Advances in AI technologies are creating new and evolving safeguarding challenges for schools. The increasing availability of AI tools has made it easier than ever to create, alter and repurpose images, raising significant concerns about privacy, consent and online safety. Alex Dave, safeguarding lead at edtech charity LGfL – The National Grid for Learning, explores the issue
Effective safeguarding extends beyond the school gate. As schools increasingly use websites and social media to celebrate achievements, showcase learning and engage with their communities, it is important to consider how published images could be accessed, shared or misused in ways that were never intended.
While sharing photographs brings clear benefits, advances in AI have significantly reshaped the risk landscape. Images featuring pupils and staff can now be copied and manipulated with unprecedented ease, creating new challenges for schools seeking to balance community engagement with keeping children and young people safe online.
A growing concern is where photos of pupils or staff are taken from websites, social media channels and marketing materials. These images are then processed using artificial intelligence tools - such as freely available ‘nudification’ apps - to create non-consensual, synthetic sexual imagery, including AI-generated child sexual abuse material (AI CSAM). The AI tools used to create such abhorrent and illegal images (photos and videos) are neither difficult to find nor use. The reality of this threat requires our attention and proactive leadership.
The Internet Watch Foundation (IWF) has also published recent data about the significant increase in AI Generated CSAM being found by their analysts, suggesting that this technology is already in the wrong hands.
This has led to new guidance being published this month by the UK Online Harms Early Warning Working Group.
Understanding the evolving risks
For some, concerns about AI image manipulation may seem remote or unlikely. However, the risks are real and becoming increasingly relevant as AI tools become more accessible and capable. Schools understandably want to celebrate pupils’ achievements and share positive experiences with their communities, but advances in AI have changed the way images published online can be collected, altered and reused, creating new safeguarding considerations.
Photographs shared on websites and social media can now be easily edited and repurposed into highly realistic but entirely fabricated content. In some instances, this may involve harmful, abusive or exploitative material. Against this backdrop, schools are encouraged to carefully reflect on whether their current approaches to image sharing remains effective and aligned with the expectations and informed consent of parents and carers in an age of increasingly sophisticated AI tools.
The risks
The creation of synthetic intimate imagery carries serious real-world consequences. Manipulated images may be used to blackmail individuals or institutions, with perpetrators demanding payment or compliance under threat of disclosure.
The non-consensual sharing and modification of student photos directly compromises the safety of vulnerable children, such as Looked After Children or those on child protection plans, by exposing personal data or location routines.
The emotional toll on the victims, whether they are pupils or staff members, and their families, is immense. Dealing with these breaches is also heavily distressing for the safeguarding teams managing the fallout. And if deepfakes are shared on the web, they are difficult to totally remove, and so the consequences can be long term.
Reviewing published school images
Senior leadership teams are encouraged to review images that are publicly available on the school’s website and social media platforms, including those featuring pupils, staff, governors and school leaders. This review provides an opportunity to consider whether existing image-sharing practices remain appropriate and whether additional safeguards could help reduce the risk of images being copied, manipulated or reused without permission.
Firstly, review the necessity of published images. Reflect on whether identifiable, front-facing photographs are genuinely required. In many cases, the same message can be communicated effectively through alternative approaches, such as images taken from a distance, over-the-shoulder or from behind, or group photographs where faces are less easily identifiable. Some schools are also choosing to use illustrations or avatars for staff, leaders and governors in place of photographs, helping to reduce the likelihood of images being copied, manipulated or misused.
You could also utilise protective technology. Deploying blur or manipulation technology on student faces or background features makes imagery harder to misuse*. Additionally, you can strip out all embedded EXIF metadata (which can reveal device details, times, and routines) before uploading files. But this is not a quick process and requires some technical expertise.
Schools can also implement quality controls, by publishing lower-resolution images online to hinder the effectiveness of AI manipulation tools, although this does not eradicate the risk.
Schools should also assess their social media channels. Closed groups are always preferable when posting photos, but any member, regardless of who they are, could still save, edit and share any images posted in the group. If you continue posting images in closed social media groups, regularly review the security settings of the groups and their memberships.
It’s important to remind staff about reporting. Staff will already be familiar with how to report a safeguarding concern and to avoid looking at, saving or sending child sexual abuse imagery (even AI-generated content) – see UKCIS guidance for a reminder. But it could be helpful to communicate to staff about how to report concerns relating to the synthetic imagery of teachers/adults being created.
Schools should also update their policies and AUPS. It is worth ensuring that the issue of image sharing is covered in your existing policies, e.g. Online Safety Policy and Acceptable Use Policies. We will be updating our template policies and AUPs shortly.
Schools can also re-issue image consent forms. Ensure that parents and carers (and children over the age of 16 years) are aware of the risks, so they can make an informed decision about using their child’s photos. Opt in systems, rather than opt out, would seem more responsible in this new landscape.
*AI image editing and data protection considerations
As schools respond to emerging safeguarding risks, careful thought should also be given to how AI tools might be used to create, enhance or alter images. Any use of AI-generated or AI-assisted imagery should be appropriately risk assessed to ensure it aligns with data protection obligations, safeguarding duties and expectations around transparency.
For further guidance, schools can refer to edtech charity LGfL’s AI Policy Toolkit, which supports a safeguarding-first approach to the adoption and use of AI in education settings.
Manipulation of student images using unapproved or unchecked AI tools may give rise to privacy breaches and risks of non-compliance with data protection legislation. A Data Protection Impact Assessment for any AI tools used is a key requirement to ensure that schools continue to meet their legal obligations.
