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Re-using archived footage

Any video footage held on file before 25 May 2018 should be stored safely and securely. Find out more about safe storage here.

When taking that footage and making a new edit from it, this is classed as processing data. If uploading an existing video to a ‘new’ platform for the first time, this is also processing data. Showing the video at a conference is processing data. In short – doing almost anything with the data is processing it under the GDPR.

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More information


You uploaded a video to Facebook before 25 May 2018 but you forgot to upload to YouTube. It’s now 1 February 2019 and you’d like to upload it to YouTube. This is classed as processing the data under new GDPR law. What should you do?

If there are only staff and students in the video and they consented at the time (before 25 May 2018) then we can reasonably assume that they would expect to see themselves in our content.

In this case it’s good practice to contact the staff/students to tell them we’re still using their footage/video and that we simply need to alert them to our new privacy policy. You can then attach the policy or direct them to the  online version here. It is expected that we do everything we reasonably can to issue that policy. Sending an email is fine, and hopefully you will have these on file in the consent forms you collected at the time.

If there are external people in a video, for example a representative from a company or other organisation, then we must make every effort to contact them to issue the privacy policy. It is best to avoid reusing anything with external people in them if you can’t reach them, especially if they are named and are speaking on camera. Under no circumstances can you reuse past footage contain containing children.


Additional guidance

  • If it's not possible to identify someone from footage, you can use it without concern. Practically, this generally means the full face of the individual, or at least a sentence 
    or two of speech. Ask yourself whether, using the power of an organisation like Google and the technology they have at their disposal, someone could be identified
  • If you've published content before 25 May 2018 and you're not changing it or putting it somewhere new, then you're fine to keep using it. For example, if you'd put a video on YouTube and MediaSpace, you can keep linking to that video on those platforms, but you couldn't put it up on Facebook without going through the process
  • Any old consent forms you have should be scanned, stored securely and the hard copies destroyed

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