The legal framework #
Unlike mass events, the context of a sports club does not allow for implicit consent. Photographs of members taken during training sessions, matches or internal tournaments require prior explicit consent.
This consent must be:
- Written — via a form signed by the licensee or, for minors, by their legal representative
- Informed — the licensee must understand how the photos will be used and who will have access to them.
- Specific — general consent for club communications does not necessarily cover the use of facial recognition.
Facial recognition: enhanced consent now mandatory #
If you use the Effective or Without Bib algorithm with facial recognition, you are collecting biometric data within the meaning of the GDPR. This data is subject to maximum protection — explicit consent is non-negotiable in this case, even for adults.
For minors (under 18 years of age), consent must be signed by their legal representative — parent or guardian. The minor’s own consent is not sufficient.
Establishing consent #
- Draft or adapt a consent form that explicitly states:
- Photography during club activities
- The use of facial recognition via Sportpxl
- The purposes of use (distribution to licence holders, club communications, etc.)
- The right to erasure and how to exercise it
- Have each licence holder — or their legal representative in the case of minors — sign this form before any filming takes place.
- Keep the signed forms so that you can prove consent in the event of a request.
Manage your team in Sportpxl #
Sportpxl offers a feature dedicated to managing your club’s membership — see the article “Understanding membership management”. Each member for whom you have obtained consent can be added to your membership with a reference photo, allowing the Membership algorithm to automatically identify them in your photos.
Your obligations #
- Right to erasure — any licensee may request the deletion of their photos and biometric data at any time, including after giving their consent. Process these requests within 30 days — see the article "Hide or delete an athlete's photos".
- Retention period — do not retain data longer than necessary. At the end of the season or when a member leaves, delete their data from Sportpxl.
- Withdrawal of consent — a licence holder may withdraw their consent at any time. In this case, delete their data without delay.
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
To go further:
