TL;DR for the DPO
Principle from the Italian DPA (newsletter 17/6/2026): publishing a minor's images on social media requires both parents' consent (shared parental responsibility); one parent's dissent blocks publication. For bodies handling minors' images the practical consequence is: double-signature consent forms and a procedure for withdrawals and disagreements.
The three points that matter
- Parental responsibility is shared: one parent's consent is not enough, and the other's dissent prevails. This applies to the school's social profile exactly as to mum's or dad's.
- The scope is wider than social media: school and sports events, recitals, summer camps, newsletters and websites - wherever the child's image becomes 'publication'.
- Typical practices to fix: release forms signed by one parent only, 'lifetime' consent collected at enrolment, no withdrawal procedure, WhatsApp/social groups where photos circulate unchecked.
What to do now, in practice
For schools, nurseries, sports clubs and clients publishing minors' images: 1) DOUBLE-signature forms (or a declaration of acting with the other parent's consent, at the signer's responsibility); 2) granular consent: website, social media, promotional material as separate items; 3) a written procedure for withdrawal and later disagreement (who removes, within what time); 4) training for whoever runs the organisation's social channels.
Why it matters for your clients
It is one of those principles that generates concrete, immediate work for the DPO: almost every organisation dealing with minors has single-signature forms. Updating them is a quick, visible, easily explained fix - and it prevents both parental complaints and trouble when family conflicts arise.
Official source:Italian Data Protection Authority - newsletter of 17 June 2026Looking for a workspace for your DPO work?
DPO Workspace is built by a certified DPO. 30-day free trial.
Start free
