Use client photographs with care
Get a specific choice before publishing an identifiable client, and remove a photo when that choice no longer supports its use.
2 min read · Updated August 28, 2026
In short
- An identifiable client photo can be personal information.
- Before publishing, get a separate choice that covers the exact images and public use.
- A replacement image needs a new choice, and a withdrawal means stopping the use that depended on consent.
A face, tattoo or other recognizable feature can make a photograph personal information. Under the Act respecting the protection of personal information in the private sector, as amended by Law 25, collecting and publishing it must rest on a clear legal basis and a specific purpose.
Before you publish
- Explain where the photo will appear.
- Explain why you want to publish it.
- Ask for a separate choice covering the exact images and use.
- Before taking or using the photo, explain where it will appear, why you want to publish it, and whether anything identifies the client.
- Ask for a separate, specific choice. Keep enough information to show which images and which use the choice covered.
- When adding a before-and-after pair, use the client's actual images and confirm that you hold the client's consent for public display. You cannot save a new pair without that confirmation.
- If you replace either image, treat the replacement as a new pair and obtain a choice that covers the new images. If the client withdraws consent, stop the use that depended on it and review every place you published the photo.