How long can we keep photos of junior players?

Question

Accepted Answer

No longer than is necessary for the purpose you collected them for (s14(1)), unless:

a law requires or authorises keeping them;
the club reasonably needs them for lawful purposes related to its functions or activities;
a contract between the parties requires it; or
a competent person (parent or guardian) has consented to the club keeping them.

Photos may be kept longer for historical, statistical or research purposes (for example a club archive) if the club has appropriate safeguards against them being used for anything else (s14(2)).

Once the club is no longer authorised to keep them, it must destroy, delete or de-identify them as soon as reasonably practicable, in a way that prevents them being reconstructed (s14(4)-(5)). A data subject can also ask for a record the club is no longer authorised to keep to be destroyed or deleted (s24(1)(b)).

Source: POPIA (Act 4 of 2013) ss 14, 24.