ARTICLE · 26 NOVEMBER 2025

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With the year coming to end, many companies will be hosting year-end events to celebrate and close off the year. During these festivities, memories are often being captured in photographs.

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With the year coming to end, many companies will be hosting year-end events to celebrate and close off the year. During these festivities, memories are often being captured in photographs. These may end up being circulated internally for employees to enjoy, posted on company LinkedIn pages or maybe even used in the company's marketing materials. However, just because these images are captured at a work event or for fun, does not mean that data privacy law does not apply.

Under the Protection of Personal Information Act, 2013 (POPIA), photos which contain information that can identify a person, are considered personal information. Photos can also inadvertently reveal special personal information of a person, such as race, ethnic origin, health and religious beliefs. When processing special personal information, responsible parties need to take extra precautions to ensure that the processing of such special personal information complies with POPIA.

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