Who may film at your club, and what may you publish?

Background checks are no longer a one-off

A limited criminal record extract has been mandatory across Swedish sport since 1 January 2020 for everyone with direct and regular contact with children. The rules were tightened in 2026: the validity period is shorter — at most six months rather than a year — and the list of offences has been widened.

Two practical consequences. The first is that the check has to become a recurring calendar event rather than something done when a new leader starts. The second is that the club must not keep copies of the extracts — only document that the check was made, by whom and when. That is a data protection matter as much as a safeguarding one.

At the same time the Swedish Sports Confederation is explicit that the extract alone is not enough. Safeguarding consists of four parts: background checks, a code of conduct, a documented routine when there is concern or misconduct, and leader training. Reports to sport’s whistleblowing service hit a record in 2025 with 841 submissions, and perceived misconduct was the most common category.

Choose a legal basis for each type of image

The most common weakness in a club policy is choosing a single basis for everything. There are three to choose from — consent, legitimate interests and contract — and which one holds depends on what the image is.

• A team photo or match report from an event: legitimate interests can work.
• A close-up of an individual child, or an image used in recruitment or marketing: consent — and commercial use requires it under separate Swedish legislation.
• Images in contexts that reveal more than the football: injuries, illness, changing rooms. Do not publish.
• Children with protected personal data need their own routine — they should not appear on shared participant lists, and images require particular care.

The household exemption does not cover the club account

The GDPR’s household exemption does not apply once images are shared with a large or undefined audience. An open social media account is therefore not private use, and whoever publishes is responsible for the processing. That applies as much to a team account a leader set up themselves as to the club’s official channels.

The Swedish privacy authority takes a restrictive starting point on images of children: their personal data merits particular protection, and the child’s privacy normally outweighs the interest in publishing. So build the club’s digital presence around teams and context rather than around individually highlighted talents, and avoid combining a full name, birth year and town in the same post.

Consent below 16, and a "no" that costs nothing

Within Swedish sport, a guardian’s consent is sought for photographing and filming children under 16. From 16 the child can consent themselves, provided they understand what it means. That is stricter than the 13-year threshold in data protection law for online services, and deliberately so.

The Swedish FA’s wording is the most important sentence in this whole topic: being filmed must be voluntary, and the child does not have to justify saying no. So make the no frictionless in practice — a child should be able to say it to anybody in the club, including after the fact, and the material should come down without debate.

Put up signage at the ground saying that photography and filming take place, with a named contact person, and say it out loud to the group before shooting on the club’s behalf. Also check what can already be switched off in the tools you use: in Min Fotboll a team can turn photography and live streaming off entirely, and young players’ profile pictures and full names can be hidden.

Two rules that are not policy but law

Intrusive photography has been a criminal offence in Sweden since 2013: secretly and unlawfully photographing someone in a changing room, toilet or home can carry a fine or up to two years in prison. So set a clear phone rule for changing rooms and showers and explain why it exists — it is not the club’s invention.

And material that is degrading must be taken down immediately, regardless of whether there was consent to begin with. Consent can always be withdrawn, and consent to appear is not consent to anything at all.

One answer to scouting enquiries, written in advance

Put the answer on the club’s website so nobody has to improvise: all contact about a player goes to the office or a designated person on the board, never directly to the player, the family or the team’s coach. That protects both the child and the youth coach who would otherwise end up in a negotiation they never asked for.

At the same time teach your leaders the order of contact by heart — the initiative goes from the player to their own club, then to the new club, and only then between the clubs. A club representative making first contact with a child at another club is an illegal approach, and that expressly includes social media.

Give guardians three questions to ask any agent who gets in touch: is my child over 14 years and 6 months, may I see your FIFA ID, and who is paying you? Tell them at the same time that player contracts cannot be signed before the age of 15 and that international transfers under 18 are prohibited as a rule. Parents who know that do not have to make the decision under pressure.

The safeguarding routine fits on one page

Write it in three steps, with names and phone numbers, and put it where leaders actually see it: first the club’s board, then the sport’s national federation or the regional RF-SISU district, and last the sports ombudsman and the whistleblowing service. The point of spelling out steps two and three is that anyone with a concern should know there is a way onward even when step one is the problem.

Write a short code of conduct that says something concrete about digital contact, since that is where most boundary questions actually arise today: no one-to-one messages between an adult leader and a minor, and all team communication in open channels where more than one adult can see it.

Common follow-up questions

Do we need consent to post a team photo?

Not necessarily — a team photo or match report from an event can rest on legitimate interests. But the assessment has to be made and written down, and it holds up less well the more the image singles out an individual child. If the image can be described as "a picture of Kalle" rather than "a picture of the team", consent is the right route.

A parent films the whole match from the touchline. Can we say something?

Yes. An individual parent filming for the family’s own use is normally covered by the household exemption, but as soon as the material is published in an open channel it is not. A club can also set its own rules for its activities and its facilities, and a team can agree on something stricter than the legal minimum.

Who at the club is responsible for this?

The board, legally. In practice you need one named person who owns the issue, because a policy without an owner does not survive a change of leaders. The same person can hold together the background checks, the image policy and the answer to scouting enquiries — in practice they are the same recurring questions.

Read next

• Your child is posting football clips. What should you look at?
• Contacting a young player: what the rules are