Support services - Media: media standard operating procedure (M01a)

1. Summary of changes

1.1. The following amendments have been made to this standard operating procedure (SOP) in July 2024 - stipulating engagement with accredited journalists and reporters for recognised and established media outlets at point 2.1. 

2. What this procedure is about

2.1. The purpose of this policy is to provide guidance to Press Office staff, media and the public about the aims, objectives and rules governing the release of information to accredited journalists and working with recognised and established media organisations (for the remainder of this SOP these groups will be referred to as ‘media’). This applies to all officers and staff who may come into contact with the media in relation to releasing information, film and photographs. The list below outlines the main roles that this policy will apply to, however, the list is not exhaustive.

• Press Office
• Senior Investigating Officers (SIOs)
• Case Officers (OICs)
• Neighbourhood teams
• Cold Case Review team
• Head of Major Crime

2.2. The purpose of this policy is to define the legislation and procedures to be followed in relation to releasing information to the media, including information on media appeals, release of photographs to the media, providing media access to Kent Police personnel, information or images, images used in publicity material, CCTV images, e-fits, media requests for information from non-recent serious crime cases and publicising sentencing outcomes.

2.3. This policy will ensure all media relations activity is carried out consistently and for a legitimate purpose in line with the Code of Ethics, adheres to national approved professional practice from the College of Policing, and demonstrates openness, integrity and legitimacy.

Compliance with this standard operating procedure (SOP) and any governing policy is mandatory.

3. Detail the procedure

3.1. All press releases issued to the media in relation to crime investigations must be authorised by the senior investigating officer (SIO) or investigating officer (OIC).

3.2. When responding to media enquiries the force should be open and transparent, providing factual information in a timely way during core working hours, recognising deadlines and pressure on journalists. However, staff should not be pushed into giving material or information that is inappropriate, carries potential risk or which the force has not had time to verify properly.

3.3. A large or high profile police presence at an incident will attract media attention. The decision on what information to release must be considered on merit, including whether the information is operationally sensitive or security-related.

3.4. Incidents attended by police and other emergency services have always attracted media attention. With 24/7 online news, TV coverage, social media and a trend towards the use of multi-skilled journalists who often act both as reporter and camera operator, news organisations are under increasing pressure to report current information in fast-time.

3.5. Information will normally be provided to the media through news releases, on the Kent Police website, Kent Police social media sites, or in response to an enquiry. Sometimes it may be appropriate to issue a media advisory notice on specific issues or incidents to provide guidance or background information.

3.6. There may be circumstances where it is appropriate to hold a media briefing to explain an issue or policy decision.

3.7. A press conference or media briefing will be considered if an important announcement is to be made or where there are high profile incidents or issues that attract media interest.

3.8. It is important that all information released is correct and consistent, so statements and news releases on important or sensitive issues must be properly verified and then cleared by the most appropriate person at the relevant level of seniority (usually the senior investigating officer (SIO) investigating officer (OIC), head of department, or chief officer). To avoid misreporting, approval may be sought as a matter of urgency.

Media calls on countywide activities, force policy, issues that impact on the force’s reputation or those that do or could attract national media publicity should always be referred to the Press Office. Similarly any proactive or reactive work that will require Kent Police to respond from a corporate position should also be referred to the Press Office.

3.9. Local issues should be directed to the Press Officers working on division. From time to time officers in the course of their duty, may be asked by journalists for information about routine operational issues and those authorised by their department or division can respond with factual information within the National Police Chiefs Council (NPCC) guidelines. In these cases, to ensure consistency the Press Office should be made aware of the information given. For other than routine issues, the duty Press Officer can be contacted 24 hours a day through the Press Office. Senior officers can also contact the head of Press Office or head of corporate communications at any time.

3.10. The potential for media publicity should be considered at the earliest stages of planning for operations and activities, through liaison with the Press Office for force-wide operations and activities, or the local Press Officer for local issues. In all cases adequate notice should be given.

3.11. The Press Office will advise on key messages, sensitivities and legal issues and if necessary consult with the legal services department.

3.12. If legal or operational reasons make it inappropriate for Kent Police to give certain information to the media, the Press Office should be informed so they can then liaise with journalists to explain why.

3.13. Spokespeople should never say ‘no comment’, but should make it clear why Kent Police is unable to say anything. If there are thought to be good legal or operational reasons not to comment, advice should be sought from the Press Office, who will, if necessary, consult the Legal Services department.

3.14. Interviews, statements or comments must be made in plain English, avoiding police jargon at all times. This is essential if Kent Police is to communicate effectively across the community. For example, people are people, not persons; they are men and women, not male or female; they walk, run or go rather than proceed or make off.

3.15. Any interviews, statements or comments must comply with force policy. In particular, care must be taken on issues relating to equality and diversity, taking into account sensitivities around specific groups and their needs. The content and language used must reflect this.

3.16. In line with Kent Police’s commitment to citizen focus and protecting and serving people in the county, the appropriate contact numbers for Kent Police should be offered when issuing information or press releases.

3.17 Spokespeople

3.17.1. Where interviews are requested or statements issued on strategic or force policy issues, the spokesperson will be the relevant national lead or other chief officer.

3.17.2. At operational or divisional level, the spokesperson will be the relevant officer or manager.

3.17.3. Where possible, any statement or comment issued should be attributed to the nominated spokesperson.

3.17.4. Media training will be offered to likely spokespeople, including senior officers and managers, individuals identified as having key public-facing roles and those best placed to speak on behalf of the force.

3.17.5. Press Officers will arrange interviews and statements, but will not act as named spokespeople. They will not, other than in the most exceptional circumstances, be put forward for interview.

3.18. Release of personal details of victims or witnesses of crime

3.18.1. The role of publicity in solving crime and helping to bring offenders to justice is well recognised. However, it is also recognised that individuals are entitled to privacy and their wishes should be respected. Inappropriate information released at the wrong time could also compromise sensitive investigations.

3.18.2. The severity or nature of a crime may require Kent police to seek publicity. Victims and witnesses will not generally be identified without consent. However, where beneficial to any publicity, such as an appeal for information, this will be explained to a victim and their consent would be sought. Where appeals for information are made, it may be considered an operational need for a witness who officers believe to have important information to come forward and their image may be released if all other methods of identifying them have failed. It could be argued on public interest grounds that publicity is warranted, and this must be referred to the Legal Services department.

3.19. Release of personal details from road traffic incidents

3.19.1. Kent Police will follow the College of Policing’s approved professional practice guidelines regarding road traffic collisions and other incidents.

3.19.2. Press Officers or officers at or in charge of the scene or subsequent collision investigation can confirm it has happened, the number and type of vehicles involved (such as lorry, car, van or manufacturer), where it happened and whether there is an appeal for witnesses.

3.19.3. Where there are fatalities or serious injuries to people the details should not be confirmed until the next of kin have been informed. Details to be released on the incident should be agreed with other emergency services and can include the number of people killed or injured. Initially the Press Officer or officer involved can confirm there are casualties, explain how they have been taken to hospital.

3.19.4. Personal details of people who have been killed or injured must not be released or confirmed to the media until formal identification has taken place and next of kin have been notified. With non-fatal road incidents the principle governing the release of names and addresses is the same as that for crime victims.

3.19.5. When considering publicity for a crime, road collision or any other incident, consideration of those involved should be taken into account from the outset and balanced against the public interest. Those involved include the victim or victims, witnesses and next of kin. Anything published must be in accordance with the Data Protection Act 2018 (DPA) as it relates to the relevant parts of the General Data Protection Regulation (GDPR), or the Law of Enforcement Directive (LED).

3.20. Deaths (other than in road traffic incidents)

3.20.1. It is important to consider the effect on relatives when releasing information on the circumstances surrounding someone’s death. In the case of suspicious deaths or fatal industrial injuries, for example, personal details will not usually be released until formal identification has taken place and the next of kin have been notified.

3.20.2. It should also be recognised and respected that some families may wish to speak to the media to pay tribute to the person who has died.

3.20.3. Spokespeople should not speculate about the cause of death and must restrict any comment to factual information.

3.20.4 It is important to remember that journalists will be expected to comply with their professional code on intrusion into people’s grief.

3.20.5. Where a death is referred to a coroner it is important not to speculate about the circumstances as this will be a matter for a subsequent inquest.

3.21. People under investigation

3.21.1 The force follows the College of Policing’s approved professional practice when responding to media interest in people under investigation.

3.21.2. Kent Police will not confirm to the media that someone they name is helping police with their enquiries, is under investigation or has been arrested. Kent Police does not confirm the identity of anyone who may, or may not, be the subject of a criminal investigation and who has not been charged. It is the journalist’s risk and not that of Kent Police if they choose to broadcast or publish information that is not confirmed by the force.

3.21.3. Kent Police will seek to advise anyone under investigation if no further action is to be taken, before responding to media enquiries accordingly. Kent Police will not detail allegations not already published if no further action is to be taken in a case against a suspect.

3.22. People who have been charged

3.22.1. When someone has been charged their name, age, occupation (if relevant), details of the charge and when they are to appear in court will normally be given. Enough details must be given to fully and accurately identify the charged person to avoid the risk of inadvertent libel of someone of the same name. The charged person’s home address, including the road, town or village, but not the number of the house will also be given, unless there are legal or operational implications in doing this. Where there are exceptional circumstances, authority should be sought from the Legal Services department.

3.22.2. Caution should be exercised before releasing details of an individual where it may be anticipated a court will enforce reporting restrictions or where legal constraints will be imposed. For advice in such cases, contact the Press Office who in turn may consult with the Legal Services department. In particular details of a person who is charged with an offence should not be released if that person is a juvenile or if naming the person could lead to the identification of victims of sexual offences.

3.22.3. No further details must be given. This is to avoid prejudicing a case and being in contempt of court. The name of someone cautioned for an offence should not be confirmed. However, it is possible to confirm that ‘a man’ or ‘a woman’ has been cautioned for a certain offence.

3.22.4. Kent Police should not identify individuals as being the subject of police attention until or unless they have been charged with an offence. The only exception is where someone is named as ‘wanted’.

Personal details of people who are convicted should not remain on the force website for any more than one month after conviction. This assumes they are not juveniles, naming would not lead to identification of victims of rape or child abuse and there are no outstanding court-imposed reporting restrictions. The situation must be reviewed immediately if there is a change in circumstances within a month, for example, if an appeal is being lodged or further charges or allegations are made against any of the people named. In these situations, any website entry must be carefully checked to avoid the potential risk of contempt.

3.23. Sex offenders

3.23.1. Legislation relating to sex offenders has generated significant media interest in the whereabouts and activities of people convicted of sex offences. Any such enquiry should be referred to the Press Office who will liaise with the lead specialist officer, Legal Services and, where appropriate, with other agencies including the Probation Service. Any Multi-Agency Public Protection Arrangements (MAPPA) will be taken into account and any responses will be in accordance with the College of Policing’s approved professional practice.

3.24. Multi-agency incidents

3.24.1 Kent Police spokespeople will not comment on issues that are the responsibility of other agencies, unless this is agreed as part of a multi-agency response.

3.25. Providing media access to Kent Police personnel, information or images

3.25.1. From time to time Kent Police offers journalists facilities to accompany officers on operations. Sometimes the media may request facilities themselves, for example linked to documentaries and features. Offering facilities can play a key part in reassuring the public we are dealing with issues of concern. However, when deciding to offer or agree this facility, it is important to consider operational, community and legal implications. The public benefit, or otherwise, of offering such access must be the prime consideration.

3.25.2. Where permission is granted, the media representatives (journalists/ photographers/film crews) should be briefed in advance by a Press Officer and relevant senior officer. This is often done by inviting journalists to attend a final operational police briefing. Journalists should be briefed to give them background information, convey key messages and ensure they are aware of any potential sensitivities or risks. However, media representatives should also, before the start of any operation or briefing, sign the Kent Police media agreement. If a media representative declines to sign the media agreement, they cannot accompany Kent police officers on the operation.

3.25.3. From time to time police images of operations are released to the media to highlight success, reassure or inform the public about how we are dealing with issues of concern to them. This must only be done with the permission of the OIC or SIO. Photographs or video footage must not identify defendants, show evidence or in any other way compromise potential court proceedings.

3.26. Pre-trial and pre-verdict media briefings

3.26.1. Kent Police may hold pre-trial or pre-verdict media briefings for exceptional cases. This will be in full consultation with any agencies or organisations that may have an interest and will support the supply of information and materials to be used at court. The overriding principle is that nothing will be done that might prejudice a trial.

3.26.2. It is recognised that both pre-trial and pre-verdict briefings are a useful tool to provide accurate information for the media. This in turn helps generate well-balanced and informed reports about court cases. It is also an opportunity for senior officers and investigating officers and their teams to give on the record interviews at one sitting as well as being on hand to offer guidance to journalists with outstanding queries.

Pre-trial briefings can only take place on a basis of trust and mutual understanding. Media must sign the Kent Police media agreement that acts as an indemnity before they can attend. Journalists must also be reminded of their obligations under the Contempt of Court Act 1981, which restricts what they may be able to report, and any other relevant legislation. If specific reporting restrictions are in place, media will be made aware that restrictions exist. However, media will be expected to consult with the court for details of the restrictions and seek legal advice from their respective organisations on what is and is not reportable.

3.26.3. Relevant materials intended for court proceedings and used for pre-trial and pre-verdict briefings will be compiled for the media in full consultation and with the approval of the Senior Investigating Officer (SIO) and Legal Services and after discussion with the Crown Prosecution Service (CPS). In particular cases it will also be necessary to consult with the force’s chief officer team.

3.26.4. Materials may include, but are not limited to, a history of the investigation, image(s) of the offender(s), approved image(s) of the victim(s), image of the SIO, relevant CCTV or other moving footage or still photographs and in some cases, audio recordings. Materials to be released will form Crown evidence being presented to the jury. Circumstances may arise where the SIO or Prosecution Counsel makes a case to withhold certain materials for operational reasons. Materials will not normally be released at pre-trial briefings, but some may be considered suitable for release at pre-verdict briefings. Agreement must be reached on what materials are suitable before any briefings are held – for example, Legal Services or an SIO may have good reason not to release an individual’s image before conviction, even though the media’s intention is that it will not be used until after a verdict.

3.26.5. A record will be kept of any meetings or decisions to hold a pre-trial or pre-verdict briefing and a register will be kept of all journalists who attend any briefing. A written, audio or video record of the briefing will be made. Copies of the proceedings will be supplied to the CPS and the Legal Services department if required.

Information provided by the police to the media will be confined to the facts of the case and/or individuals. There should be no speculation about events or individuals, which could prove harmful. For example, it is acceptable to say a defendant or witness was shocked by a particular experience but not that he or she was or is receiving any medical treatment related to the condition. The defence could use this as a sign of instability or unreliability.

3.26.6. Any information provided by Kent Police to the media will be in compliance with the Human Rights Act 1998 and the Data Protection Act 2018 (DPA) as it relates to the relevant parts of the General Data Protection Regulation (GDPR), or the Law of Enforcement Directive (LED).

3.26.7. Under no circumstances should sensitive or confidential material be released to any member of the media either formally or informally.

3.26.8. Further advice on briefings may be obtained from the head of Corporate Communications or head of Press Office.

3.27. Public comments by police – post verdict

3.27.1 The media will often look for a ‘court steps’ response after a verdict is reached in court cases. Convictions are an opportunity to highlight the good work of Kent Police. Officers should consult with Press Office before doing interviews to agree what will be said.

3.27.2. Occasionally, an officer may have already given an interview at a pre-verdict briefing and will not feel he or she has anything to add. In some cases it is often better to repeat an interview than to decline the opportunity, for example, a good sentence or comments made by the judge in court.

3.27.3. Where a trial results in acquittal(s) the officer in the case should consult the Press Office. It is possible a statement may be more appropriate. It is important that extreme care is taken to ensure nothing is said that suggests police disagree with the verdict.

3.27.4. Depending on circumstances, it may be appropriate to say that Kent Police accepts the court’s decision, but if any new evidence comes to light it will be examined on its merits. Or a general comment that Kent Police has taken note of the court’s decision/the comments of the judge/coroner and will now consider in more detail the comments/decision. After careful consideration of the facts it is possible that agreement is reached for a further statement to be issued at a later date.

3.27.5. The officer in charge of an investigation that is subject of court proceedings should always consult with the Press Office, with good notice and in advance of the case whenever possible, where there is media interest or where publicity is sought. The Press Office can help in the preparation of responses and press releases with relevant materials as appropriate.

3.27.6. Kent Police Press Office will look to actively promote successful convictions where appropriate, including the use of audio, video, still images and CCTV where available and appropriate.

3.28. Media appeals

3.28.1. To help identify or trace suspects or witnesses, and missing people, an OIC, SIO, Inspector or HQ department head may agree to the release of video, film or photographs of an incident to the public through national, regional or local media. Appealing for witnesses and information in the media is a legitimate line of enquiry for investigation purposes, as endorsed by the College of Policing.  

3.28.2. When such a broadcast or publication is made a copy of all material released must be retained in compliance with the Police and Criminal Evidence Act 1984 (PACE) and it’s codes of practice.

3.29. Release of photographs to the media

3.29.1. The media should make every effort to acquire a photograph of a defendant at the time of their court appearance. This may not always be possible, and police custody photographs may be issued at the time of custodial sentences following court proceedings if it is proportionate to do so.

3.29.2. No photograph of a defendant is to be issued without the authority of an OIC or SIO. In considering whether or not to release the photograph of a defendant, due regard must be given to:

• Regulation of Investigatory Powers Act 2000 (RIPA)
• Human Rights Act 1998 (HRA)
• Data Protection Act 2018 (DPA) as it relates to the relevant parts of the General Data Protection Regulation (GDPR), or the Law of Enforcement Directive (LED)
• College of Policing’s approved professional practice
• any other relevant legislation
• implications for any future court proceedings

3.29.3. Kent Police may also release other images/footage relating to a case following court proceedings.

In court cases, any photographs of those convicted being released into the public domain will generally only be released after sentencing and authorised by an SIO or OIC. Photographs will only be released where identification will not be an issue in a known appeal.

3.29.4. Photographs and/or any audio-visual material deemed of an explicit and potentially distressing nature to the public and/or families of victims by the SIO will not be released to the media under any circumstances. If any disclosure is being considered at any time there will not be any release without a documented consent process with senior officers, victims or their next of kin.

3.29.5. Media organisations seeking Crown exhibits owned by Kent Police and used as part of the court process, which are deemed unsuitable for release to media within this policy by the SIO, will be referred to the Crown Prosecution Service or court.

3.29.6. Other than in exceptional circumstances, a defendant’s photograph will only be released contemporaneously and generally within seven days of sentencing.

3.29.7. Photographs and images are released on the understanding they will be used contemporaneously. Kent Police retains copyright on photographs and images and they must only be published once and not republished without the written authority of Kent Police. Media are advised to abide by these conditions and a disclaimer will be sent with all photographs and images released by the Press Office.

3.29.8. Any photograph or image that meets relevant criteria for release by the police must have had the identity of the individual visually verified by the relevant case officer or a nominated officer. No image can be released until this process has taken place and a written record of visual verification obtained and recorded by the Press Office.

3.30 Photographs after death

3.30.1. There will usually be no publication of photographs taken after death, other than for internal police use only.

3.30.2. Any pictures used for public circulation will either be recent photographs or created using techniques such as computer generated images and artists’ impressions. Where possible the wishes of next of kin, if the identity of the person who died is known, will be respected.

3.30.3. Pictures of people who have died must only be published with the authority of a detective of at least superintendent rank. This may be for identification purposes.

3.30.4. The Serious Crime Directorate at force HQ can be contacted to obtain advice and assistance with regard to computer generated images and artists impressions. This includes the potential use of an ‘age progression’ computer at the National Missing Persons Helpline, which can provide photo-sketches showing the most likely recent appearance of the dead person.

3.31. CCTV images

3.31.1. CCTV images should only be issued to the media on the authority of the senior or investigating officer. This may be to identify a possible offender or to trace witnesses. Where necessary the senior or investigating officer will obtain permission from the copyright owner to release any images. Wording issued with the CCTV should not attribute blame to the person/s featured in the image(s) but should suggest the person/s featured may be able to help with police enquiries. This is so not to affect any future court proceedings which may result from the publication of the image(s).

3.31.2. The identity of any member of the public not connected with an inquiry must be obscured visually. This would include passers-by who are not sought as witnesses or those who have already come forward.

3.31.3. CCTV images will only be released on the understanding that they will be used contemporaneously. The owner retains copyright and the image must only be published once and not republished without written authority. Media are advised to abide by these conditions and will be sent a disclaimer to this effect with each image.

3.32. Media requests for information from non-recent serious crime cases/cold cases

3.32.1. Where requests are made by the media for information about past or ‘cold’ cases, the Press Office will liaise with the relevant officer in the cold case investigation team, within the Major Crime department, as appropriate.

3.32.2. Serious crime offences can be defined as any major crime offence such as murders, rape, kidnap, or where the seriousness of the case would draw media attention due to extreme uses of violence, large financial loss, or new or unusual investigative or forensic technique.

3.32.3. This includes those offences where a trial has taken place irrespective of conviction or acquittal and any unsolved cases which are no longer subject of a major investigation but remain open pending any further information and/or evidence. Particular care must be taken when dealing with cases of acquittal.

3.32.4. If someone is subsequently charged with such an offence, then previous disclosure of information to the media could become an issue at court.

3.32.5. The decision whether to release information or give police assistance to other forces will be made by the Head of Major Crime or above.

3.32.6. Legal advice should be sought from the Legal Services department if required.

3.32.7. Before information is released or a decision is made to provide information to the media, every reasonable effort must be made to contact any close relative of the victim, and the family’s permission must be sought.

3.32.8. In practice this will mean contacting the most senior and responsible family member, as identified by the family liaison officer and senior investigation officer. If a child is the only surviving relative, then their guardian or an appropriate and responsible adult should be involved in the decision.

3.32.9. Having contacted the close relative, the police are absolved of responsibility for contacting other relatives/friends/neighbours, as this must be the responsibility of the relevant family member.

3.32.10. Every effort will be made to keep the relevant family member informed of developments, such as the date and time of broadcast or publication and, if possible, a guide as to its likely contents.

3.32.11. In the event of a conflict between the wishes of the relatives and police, it is the detective chief superintendent, Serious Crime Directorate, or above, who has the final decision whether to release the information or not to the media. Kent Police shall not oppose the wishes of a victim’s family, unless there are sound legal and operational reasons to do so, such as the need to obtain publicity in an unsolved case to prevent or detect crime.

3.32.12. Any release of information to the media must comply with relevant legislation. Journalists should be reminded of their relevant codes of practice. It is recommended, as ‘good practice’ that the Human Rights Act 1998 ‘Decision Considerations’ JAPAN (Justifiable, Appropriate, Proportionate, Auditable, Necessary) is used in order to determine if the information can lawfully be released.

3.33. Material to be released

3.33.1. In the first instance, all requests by the media for information and police assistance in the production of film, television or radio programmes, or the publication in a book, magazine or newspaper of old serious crime offences and or investigations of such cases must be forwarded to the Press Office.

3.33.2. It is highly unlikely, in any circumstance, that case files and their contents will be given to the media. The detective chief superintendent, Serious Crime Directorate, HQ, in consultation with the Press Office and the SIO, where practical, will decide what information to release and the form it should take.

3.33.3. Care must be taken when considering the release of items with potential evidential value.

3.34. Use of defendant’s image

3.34.1. The use of a defendant’s image can assist in presenting an open and accountable criminal justice system. A defendant’s image will only be included in a feature in the following circumstances:

• images of defendants appearing at magistrates courts may be used from the custody process at the time of arrest to publicise the result of a case, if it is proportionate to do so
• Corporate Communications will check with the OIC to ensure the image is the correct one before it is published
• each correspondence with an image will carry a copyright notice for ‘Kent Police’

3.34.2. Photographs of convicted offenders are issued by the Corporate Communications department on the strict basis that they are used only in connection with the story that prompted the request for the picture. They are not for use as library images and media organisations that use them as such face having all future requests for pictures refused.

3.35. Publicising sentencing outcomes

3.35.1. It is known that the public has greater confidence in police and the wider criminal justice system, when they receive or access information about sentencing outcomes. Kent Police supports the publication of sentences given in both Magistrates and Crown Court, provided each case is considered against the guidance set out in this policy.

3.35.2. This policy has been developed in line with guidance from The College of Policing’s approved professional practice. Additionally, taken into account are the following criteria:

• Data Protection Act 2018 (DPA) as it relates to the relevant parts of the General Data Protection Regulation (GDPR), or the Law of Enforcement Directive (LED)
• The Human Rights Act 1998

3.35.3. Vulnerable offenders – It may not be appropriate to release information about a vulnerable offender e.g. one who is considered to have mental health issues and is detained under the Mental Health Act, or someone who has mental health problems or learning disabilities recognised by a court, where publicising the conviction warrants adverse consequences. Publication may be a breach of their or their family members’ human rights.

3.36. Images used in promotional publicity material

3.36.1. Photographs used in Kent Police publicity material must reflect the diversity of the community in Kent and of the Kent police workforce.

3.36.2. No photograph for promotional use must be published by Kent Police showing members of the public without having the signed consent of everyone pictured. Consent forms that comply with the relevant legislation are available from the Press Office. Separate forms for parental consent must be used when pictures are taken of children for publicity purposes. Any individual approached for consent must be made aware of the form and context in which it will be used.

3.36.3. The release of photographs should only be considered when there has been significant public interest or where the opportunity exists to reassure the public or raise awareness of the role Kent Police played in a particular success. Where the image is of, or includes, a member of the public not connected with the case or incident, their signed consent for its use in publicity must be obtained. The form for this can be obtained from the Press Office at HQ.

3.36.4. Relevant legislation such as the Human Rights Act and the Data Protection Act 2018 (DPA) as it relates to the relevant parts of the General Data Protection Regulation (GDPR), or the Law of Enforcement Directive (LED) will also apply to the use of images of members of the public.

3.36.5. No photograph intended for promotional use must be published by Kent Police of police officers or staff without the individual’s knowledge. There is an assumption that officers and staff in local policing with responsibility for neighbourhood(s) consent to their photograph being used on the Kent Police website and used within local publicity material such as newsletters. This has been introduced as a contractual obligation for police community support officers (PCSOs). Consent should be sought where no contractual obligation exists. The consent form should be completed and signed in the usual way.
The Kent Police Federation and Unison have been consulted and endorse the stance.

3.36.6. Where exceptional circumstances exist, officers or staff can notify their divisional commander via their line manager on form 1068 to explain why they feel it would not be appropriate for their photograph to be used on the website and/or on publicity material.

3.37. Administration
3.37.1. Sentencing outcomes are posted on the Kent Police website for around one month.

4. Equality Impact Assessment (EIA)

4.1. This policy has been assessed with regard to its relevance to race and diversity equality. As a result of this assessment the policy has been graded as having a low potential impact.

5. Consultation

• Human Resources
• Finance
• IT Security
• Estates
• Health and Safety
• Legal
• Freedom of Information
• Equality and Diversity

6. Monitoring and review

6.1. This procedure will be reviewed by the head of Press Office every two years. The next review will be June 2025.

7. Other source documents

7.1 Kent’s media policy is based on the College of Policing’s approved professional practice, which should be referred to before any dealings with the media.

8. Security

8.1. Kent Police have measures in place to protect the security of your data in accordance with our Information Management policy (Policy W1000 – Information Management).

9. Retention and disposal of records

9.1. Kent Police will hold data in accordance with our Records Review, Retention and Disposal policy (Policy W1012 – Records Review, Retention and Disposal).