Why Total Photo Bans in Early Childhood Hurt Children More That They Help - CTRL SHFT

Across Australia, more and more early childhood services are quietly shutting their lenses. No images sent home. In some centres, every photograph is deleted before the end of the day. A child may have built a bridge out of blocks or climbed something they never dared to climb before, but the moment is gone, undocumented, unshared, unseen by the people who love them most.

One parent told me they now arrive at pick-up 15 minutes early to sit beside an educator and view images of their child on a shared iPad, photos that are deleted while they watch. No copy sent, no memory kept. “It’s what we were told to do,” the educator now burdened with image curation explains. Not because of a complaint. Not because of risk but because someone in management misread a regulation and decided erasure was safer than understanding.

But what they were told isn't what the law says. And it certainly isn't what children need.

Here’s what the law actually says: photos can be taken and shared with families, as long as there is informed consent. That’s not a permission slip buried in enrolment paperwork. That’s not silence mistaken for agreement. Real consent is specific, updated, and respected. Families have the right to know where an image is stored, for how long, and who will see it. And once a photo becomes part of a child’s learning record, it’s no longer optional; it’s required.

Regulation 181 of the National Regulations mandates that all personal information, including images, must be kept confidential and shared only with the proper authority. Section 175 of the National Law makes it an offence to destroy required documentation. That includes portfolios. That includes photos. Those photos must be kept for up to three years (depending on the jurisdiction) after a child leaves the service. Deleting them out of fear or confusion isn’t just unnecessary. It could be non-compliant.

Under the National Quality Standard, services are required to protect children from all forms of harm, including digital harm. That’s not an abstract risk. It means no photos on personal phones, no smartwatches snapping images on the sly, no glasses with cameras built in them left out of policy, no USBs shuttling pictures home. Only service-issued devices provide the audit trail regulators now expect.

Many services are making the same mistake: they are treating secure family communication platforms like social media. They are not the same.

Yes posting a photo of a child on Facebook or Instagram is an issue.

Sending it to a parent through a risk-reviewed, secure, auditable, consent-based, and compliant app is fine.

The safe platforms are built for this purpose.

They require logins, encrypt data, and maintain audit trails. They are aligned with the Privacy Act, the Online Safety Act, BOSE & Industry Codes and the National Regulations.

Dismissing them strips families of one of the few windows into their child’s day.

On September 1, 2025, the National Model Code for Taking Images and Videos of Children came into effect. Cue panic. But the panic was misplaced.

The Code is not legislation. It’s voluntary guidance, designed to help services lift their game before legal changes arrive. The Code recommends the use of only service-issued devices. It advises against using personal phones or smartwatches (and new smart glasses, such as Ray-Ban Meta Smart Glasses, should be included) during supervision. It calls for secure storage and communication systems.

What it does not do is mandate blanket bans. It does not require faces to be blurred or cropped. It does not demand that photos be deleted daily. In fact, the Code says plainly that photos and videos play a role in building family connections and supporting children’s learning. The problem isn't the Code. It’s how people misread it.

The Early Years Learning Framework has always valued reflective documentation. In its latest version, that hasn’t changed.

Photos help track learning over time, engage families in the process, and give children a sense of identity and belonging. A toddler pointing proudly to their painting. A moment of focus, joy, curiosity. These are not moments to erase. They’re moments to protect. When we delete every image, we don’t protect children. We erase their stories. And we deny them the right to see themselves as learners.

The real risk here isn’t the camera. It’s the policy written in fear by someone that doesnt fully understand or know what they don't know. Too many services are copying templates written by GPT, or drafted by people with only a superficial understanding of one section of child safety. Some haven’t read the legislation. Others don’t understand the technology. Most haven’t done a proper risk assessment or stakeholder interviews, nor do they know how to. And it shows.

Policies are being written based on opinion, not law. Based on myths, not regulations. Based on a single concern without considering the broader responsibilities services have to document learning, engage families, and support children’s development. A good policy doesn’t just say “no photos.” It balances rights and risks. Miss even one of the pieces, and the policy may fail, no matter how well-intentioned it was.

Children deserve to be seen. Families deserve connection. Educators deserve clarity.

Blanket photo bans serve none of these.

The National Quality Framework wasn’t built to hide children’s learning. It was built to protect it thoughtfully, respectfully, and in full view of families.

It’s time to stop letting panic write policy. Time to stop treating secure apps like threats. Time to stop deleting evidence of a child’s growth because someone in a meeting got nervous.

Write policy like it matters — because it does. Understand the tech, the questions that need to be asked of providers and stakeholders. Ground it in best practice and law. Reflect it in practice. And make it serve the people who need it most: the children and their proud parents and carers remain at the heart of every photo.

If you need assistance or advice, please reach out to hello@ctrlshft.global for a confidential discussion on how we can help with your compliance strategy.

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