoft SharePoint
All club photos are stored in a private SharePoint document library accessible only to committee administrators. SharePoint is part of Microsoft 365 โ data is stored in Microsoft's Australian datacentre region (Sydney and Melbourne).
Microsoft 365 is ISO 27001 certified and compliant with the Australian Privacy Act. The club uses a Not-for-Profit (NFP) licence โ data is not used by Microsoft for advertising or AI training.
Face vectors โ AWS Rekognition
Face feature vectors (mathematical representations โ not images) are stored in an AWS Rekognition Collection hosted in the ap-southeast-2 (Sydney) region. Data does not leave Australia.
Vectors are deleted immediately on opt-out request. We do not share Rekognition data with any third party.
Website โ Azure Static Web Apps
The public website (www.wakehurst.rugby) is hosted on Microsoft Azure Static Web Apps โ free tier, Australian edge. Photos displayed on the public website are web-compressed copies served from SharePoint CDN.
The website collects no cookies beyond what's strictly necessary for navigation. No analytics without consent. No advertising trackers.
Access controls
Only committee administrators with a verified Microsoft 365 account can access the full photo library. Member portal (/myclub) access uses one-time magic links โ no stored passwords.
All admin access is logged. The committee reviews access logs quarterly.
Retention: Photos of club activity are retained indefinitely as part of the club's historical archive. If you request removal, your images are removed from public and member-visible areas within 5 working days. The original file may be retained in the private archive unless you specifically request full deletion.
Contact & complaints
Questions, opt-out requests, corrections, or complaints about how we've handled your data โ contact us directly. We take every query seriously.
Privacy contact
All privacy and media queries go to our committee privacy contact, who is a named committee member โ not a helpdesk.
privacy@wakehurst.rugbyResponse within 2 business days. Opt-out requests action within 5 working days.
External regulator
If you're not satisfied with our response, you can lodge a complaint with the Office of the Australian Information Commissioner (OAIC), who oversees the Privacy Act.
OAIC Privacy Complaints โ1300 363 992 โ Monday to Friday 9amโ5pm AEST