Filming minor players: what the club needs to put in place

A person's image is personal data

As soon as a player is recognisable, the video is personal data about them. It does not matter whether it stays in the club, is not published, or is used for training. This triggers three obligations: a legal basis for filming, clear information for the people concerned, and a defined retention period.

For a minor, consent is given by the legal representatives. Depending on age and maturity, the child's view also counts: a sixteen-year-old who refuses to be filmed is not overruled by a parent's signature.

What to have in place before the first session

1. A written authorisation from the parents, separate from the registration form. It must say what is filmed, why, who has access, how long it is kept, and how to withdraw agreement.
2. Information for the players themselves, in terms they understand. “We film training to review situations together; it stays in the team.”
3. A clear distinction between analysis and communication. Agreement to film training is not agreement to publish on the club's social networks. These are two separate boxes, and many disputes come from confusing them.
4. Restricted access. If the file ends up in an open messaging group, the signed agreement no longer protects anything.

A refusal must remain possible without any sporting consequence. A child whose parents refuse video cannot be left out of the team for that reason: consent is valid only if it is freely given.

Who is responsible: the club, not the tool

This is the point most often misunderstood. The club (or the coach) decides to film, decides who watches and decides when to delete: it is the data controller. A tool like TactiCam hosts and processes the videos on behalf of the club, following its instructions: it is a processor. The provider cannot take on the consent in place of the club, and no serious supplier will claim otherwise.

What the club can legitimately require of its provider: knowing where the videos are hosted, who has access, which subprocessors are involved, and being able to delete everything on request. This information must be written and public.

When someone asks to stop appearing

This request does come, and a club must know how to answer it before it arrives. Three cases arise:

• The person is alone in the image: the sequence can simply be deleted.
• Other players are filmed at the same time, which is the usual case on a pitch. Deleting also erases the teammates' work. The club then weighs it up: delete, trim, or keep and give reasons for its decision. Automatic blurring is rarely a realistic answer on a wide shot.
• The name can be removed from labels, mentions and comments even when the image is kept. That is often what the person was actually asking for.

In every case, the decision must be communicated to the person, favourable or not, and the club must be able to show that it handled the request. A request left unanswered is a breach in itself.

How long to keep the videos

The law sets no period for training videos: it is up to the club to define one and stick to it. A sporting season is a readable and defensible benchmark. What is not defensible is “we keep everything, we'll see”: retention with no declared limit is exactly what an inspection flags.

Write the period into the parental authorisation, and apply it. A tool that deletes automatically at the planned end is worth more than an intention noted in the minutes.

The case of facial recognition

Biometric data, including facial recognition, falls under a much stricter regime, and has no reason to be in an amateur club. If a tool identifies players automatically by their face, ask explicitly on what legal basis. Detecting silhouettes and movements to help tactical analysis is something else: it identifies nobody.