Image Capture at the Sports City
PROTOCOL OF ACTION AND CODE OF CONDUCT FOR THE USE OF CAMERAS AND SIMILAR DEVICES AT SPORTS EVENTS OF UNIÓN FUTBOLÍSTICA CORDOBESA, S.A.D.
Publication date: April 4, 2024
INTRODUCTION
We recognize the value of shared moments and celebrate the passion of our fans for capturing and preserving memories of our sporting events. However, we are equally aware of the need to balance this enthusiasm with absolute respect for the privacy, security, and dignity of all participants, attendees, and players, with particular emphasis on the protection of our underage players. The proliferation of image-capturing devices and the ease with which photographs and videos can be shared and distributed in the digital world oblige us to be especially diligent in preventing abuse, irregularities, and unauthorized uses of images.
PURPOSE OF THE PROTOCOL AND CODE
In light of the above, the Club has decided to establish a protocol and Code of Conduct to prevent situations that may interfere with individuals’ intimacy, privacy, or right to honor, particularly ensuring the protection of minors. It also seeks to determine how to proceed in the event that such situations arise.
Accordingly, this Code of Conduct has as its fundamental purpose the establishment of clear guidelines and specific procedures for the use of cameras and recording devices during sports events organized by the Club or held at the Club’s facilities, ensuring a safe and respectful environment and compliance with applicable legislation.
SCOPE OF APPLICATION
This protocol and code will be shared with the individuals directly affected by its enforcement within the Club and, in addition, published on the Club’s corporate website, all with the aim of granting greater transparency and proactive protection of privacy and intimacy as established herein.
APPLICABLE REGULATIONS
This Code of Conduct is based on a legal and ethical framework designed to guarantee the respect and protection of the rights of all attendees and players at sporting events:
-
Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights (“LOPDGDD”): This national law represents the commitment to the protection of citizens’ privacy and personal data. In the context of our code, it emphasizes the importance of handling images captured at public events—which may be considered personal data—with the utmost care and respect for individual privacy.
-
Organic Law 1/1982 on the Right to Honor, Personal and Family Privacy, and One’s Own Image (“LO 1/1982”): This law underlines each individual’s fundamental right to their own image and to protection against capture and dissemination without consent.
-
General Data Protection Regulation of the European Union (“GDPR”): The GDPR establishes a standard for data protection in Europe, including the management of images as personal data. This regulation is particularly relevant to our code, as it lays down the principles of lawful processing, data minimization, and enhanced protection for minors’ data. Our code aligns with these directives by requiring that any image capture at sporting events comply with legality, legitimate purpose, and data security principles.
-
Codes of Conduct and Best Practices Recognized at National and International Levels: In addition to specific laws, our code draws inspiration from a variety of recognized codes of conduct and best practices, both nationally and internationally, establishing a set of core values and principles we consider essential.
These ethical and professional principles guide us in creating a respectful and safe environment, promoting responsible practices among fans, players, Club staff, and the entire community.
This approach includes the promotion of education on digital rights and privacy, fostering a culture of respect and legality in the capture and use of images, and the establishment of clear mechanisms for reporting and managing infringements.
CLUB PRINCIPLES AND VALUES
-
Respect for Privacy: The Club considers respect for individual privacy as one of its fundamental pillars. We understand the importance of protecting the personal information and image of all participants in our events, especially minors. This respect is expressed through clear policies and responsible practices regarding the use of cameras and recording devices, ensuring that each person’s dignity and privacy remain intact.
-
Commitment to Safety: The Club is committed to implementing all necessary measures to ensure a safe environment where the community can enjoy sports without concerns, free from any form of abuse or exploitation.
-
Transparency and Open Communication: We are committed to maintaining clear and transparent communication about our policies and practices related to the capture and use of images at sporting events. This ensures that all members of our community are informed and can participate consciously and respectfully, in alignment with our values of integrity and mutual respect.
-
Education and Awareness: The Club is dedicated to educating and raising awareness among its staff, players, fans, and the broader community about the importance of privacy and image rights. Through training programs and information campaigns, we seek to promote a culture of responsibility and respect in the use of recording and photography technologies.
-
Defense of Children’s Rights: Protecting the rights of minors is central to our mission and values. We strive to be a Club that leads by example in safeguarding young people, ensuring that their rights to privacy, safety, and protection against exploitation are always prioritized in our policies and actions.
-
Accountability: We take responsibility for complying with applicable laws and regulations regarding the protection of personal data and image rights, committing to constant review and improvement of our practices. We also establish accountability mechanisms to ensure compliance with these principles, acting decisively and transparently in the event of any breach.
These principles and values reflect the Club’s deep commitment to creating a safe and respectful sporting environment where the privacy and dignity of all—especially minors—are protected. Through these guidelines, the Club seeks to foster a more informed, responsible, and ethically engaged community.
GENERAL GUIDELINES FOR IMAGE CAPTURE
Permitted Use
The use of non-professional cameras and mobile devices is permitted exclusively for capturing personal and memorable moments. Such images must be for private use and may not be distributed widely or for commercial purposes.
Fans must be fully aware of their surroundings and avoid photographing or recording individuals who do not wish to be captured in images. This is particularly critical with children and adolescents, where consent for capturing and publishing images must be obtained from parents or legal guardians.
The publication of images on social networks or other digital platforms where clearly identifiable persons appear is strictly prohibited unless prior consent has been obtained—or, in the case of minors, the consent of their parents or legal guardians. This policy is intended to protect privacy and prevent any possible exploitation or misuse of images.
The Club expressly prohibits the use of professional and reflex cameras at all its events, unless prior specific authorization has been granted.
This restriction includes any camera with advanced capture capabilities, such as interchangeable lenses, extensive manual settings, and the ability to record in high definition, which are generally associated with professional or commercial use. The capacity of these cameras to capture detailed long-distance images may raise significant privacy concerns, especially at events with minors present. Limiting their use helps protect participants’ intimacy and prevent unauthorized image capture and distribution.
Restricted or Prohibited Areas
In addition to prohibiting image capture in locker rooms or areas designated for minors, we will establish camera-free zones in sensitive or high-privacy areas during events, i.e., areas where the use of cameras is expressly prohibited or restricted. This includes, but is not limited to, athletes’ rest areas, family areas, and any space temporarily designated for specific activities with children.
We will provide visible signage and additional guidance through our communication channels and on-site staff to inform and remind attendees of these camera-free zones, ensuring respect for the privacy of all participants.
Respect and Protection of the Rights of Photographed Persons
We will reinforce the need to obtain explicit and informed consent before photographing or recording individuals, particularly minors. Such consent must be clear and documented where possible, especially in situations where individuals may be uniquely identified in the captured material.
Any image or video obtained during our events must not be used in a way that compromises the honor, privacy, or safety of those photographed. This includes the explicit prohibition of distributing material that may be considered invasive, derogatory, or in any way infringing upon human dignity.
We will establish a clear and accessible process for attendees and participants to report inappropriate use of images or privacy-related concerns. This mechanism will ensure a rapid and effective response by the Club to address and mitigate any incident.
Exception for Journalistic Use of Images
To ensure a balance between freedom of the press and the protection of privacy and safety—especially of minors—all media outlets wishing to capture images during events must request and receive specific accreditation from the Club prior to the event.
This accreditation will be subject to review of the outlet’s credentials and the declared intended use of the images.
Upon receiving accreditation, the media will be provided with guidance on the specific areas of the event where image capture is permitted, the restrictions on certain areas or times of the event, and the Club’s expectations regarding respectful treatment of captured images, particularly those involving minors.
The Club expects all images captured under this exception to be used ethically, respecting individuals’ rights and avoiding the distribution of material that may be harmful, invasive, or in any way disrespectful.
The media are encouraged to collaborate with the Club in promoting a positive and respectful representation of sport and its participants.
After each event, the Club reserves the right to review and discuss with the media the use of images captured, in order to ensure ongoing compliance with the established guidelines and to improve future practices.
CLUB’S COMMITMENT TO THE SPECIAL PROTECTION OF MINORS
The Club adopts a zero-tolerance policy towards any form of abuse, mistreatment, or exploitation of minors. This commitment extends to all activities and events associated with the Club, emphasizing the importance of a safe environment for the development and well-being of young people.
We will implement mandatory training programs for all staff, volunteers, and participants in Club activities, focusing on the recognition, prevention, and proper handling of situations that may compromise minors’ safety. We will also develop materials and informative sessions aimed at minors and their families, educating them on children’s rights, how to recognize risky situations, and the channels available for reporting any concern or incident.