In a nutshell
Before a pupil’s photo or name goes behind a door, check the school’s consent: the official pages in Bavaria, North Rhine-Westphalia and France ask for parents’ consent to publish pupils’ photos, the UK’s ICO says an opt-out can be enough for promotion, and the US rules turn on whether the photo is an education record. A class calendar does not need faces at all.
- US: the Department of Education’s photo FAQ says a photo or video is generally an education record when it is directly related to a student and maintained by the school, and it does not address social media or school websites.
- UK: the ICO says “if someone can be recognised from a photograph it’s usually considered their personal data”.
- Germany: Bavaria and NRW both name consent for publishing pupils’ photos, and NRW says a general consent given at school entry is not enough.
- France: CNIL answers yes to parental consent and says the agreement must be in writing.
- On the maker, you can delete a calendar yourself at any time with the edit link.
This page is information, not legal advice. It reports what official pages say, as read on October 25 and 26, 2026, and does not apply them to your school or your calendar.
This page is for a teacher, or a parent helping a class, who is about to put a class photo or children’s first names behind a door and send the link to families. It sits beside how to make a digital advent calendar: that page compares the routes, this one covers the one question the routes do not answer. The rules below come from the education ministries, data-protection authorities and regulators themselves, not from guides.
What the official pages say
| Jurisdiction | What the official page says | Page date | Source |
|---|---|---|---|
| US: FERPA | Gives parents the right to access their children’s education records, to seek amendments and to have “some control over the disclosure of personally identifiable information from the education records”; the rights transfer to the student at 18 or on entering postsecondary education | None shown | |
| US: FERPA, photos and videos | A photo or video is generally an education record when it is directly related to a student and maintained by the school or a party acting for it; a student who appears only incidentally or in the background is generally not covered, as with a parent’s photo at a football game that the school does not keep. Schools “designate photos or videos of students participating in public events” as directory information and may obtain consent from parents or eligible students before publicly disclosing them. The page does not address social media or school websites | None shown | |
| US: COPPA | The FTC’s FAQ says the rule protects “children under age 13” and treats photos, videos and audio recordings that contain a child’s image or voice as personal information. A school may act as the parent’s agent for programs used solely for the benefit of its students; the FAQ recommends that schools or districts decide whether a site’s practices are appropriate, “rather than delegating that decision to the teacher” | None shown | |
| UK: ICO | “If someone can be recognised from a photograph it’s usually considered their personal data.” Schools choose a lawful basis, usually public task or legitimate interests; for promotional use the ICO generally expects an opt-out for parents or for pupils old enough to decide, and an opt-out is not consent. Asking parents not to post other children’s photos is a policy choice, not a data-protection rule; private posts to friends and family fall outside the law | None shown | |
| UK: GOV.UK, data protection in schools | The guidance has a section on data protection when taking and using photos and videos | Updated October 14, 2026 | |
| Germany: Bavaria | Under § 46 BaySchO, personal data of people in school life, “including photos with or without name”, may go on a school website only on the basis of consent that meets data-protection law; for minors under 14 the parents consent, from 14 the minors and the parents. Class photos may go in the annual report if those pictured consented; beyond class photos consent should be sought “only extremely cautiously” | July 15, 2023 | |
| Germany: NRW | Consent is required for putting photos, podcasts and videos online; a general consent for photos given by parents at enrollment for the whole time at school is not enough; a class photo taken centrally at the start of the school year, seen by parents before publication, can be covered by one consent; consent can be revoked for the future | None shown | |
| France: CNIL, photos | A school that wants pupils’ photos in its newspaper, class directory or website must obtain the consent of the parents or legal representatives, and the page says the agreement must be in writing (“cet accord doit être écrit”) | None shown | |
| France: CNIL, online tools | The data controller decides and confirms the legal basis before a tool is used; check the tool for advertising or profiling trackers and switch them off if present; consent seems hard to hold as the legal basis in this setting; an impact assessment is probably needed in most cases | August 24, 2026 |
What the pages share, and where they differ
In Bavaria, NRW and France the pages ask for parents’ consent before pupils’ photos are published; Bavaria adds the pupils’ own consent from age 14, and France asks for it in writing. NRW is the only one of the three that says a blanket consent from enrollment is not enough. The UK is the odd one out: the ICO says an opt-out can be enough for promotion and that offering one is not consent. The US pages talk about education records and directory information, not about a consent form for a website.
On who decides, three pages agree: the school, not the teacher. The FTC’s FAQ says schools or districts should decide whether a site’s practices are appropriate. CNIL says the data controller decides and confirms the legal basis before deploying a tool. The NRW ministry says whether schools use digital systems is for the school to decide, and names Padlet among tools where it has concerns as far as personal data are processed.
Good to know None of these pages addresses a third-party calendar link. The US photo FAQ does not mention social media or school websites, and the Bavarian and NRW pages are about school websites. Read them as the school’s standard for any publication of pupils’ images, and ask the school which standard covers a link sent to families.
What that means for a class calendar
Consent first, in the school’s form. If a recognizable pupil, or a pupil’s name, goes behind a door, the school’s own consent process is the one the pages point to, and it has to cover this use: a calendar sent as a link to families. A consent worded for a yearbook or a school website may not name it, so read the wording.
Doors without faces. A riddle, a drawing the class made on paper, a read-aloud chapter and a kindness task need no photo and no name. A classroom calendar with one door per school day is built that way. The terms of the maker add one line: a user who is under age may use the service only with the approval of a parent, guardian or teacher.
A link kept to the people it is for. On the maker, anyone who has the link can open the calendar. A YouTube video set to Unlisted can be seen and shared by anyone with the link, and “link sharing has no restriction on resharing”. Send the link to the families of the class, not to a public page or a post, and put nothing behind a door that you would not want a third person to see.
Deletion after Christmas. The maker’s page says a calendar stays online at least through January and that you can delete it yourself at any time. Delete it when the class is done. Videos live on YouTube, not in the calendar, so delete those separately.
In the tool The maker’s doors hold text, an image, a YouTube video, a GIF or a link, and each door opens on its date. A class calendar with no pupils in it uses text and link doors, plus images that show no faces: a drawing, a window view, a word list. Videos are links to YouTube, not uploads. The edit link, sent once to the email address you enter, opens the calendar for changes and for deletion.
What the pages leave open
The US photo FAQ gives no rule for a teacher who uses a third-party link tool, and does not say whether posting on a website changes the answer. The FTC’s COPPA FAQ is about operators who collect personal information from children and does not say whether a calendar maker used by teachers and parents counts as directed to children. The Bavarian FAQ covers public schools in Bavaria, and the NRW page covers NRW. This page does not cover Austria, Switzerland or the other German states.
Put it in a calendar
The template for a class has 22 doors with no faces and no names: riddles, a kindness task, a read-aloud and a class job. Copy it, change the dates to your term, and send the link to families after the school agrees. Or start empty: Create your calendar.
Frequently Asked Questions
Do I need parents' consent for a class photo in a digital advent calendar?
The Bavarian, NRW and French pages ask for parents’ consent before pupils’ photos are published on school websites or in school publications. The ICO says a school may use an opt-out for promotion. The US photo FAQ says schools often obtain consent before publicly disclosing photos. Ask your school which applies to a link.
Is a class photo an education record under FERPA?
The Department of Education’s FAQ says a photo or video is generally an education record when directly related to a student and maintained by the school; a student who appears only incidentally is generally not covered. The page does not address social media or school websites.
What does COPPA say about photos of children?
The FTC’s FAQ says the rule treats photos, videos and audio recordings that contain a child’s image or voice as personal information, and that the rule protects children under 13.
Can a teacher decide alone to use an online tool with a class?
The FTC’s FAQ recommends that schools or districts decide, not the teacher. CNIL says the data controller decides and confirms the legal basis before a tool is used.
Does a consent form signed at enrollment cover a calendar?
The NRW ministry says a general consent for photos given at enrollment for the whole time at school is not enough. Whether it covers a link calendar is a question for the school.
Is an unlisted YouTube video private?
No. Google’s page says unlisted videos can be seen and shared by anyone with the link.
Can parents post photos of other people's children?
The ICO says that asking parents not to post other children’s photos is a policy choice, not a data-protection rule, and that private posts shared with friends and family fall outside data-protection law.
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