During a public sporting event (running, triathlon, cycling, etc.), the taking and distribution of photographs of participants is generally covered by implied consent — by registering for a public event and accepting its rules, participants are deemed to have consented to being photographed during the event.
This implied consent is valid under two conditions:
- – The rules of the event or the conditions of registration explicitly mention the presence of a photographer and the use of photographs.
- – The photographs are used in connection with the event (distribution to participants, communication by the organiser) and not for third-party commercial purposes.
Facial recognition: mandatory disclosure #
Facial prints are biometric data within the meaning of the GDPR — they benefit from enhanced protection compared to traditional personal data.
If you use one of the following algorithms — Face + Bib Number, Without Bib Number, or Staff — the use of facial recognition must be explicitly mentioned in the event rules or registration conditions. A generic mention on the photograph is not sufficient: it must be clearly stated that biometric data (facial recognition) will be processed as part of the event.
⚠️ Without this explicit mention, you cannot legally use facial recognition algorithms on photos from the event.
Your obligations #
Even in the context of a mass event, participants retain the right to erasure — they may request the removal of their photos at any time.
As a photographer using Sportpxl, you must:
- Inform participants about the use of facial recognition, ideally in the event rules or via the organiser.
- Process deletion requests within 30 days — see the article "Hide or delete an athlete's photos"
- Do not reuse photos for purposes other than those intended without the explicit consent of the participants.
What Sportpxl manages for you #
Sportpxl acts as a processor within the meaning of the GDPR — it processes biometric data on your behalf and is contractually bound to comply with the legal framework:
- – Secure data hosting
- – Processing of deletion requests via the interface
- – Payment compliance via Stripe
Best practices #
- – Coordinate with the organiser to ensure that the event rules explicitly mention the presence of a photographer, the use of Sportpxl and the use of facial recognition.
- – Display an information sign at the photo booth or at the finish line indicating that photos are being taken and shared via Sportpxl.
- – Keep photos only for as long as necessary to market the event.
To go further:
