Zara Smith, Writer and Editor

A new piece of UK-wide guidance, Image guidance for education settings published by the UK Safer Internet Centre (UK SIC) developed with the UK Online Harms Early Warning Working Group (EWWG), has been produced to help education settings protect children when photos and videos are shared online, in light of a growing risk from AI tools that can manipulate images. It was prompted by real cases where criminals have taken ordinary school images from websites or social media and used AI to create sexualised or abusive content, sometimes as part of blackmail attempts. Although it is written with schools in mind, the core messages are highly relevant to childminders, who also share children’s images on websites, Facebook pages, WhatsApp, learning journals and advertising. 

The central idea is not stop using images altogether but treat images as sensitive data and minimise risk. The guidance encourages settings to review what images they share, where they share them, how they store them and how they respond if something goes wrong. As a childminder, you are both the responsible person and the designated safeguarding lead, so this guidance effectively becomes your personal checklist and decision-making tool.

Key risks the guidance highlights

The guidance brings together several emerging risks linked to AI and image sharing in education:

• AI manipulation of images (deepfakes): AI tools can now convincingly change faces, expressions or clothing, or create entirely new images that look real but never actually happened.
• Use of setting images as source material: Reports show offenders taking images of pupils from setting (including schools) websites and social channels and using them to create sexualised content or to attempt blackmail.
• Peer-on-peer misuse: Young people themselves are sometimes using AI to create nude or semi-nude images of peers, which is treated in law as child sexual abuse material (CSAM) if it involves anyone under 18.

For childminders, this means that even an innocent photo from a trip to the park, shared publicly with your business name and local area, could be copied and misused by someone you will never meet. The risk is still relatively low but serious enough that national bodies have updated image guidance specifically in response.

What this means in practice for you as a childminder

The school-focused guidance suggests a series of practical steps that translate well into a childminding context. The main steps:

1. Review where you share images
   Review all the places where you currently use children’s photos such as Facebook, Instagram, your website, Google Business listing, online adverts, learning journals and WhatsApp groups with parents. For each one, consider whether identifiable images of children are truly necessary. Where possible, move towards more private, controlled channels (for example, secure learning journals or direct messaging to individual families) so that children’s images are only shared where there is a clear purpose, strong consent and limited, well‑managed access.
2. Reduce how identifiable children are
   Use photos where faces are turned away, blurred, or obscured by hats, play equipment or distance, especially for anything public facing like adverts or websites. Avoid images that clearly show faces, names, school logos or recognisable landmarks together in one shot in public spaces online.
3. Tighten your consent and information with parents
   Update your photo/video consent form so it explains that images could, in theory, be copied and misused with AI tools, and that you are taking steps to reduce that risk. Give parents clear options: for example, consent for private learning journal only; consent for group photos within closed parent groups; consent (or not) for use in advertising.
4. Control access and storage
   Treat photos and videos as personal data under UK GDPR. This means that you should store them securely, on password-protect devices and cloud accounts, and back up only to reputable services. Additionally, it is important to have a clear retention period (e.g., delete images when a child leaves, or after a set number of years, unless you have a specific reason to keep them).
5. Update your safeguarding paperwork
   Build image safety and AI risks into your safeguarding and online safety policy, even if you are a single-person setting. Note which tools and platforms you use, how you minimise risks, and what you will do if an image-related concern arises.

Responding if there’s an image-related incident

The guidance stresses that if you become aware that an image of a child has been taken, manipulated or shared in a harmful way, you should treat it as a safeguarding issue, not a tech problem. For childminders, that means:

• Do not engage with blackmail or threats: If anyone contacts you threatening to share AI-generated or manipulated images of the children in your care, do not negotiate or pay; report it to the police immediately.
• Follow your child protection procedures: Record what has happened, contact your local safeguarding children partner or children’s social care if appropriate, and follow your usual safeguarding workflow, just as you would for any online abuse concern.
• Do not save or forward illegal content: The law on indecent images of children applies even if the material is AI-generated; it is still an offence to possess or share it. The guidance is clear that staff should not copy, print, or store such images; instead, they should note key information (usernames, links) and pass this to police.
• Support the child and family: Prioritise the child’s emotional wellbeing, reassurance and practical support, including information on services like Childline and tools such as Report Remove that can help get harmful content taken down.

As a childminder, you may not have a large team, but as the Designated Safeguarding Lead it is important that you follow national advice for responding to incidents.

Building this into everyday practice and communication

Finally, the guidance underlines the importance of proactive education and communication, tailored to the age and stage of the children in your care. For childminders, this might include talking with older children and with your own children, if images of them also appear on your setting’s pages about asking permission before taking or sharing photos, and about never using apps to manipulate pictures of staff, friends or other children.

It also means sharing short, clear explanations with parents about why you may be changing how you use images online, for example by posting fewer face‑on photos on your Facebook page and making greater use of private, controlled channels such as secure learning journals or direct messages to individual families.

As part of your wider safeguarding practice, review your online presence at least once a year. Use this review to check older posts and remove images that are no longer necessary, ensuring that what remains online continues to reflect your current approach to consent, privacy and child protection.

Putting this guidance into practice shows parents and Ofsted that you understand emerging online risks and are actively managing them in line with your safeguarding duties under the EYFS.

Further information:

Image guidance for education settings – UK Safer Internet Centre

Report Remove | Childline

Photographing and filming children | Images guidance | NSPCC Learning