Can Schools Still Safely Publish Student Photos in the Age of AI?

Permission to take a photo covers a moment. The photo itself can live much longer.

That distinction was at the heart of our recent panel discussion. Around 100 school communicators, technology leaders, and administrators joined Amelia Vance, who has worked in student and child privacy for about 14 years, and Reggie Johnson, an accredited public relations professional with more than 20 years of experience in education, public relations, and digital media, including leading digital media at Fort Worth Country Day.

The question: In an age when AI can identify, analyze, and alter images with increasing ease, how can schools continue sharing the faces and experiences that bring their communities to life?

The panel’s answer was clear: Schools don’t need to stop sharing photos. They do need to think differently about how, where, and why they share them.

Why Schools Can’t Simply Stop Using Photos

Reggie opened with a reasonable question. If sharing photos carries risk, why not stop altogether? Post text instead. Tell parents what their children learned, without pictures or names.

But that approach misses something important about how families experience school.

The CEO of Interactive Schools once shared a thought with Reggie that has stayed with him:

At Fort Worth Country Day, Reggie ran different photo slideshows on screens around campus. In the cafeteria, students watched images from recent events as they ate lunch. Staff noticed students pointing at the screen and calling out:

Those moments of recognition matter. A stock photo can’t capture them, and neither can a photo that deliberately leaves everyone unrecognizable. As Reggie explained, part of a photo’s value is knowing who’s in it and remembering the experience you shared.

Authenticity matters, too. When people suspect that images have been generated or manipulated by AI, trust can suffer.

Schools need ways to share real experiences while being thoughtful about the risks that come with making those experiences visible.

What’s Different About Sharing Photos in the Age of AI?

Reggie has been asking whether it’s safe to publish children’s photos online for 20 years. Early conversations often focused on whether to use first names or full names in online publications. The experts and law enforcement professionals he consulted generally considered it uncommon for a stranger to find a child’s photo online and use it to track them down.

As Reggie put it:

AI changes the equation in several ways. Mandy outlined four important shifts:

Mandy demonstrated how accessible these capabilities have become. She uploaded a photo without accompanying information to an AI tool and received a description that included clues about her location and approximate age. She also asked AI to transform a photo of her son into images of him as a soccer star, an award winner, and a mountain biker. The results looked believable.

Amelia described the underlying issue as a loss of what is sometimes called privacy through obscurity. A yearbook might once have been available in a school library, but finding it required time and effort. Today, technology can make information much easier to discover, connect, and reuse.

Amelia put it this way:

The concerns extend beyond deepfakes. Photos shared years ago under different terms may be used to train AI systems. Facial-search websites may claim to identify people from a single image. Information once considered anonymous may become identifiable when combined with other data.

Families may also worry about over-collection, bullying, a permanent record of childhood mistakes, future opportunities, and how companies use or profit from their children’s information.

The issue isn’t simply whether a photo is public or private. It’s what can happen to that photo over time.

Privacy Is About More Than Public Versus Private

Amelia began with a definition to help frame the discussion:

Taking a photo, editing it, applying AI to it, and publishing it are all ways of collecting, using, or sharing information.

Privacy doesn’t mean keeping everything hidden. We share different information with a doctor, a colleague, or a friend because each relationship and setting calls for something different. The same principle applies to schools.

Amelia encouraged schools to consider three kinds of privacy risk:

• Compliance: Is the way the data is collected and used legal?
• Perception and trust: How might students, families, and staff feel about its use, even if it’s legal?
• Actual harm: What could happen to someone because the information is available?

Considering all three helps schools move beyond asking whether something is technically permitted and toward asking whether it’s appropriate for their community.

What Schools Need to Know About the Law

Amelia offered an overview of the legal landscape, noting that the rules that apply depend on the school, the information involved, and how it is used. The full webinar and slide deck provide more detail.

A few areas are particularly relevant to student photos:

• FERPA: For schools covered by FERPA, some photos may qualify as directory information, depending on the circumstances and the school’s designated categories. Combining a photo with additional student information can change how it is treated, so schools should assess the specific context rather than assume every photo is automatically directory information.
• State student privacy laws: State requirements vary. Some laws restrict how companies serving schools can collect and use student information, and coverage differs across school types and jurisdictions.
• State consumer privacy laws: Some laws also cover nonprofits and impose additional protections for children’s personal information.
• COPPA: This federal law addresses the collection of personal information from children under 13. Its requirements can be relevant when schools use online services on children’s behalf, particularly when information is shared with third parties.
• GDPR and similar international laws: Schools operating outside the United States may need to establish a lawful basis for processing personal data, consider whether sharing is necessary, and ensure information is used appropriately for its intended purpose.
• Child online safety laws: Newer laws address issues such as harmful content, social media, age-related protections, and AI services.

The practical takeaway is to understand which requirements apply to your school and how they affect the tools and workflows your team uses. When questions involve specific legal obligations, consult qualified legal counsel.

One attendee raised a common scenario: uploading a student’s photo to a design tool to create a marketing graphic, then using AI to edit it.

Amelia explained that uploading an image to a third-party service involves sharing it with that provider. Whether that use is appropriate depends on the circumstances, including the school’s agreements with the provider and how the company handles uploaded content.

If a tool can use uploaded images to train its AI, a photo intended for one marketing graphic could have a much broader use than the school anticipated.

Before uploading student photos, understand what the tool does with them, how they are retained, and whether they can be used for purposes beyond your original request.

Is Permission Enough?

This question ran through the entire discussion. Amelia summed it up:

Having consent on file is important, but it doesn’t answer every question. Does a photo become part of a student’s education record when software tags their face? Does editing a real student’s photo with AI require additional permission? Do permissions granted years ago cover uses families couldn’t have anticipated? Can families control whether their child’s image is used to train AI when the school manages the account?

Schools also need to consider how their decisions affect trust, even when the required forms have been signed.

As Amelia noted, “You can still break trust with your community.”

Reggie brought the communications perspective:

The panel discussed a university that used AI to alter a student’s photo, prompting a strong reaction from students. One student’s concern wasn’t simply about privacy. He felt that the altered image no longer represented him. Mandy also observed that another student had been changed to look more attractive.

That raised a deeper question: What message does it send when a school changes a student’s appearance to make an image look better?

The impact can extend beyond the individual in the photo. Students may question whether their school accepts them as they are, and families may wonder what else could be changed without their knowledge.

Consent matters, but so do context, representation, and the expectations a school establishes with its community.

The Face-Swap Question

In an earlier webinar, Vidigami asked school communicators whether they would use contextually authentic photos: images depicting a real event in a real setting, but with a student’s face replaced by an AI-generated one.

The responses were split. Half said yes, and half said absolutely not.

One attendee explained that students would be “weirded out” seeing themselves with a different face. Reggie agreed and pointed out a complication that consent alone doesn’t resolve.

Even if a student and family agree to the change, classmates may recognize the person by their jersey number, position, or role on the team. They may then notice that the face isn’t the student’s. Other people could feel misled by the school’s decision, even when the student involved gave permission.

Reggie suggested that, if schools choose to experiment with this approach, it may be more appropriate for external marketing than for internal channels, where students and families expect to see authentic representations of people they know.

Clear explanations and examples are essential before asking students and families to participate.

The larger lesson is that a technically convincing image isn’t necessarily an authentic one. Schools need to consider not only whether an image can be created, but also how the people represented in it will feel about it.

There Is No Single Solution, but Schools Can Reduce Exposure

One of the most common questions from registrants was whether technology can prevent school photos from being scraped or misused.

Mandy’s answer was straightforward: no single technology can eliminate the risk.

The panel discussed several approaches and their limitations:

• Blocking AI crawlers: Restricting automated crawlers on public websites is a useful step, but it cannot guarantee that every system will respect those restrictions.
• Cloaking, masking, and watermarking: These techniques may discourage some forms of misuse, but they aren’t foolproof.
• AI detection: Detection tools may help identify manipulated content after the fact, but they don’t prevent misuse.
• Limiting image detail: Blurred faces, distant shots, and lower-resolution images may reduce some risks, but they can also diminish the value of a photo. Lower-resolution images may be enhanced, too.

For schools, one of the most practical ways to reduce risk is to manage exposure: who can access a photo, for what purpose, and for how long.

Amelia’s advice on data minimization was particularly useful:

She outlined several practical steps schools can take:

• Collect only what you need. Turn off location data on cameras or remove it before sharing images when it isn’t needed.
• Use photos for their intended purpose. A class gallery photo isn’t automatically a marketing photo.
• Share only the information that’s necessary. Consider whether full names or other identifying details need to accompany an image.
• Review how long photos remain accessible. Establish expectations for retaining older photos, including after students graduate or staff leave.
• Limit access appropriately. Consider who needs to see each collection of photos and adjust access as those needs change.

A useful question to ask throughout the process is simple: If you can’t clearly explain why your school needs a piece of information, should you be collecting it at all?

The Choice Isn’t All or Nothing

One attendee asked a question many schools may be considering: Are we moving toward a future of distant shots and photos of the backs of students’ heads?

Reggie hopes not:

Amelia challenged the idea that schools must choose between sharing smiling faces with the entire world and avoiding identifiable photos altogether.

Instead, schools can make more thoughtful decisions about where images appear, who can see them, and whether that audience needs access to them. As Amelia said:

That distinction matters. Photos shared in a school community for students, families, and staff serve a different purpose from images published publicly to reach prospective families or promote a program.

The audience, purpose, and level of access should inform the decision.

Making that possible requires more than a consent form. Schools need policies that reflect their community’s values, a clear understanding of the laws that apply, and processes that allow them to honor individual permissions as photos are collected, organized, and shared.

As Reggie explained:

That infrastructure helps schools move beyond managing individual permission forms to making responsible photo sharing part of their everyday practice.

Keeping the Story Authentic

The discussion closed with a question about where schools should draw the line when editing photos.

Reggie’s guidance offers a useful principle for AI as well as traditional editing: use editing to bring out what it was really like to be there, not to change it into something it wasn’t.

For schools, that principle goes beyond any single tool or technology. It means respecting the people in the photos, considering the context in which images will be shared, and recognizing that a photo’s life doesn’t end when the original post is published.

Schools can continue sharing the experiences that help students and families feel connected to their communities. Doing so responsibly means being intentional about what they collect, how they use it, and who gets to see it.

The goal isn’t to stop telling school stories. It’s to make sure the way we tell them continues to reflect the trust those stories depend on.