Annex 20: Media, Communication, and Image Consent Policy
Table of Contents
Chapter 3: Ethical Standards for External Communications
Chapter 4: Consent for Use of Images and Personal Data
Chapter 5: Protection of Vulnerable Populations
Chapter 6: Storytelling and Representation of Refugees
Chapter 7: Legal Requirements and Compliance
Chapter 8: Media Permissions and Content Approval Process
Chapter 9: Monitoring and Accountability
Chapter 10: Review and Updates
Chapter 1: Introduction
1.1 BackgroundRefugee Pathways & Integration Canada (RefPIC) recognizes the significant role media and communications play in promoting its mission and engaging stakeholders. Through the use of images, stories, and personal data, RefPIC strives to raise awareness, secure funding, and advocate for refugees and displaced populations. However, the organization is committed to ensuring that such practices are carried out ethically and in compliance with legal standards.
This policy establishes the principles and procedures guiding media and communication practices within RefPIC. It prioritizes the dignity, privacy, and rights of all individuals featured in its media, especially those belonging to vulnerable populations such as refugees, children, and survivors of trauma.
1.2 ObjectiveThe primary objective of this policy is to ensure that RefPIC’s media and communication practices are conducted ethically, transparently, and in full compliance with legal requirements. Specifically, the policy aims to:(a) Protect the privacy and dignity of individuals represented in media content.(b) Foster respect for diversity and avoid reinforcing stereotypes about refugees and displaced persons.(c) Ensure that consent is obtained and documented before using personal data or images.(d) Establish guidelines for ethical storytelling and representation.
Chapter 2: Purpose and Scope
2.1 Scope of Media and Communication PracticesThis policy applies to all media and communication activities undertaken by RefPIC, including but not limited to:(a) Photographs, videos, and written stories used for promotional materials, reports, websites, and social media.(b) Communications with donors, partners, and stakeholders involving personal data or images of beneficiaries.(c) Collaborative projects with external media organizations, journalists, and other partners.
2.2 Stakeholder InvolvementThe policy is applicable to all RefPIC employees, volunteers, contractors, and partners who engage in media or communication activities on behalf of the organization. Beneficiaries and community members whose images, stories, or data are used are also key stakeholders, ensuring their involvement in decision-making processes related to their representation.
Chapter 3: Ethical Standards for External Communications
3.1 Respect for Privacy and Dignity(a) RefPIC is committed to portraying individuals in ways that uphold their dignity and privacy.(i) Personal stories and images should emphasize the resilience, agency, and humanity of beneficiaries.(ii) Communication materials must avoid depictions that could stigmatize or harm individuals, particularly vulnerable groups.(iii) All media must be reviewed to ensure adherence to these principles before publication.(b) Privacy must be maintained by limiting the sharing of identifiable details unless explicit, documented consent has been obtained.(i) Identifiable information such as names, locations, and specific circumstances must only be shared with the full knowledge and agreement of the individuals concerned.
3.2 Avoiding Stereotyping(a) Communication materials should reject stereotypes and promote accurate, diverse representations of refugees and displaced persons.(i) Media must highlight the unique contributions and diverse backgrounds of beneficiaries to combat oversimplified narratives.(ii) Efforts should be made to balance stories of hardship with examples of resilience and recovery.(b) Employees and volunteers involved in media production must undergo training to recognize and counter unconscious bias in storytelling.(c) Care must be taken to avoid cultural insensitivity in text, images, and audiovisual content.(i) All materials must be reviewed by the communications team for cultural appropriateness before dissemination.
Chapter 4: Consent for Use of Images and Personal Data
4.1 Informed Consent Protocol(a) RefPIC recognizes the importance of obtaining informed consent from individuals whose images or personal data are used in communications materials.(i) Informed consent requires providing a clear explanation of how the images or data will be used, ensuring the individual fully understands the implications.(ii) Consent must be given voluntarily and without coercion, with the option to decline participation at any time.(b) For minors or individuals unable to provide consent, permission must be obtained from a parent, guardian, or legally authorized representative.(i) Special care must be taken to ensure guardians understand how the child’s image or data will be used.(ii) Documentation of guardian consent must be securely stored.(c) Consent must be renewed for any new or additional uses of the material beyond the original agreement.
4.2 Consent Forms and Documentation(a) RefPIC requires signed consent forms for all images and personal data used in public-facing materials.(i) Consent forms should clearly outline the purpose, scope, and duration of the material's use.(ii) Forms must be available in the individual’s preferred language or provided with translation support.(b) All consent forms and related documentation must be stored securely and accessible only to authorized personnel.(c) Regular audits of consent documentation will ensure compliance with RefPIC’s media and communication policies.
Chapter 5: Protection of Vulnerable Populations
5.1 Special Considerations for Vulnerable Groups(a) Vulnerable groups, including children, persons with disabilities, and survivors of trauma, require additional safeguards when participating in media or communication activities.(i) Communication materials involving vulnerable groups must avoid reinforcing stereotypes or exposing individuals to harm.(ii) All interactions must be conducted with cultural sensitivity and respect for personal boundaries.(b) Photographs or interviews involving vulnerable groups must prioritize their safety and well-being over the needs of the project or organization.
5.2 Avoiding Exploitation(a) RefPIC prohibits the use of images or personal stories that exploit individuals for fundraising or promotional purposes.(i) Depictions must respect the dignity of individuals and focus on their resilience and achievements rather than solely their vulnerabilities.(ii) Avoid sensationalism or overly graphic representations of suffering.(b) Training will be provided to all staff and volunteers involved in media production to recognize and prevent exploitative practices.
Chapter 6: Storytelling and Representation of Refugees
6.1 Ethical Representation(a) RefPIC is committed to representing refugees and displaced persons in a manner that emphasizes their humanity, resilience, and contributions.(i) Stories and images must challenge negative stereotypes and highlight positive narratives of empowerment and recovery.(ii) Media materials should include the voices and perspectives of the individuals being represented.(b) Care must be taken to ensure that stories are factually accurate and do not misrepresent the lived experiences of beneficiaries.
6.2 Accuracy and Sensitivity in Reporting(a) RefPIC requires all communications materials to undergo a review process to ensure accuracy and sensitivity.(i) Materials must be fact-checked to avoid spreading misinformation or perpetuating harmful narratives.(ii) Context must be provided for images and stories to ensure audiences understand the broader circumstances.(b) Any errors or misrepresentations in published materials must be corrected promptly, with an official statement if necessary.
Chapter 7: Legal Requirements and Compliance
7.1 Data Protection Regulations(a) RefPIC complies with national and international data protection regulations, including those governing the collection and use of personal data in media materials.(i) Personal data must be processed lawfully, transparently, and only for legitimate purposes.(ii) Individuals have the right to request access to their data and withdraw consent at any time.
7.2 Compliance with National and International Laws(a) All media and communication activities must align with applicable laws, including those related to intellectual property, privacy, and consent.(b) RefPIC’s legal team will provide guidance and oversight to ensure compliance with evolving legal requirements.(c) Non-compliance with legal standards will result in immediate review and corrective action, including potential disciplinary measures.
Chapter 8: Media Permissions and Content Approval Process
8.1 Internal Approval Procedures(a) All media materials, including images, videos, and written stories, must be reviewed and approved by designated personnel within RefPIC before publication.(i) The Communications Manager is responsible for ensuring that materials align with RefPIC’s Media, Communication, and Image Consent Policy.(ii) Sensitive content involving vulnerable populations must receive additional review by the Safeguarding Officer or equivalent authority.(b) Materials must adhere to RefPIC’s ethical, legal, and cultural standards to ensure they reflect the organization’s values and principles.(c) A formal approval record must be maintained for all published materials, documenting the review process and final sign-off.
8.2 External Media Collaboration(a) Collaborations with external media outlets, photographers, or videographers require formal agreements outlining the terms of content creation, usage, and ownership.(i) Agreements must specify that RefPIC retains final approval rights for all content produced.(ii) External collaborators must comply with RefPIC’s Media and Communication policies, including guidelines for obtaining consent.(b) Regular audits of external collaborations will ensure ongoing compliance and address any deviations from agreed standards.
Chapter 9: Monitoring and Accountability
9.1 Tracking Use of Media Content(a) RefPIC will establish a monitoring system to track the use of images, videos, and personal stories across all platforms and publications.(i) A content inventory will document where and how media materials are used, ensuring consistency with consent agreements.(ii) Regular checks will verify that content remains relevant, appropriate, and compliant with ethical guidelines.(b) Any misuse or unauthorized use of media content will be investigated promptly, and corrective actions will be taken as necessary.
9.2 Accountability for Misuse(a) RefPIC will hold all staff, volunteers, and external collaborators accountable for any breaches of the Media, Communication, and Image Consent Policy.(i) Violations may result in disciplinary actions, including termination of employment or partnerships.(ii) Where legal breaches occur, RefPIC will cooperate fully with regulatory authorities and pursue legal remedies if appropriate.(b) Beneficiaries whose content has been misused will be informed and supported through appropriate remedial actions, including issuing public corrections or retractions when required.
Chapter 10: Review and Updates
10.1 Periodic Policy Review(a) RefPIC will conduct a comprehensive review of the Media, Communication, and Image Consent Policy every two years to ensure it remains current and effective.(i) The review will consider changes in legal requirements, technological advancements, and feedback from stakeholders.(ii) Input from beneficiaries and field staff will be prioritized during the review process to ensure the policy addresses practical and ethical concerns.(b) Interim reviews may be conducted if significant issues or changes arise, requiring immediate updates to the policy.
10.2 Updating Based on Legal Changes(a) The policy will be updated promptly to reflect changes in national or international laws governing media, communication, and data protection.(b) Staff and volunteers will be notified of updates through formal training sessions, internal communications, and revised documentation.(c) All updates will be communicated transparently to beneficiaries and partners to maintain trust and accountability.