A clinic wants to show what it does, and images help. But a photograph of a patient is not just any image. Saying or suggesting that someone was treated at a clinic may reveal health data, which data protection law treats as a category with reinforced protection. So it is worth thinking before publishing, not after.
Why it is a sensitive subject
An image in which a person can be recognised is personal data. Linked to a treatment or a clinic, it may reveal information about that person's health. To publish it you generally need consent that is freely given, informed and specific, and that can be withdrawn at any time. A signature on an admission form at the appointment is not usually enough. In addition, professional bodies have their own rules on advertising and on the use of patient images.
What can normally be shown
- The space: reception, waiting rooms, treatment rooms, without recognisable people.
- The equipment, without patients.
- The team, with written authorisation from each person and the possibility to withdraw it.
- Illustrations and infographics that explain a treatment.
- Stock photographs from image libraries (photo websites), licensed for commercial use, not suggesting they are the clinic's patients.
- Videos of professionals explaining a subject, where the face is the professional's.
What needs extra care
- Before and after images, especially when they suggest a guaranteed result.
- Testimonials with images of patients.
- Photographs during an appointment or in the background, with patients visible or heard.
- Children and minors: consent comes from those responsible, and the care should be greater still.
- Posts on the team's own social media showing the day's work.
If you really want to use patient images
- First confirm whether your professional body allows it, and under what conditions.
- Use a consent document of its own, not part of the patient's clinical record: it says which images, in which channels and for how long.
- Explain that consent is free, that the person can refuse without consequences for treatment and that they can withdraw it.
- Keep proof of the consent and remove the image as soon as it is requested.
- Ask a data protection professional or a lawyer to review the process.
This article gives general principles and does not replace legal advice, nor the rules of your professional body, which may be stricter.
To organise the rest of the page, see what the page for each clinic service should include. For the texts, how to talk about specialties without promising results. And the overall picture is in marketing for clinics. We also work with clinics: we look after what happens before the appointment, such as the Google profile, the service pages and reviews.
A ten-minute audit
Open the clinic's website and Instagram and go through them from top to bottom. For each image with people, ask three questions: who is it? Do I have written authorisation? Can I still show it? Note the doubts on a sheet and deal first with those involving patients. Imagine a clinic (an invented example) that finds a photograph of a treatment room with a person lying down, seen from behind, but with a visible tattoo. Even without a face, the person may recognise themselves and be recognised: the image comes down, or authorisation is requested. Repeat the audit every six months.
In short
- An image in which the patient is recognisable is personal data, and may reveal health data.
- You can show the space, the equipment, the team (with authorisation) and illustrations.
- Patient images need specific, written, withdrawable consent.
- Confirm your professional body's rules; this article is not legal advice.
Quick questions
Can I show a photograph without a face?
It depends. Tattoos, scars, context or a caption may make the person recognisable. If there is a risk of identification, treat it as a patient image.
Can the team appear in photographs?
They can, with written authorisation from each person, freely given and with the possibility to withdraw it. When someone leaves the clinic, it is worth reviewing the images.
What about photographs a patient posts about the clinic?
If they are the patient's, the decision is theirs. If the clinic wants to share them, it needs authorisation, and should avoid asking in a way that feels like a condition of treatment.
Want to review the images the clinic has published?
The exploratory call is a 30-minute conversation, at no cost. We go through the clinic's published images and the authorisations that exist with you. You keep the written summary.
Book an exploratory call