What about consent?
Initially, the employer must request for the consent for use of photos of employees on external web pages, according to the Norwegian Data Protection Authority.
However, UiO as an employer has a legitimate interest in having profile pictures of employees. The reason behind this is to allow for the identification of colleagues, contact with each other and thus facilitate the working week day. The legitimate interest supersedes the requirement of consent.
Thus, we do not require consent for the use of profile pictures of employees.
Legal basis
The legal basis for the legitimate interest is sanctioned in Article 6
(f) of the GDPR.
Optional with picture
It is recommended to have an employee profile picture for their profile. However, this is optional for the sake of privacy of individual employees. Employees initially report if they do not wish to be photographed.
Press photo
Some employees also have high-resolution versions of their portrait available for use in print, typically for those who have positions where one is often interviewed or the like.
This is optional. These images may also be reused elsewhere as long as UiO is credited.
Where is the image stored?
Profile pictures of UiO’s employees and press photos are saved in UiO’s photo archive, or other archiving solutions on devices, as well as being published on the online profiles.
How to remove the image?
If an employee wants it, the image can be removed from the website. You can either remove the image yourself, if you have access to it, or contact the nearest webmaster for assistance.
Please contact the nearest webmaster (in Norwegian) if you also want to remove the image from UiO’s photo archive or local archives.
What about guest researchers and other associates?
This guide applies similarly to any other associates at the UiO who have a profile on the websites. Provided they are connected to the UiO through a formal relationship (employment contracts, contract for scholarships or the like), UiO may claim a legitimate interest, and thus have profile pictures on the websites without prior written consent.