In order to ethically use a community member’s likeness in marketing photography, you should attempt to acquire their consent. 
  • If possible, give the community member ample time to respond.
  • Honor the member’s choice. 
To prevent images being used without permission, University Relations will acquire the names of those students with Family Educational Rights and Privacy Act (FERPA) holds in the Student Information System (SiS). When a student clicks on the FERPA hold, they are indicating that they do not want to be photographed. Those students without holds are assumed to be agreeable to photography on campus. No more information beyond the FERPA hold and the student’s name will be available to the University Relations Department. 
All Community Members
At the time of the photo, the marketing professional will gain consent to use of the person's likeness for marketing purposes. To ensure consent is secured without coercion, the consent should be both prior, when possible, and informed (see definitions below).
While attempts will be made to identify members featured in photos and videos, we will not be able to obtain all students, faculty and staff pictured in large group photos, such as those taken during move-in day, at UML Marching Band practice, or other major events. If a member of the community, who does not want to be photographed, sees a photographer at a public event, they should let the photographer know or avoid the shot.
In addition, if a community member wants their image removed from marketing material (when possible), they should email


Prior  - Consent is requested in advance of usage. The community member should have a reasonable amount of time to consider the request and to respond. 
Informed  - Informed consent is permission given with a clear understanding of the situation. Generally, this means the community member is informed of the variety of ways in which the photo might be used. For example, that the member’s image will be used in an advertisement on Facebook or in a student profile but may also be used in the Viewbook or on university web pages.
Consent  - Consent is permission to use a person’s image in marketing materials. Consent may be obtained in various ways, such as through email or in a conversation.
Reusing Photography 

Consent is typically secured prior to or at the time the photos or videos are taken. However, consent can be acquired later.  

Observe the following four steps. 

  1. Establish the possibility of other uses at the time of the original photograph. 
  2. Explain how and where the photo might possibly be used.
  3. Tell the community member, particularly a student, that they do not have to provide consent and that it’s okay to refuse. 

Students Opting Out

How should marketing units respond when students do not provide consent? 

Opting out through the Family Educational Rights and Privacy Act (FERPA) form, is the primary (but not the only) way that students control their own representation. Opting out allows students to control in what media they appear — if they will appear at all. 

Honor Student Choice 
Respect students’ decisions around their own representation. There are very few circumstances in which it is ethical to depict an individual in marketing materials when they explicitly denied your request.

However, it is possible to interpret a student’s opting out too broadly. When a student chooses not to participate, it may be useful to clarify the following. 

  • Quantity - Is the student opting out of one photo or every photo?
  • Channel - Is the student opting out of appearing on billboards, in social media marketing or every advertisement? 
  • Representation - Is the student opting out because they do not want to represent the GSA but will gladly represent the Chemistry department?    

NOTE: All of the above are legitimate reasons for a student to decline participation. Take care that as you are negotiating the use of a student’s image, you do not coerce them into cooperation.

Tracking Student Choice 

The University Relations marketing staff will make every effort to honor the student's choice. Information from the photographer should be shared with the marketing staffer. That information should be added to the photo when uploaded into Resource Space. Observe the following guidelines.

  • Update the digital archive. If your program maintains the DAM that staff can freely use, remove assets featuring students who have requested to opt out. This will prevent accidental misuse. 
  • Communicate with relevant partners. Ensure relevant parties are aware of the student’s decision. For example, the Office of Advancement should be informed that a student has declined to represent them in all marketing materials.

Approaching Students and Student Groups

Communicating with and recruiting students or student groups should be undertaken with conscientiousness. 

This is especially true when approaching student groups serving marginalized populations. While we believe no employee intentionally harms any student, bias can find expression implicitly and unconsciously. UMass Lowell is committed to non-discrimination, and so the below best practices aim to minimize any possibility of harm. 

  • Encourage a variety of students to participate.
  • Seek to represent a variety of students in all areas of marketing.
  • Don’t oblige students to act. 

Student groups serving marginalized populations include any organizations primarily serving UML students who identify with groups historically excluded from social opportunities. Students who identify with marginalized populations are at risk of discrimination and belong to groups that have been historically discriminated against. This is true within the United States and at UMass Lowell. 

Non-Coercive Communication

Because employees may be viewed as figures of authority, care must be taken so that communications are not coercive. Coercion is obliging another to act, often by compulsion. For example, telling a student “You are required to appear in an advertisement.”

Observe the following guidelines:

  • Present choices as choices. Clarify that your requests are optional. (“This is your choice. You don’t have to participate.”) Emphasize student power. (“We can meet at a time convenient for you.”) 
  • Clearly define each choice. Do not disguise the options you present. For example, the option may not be “Tell us about your dorm room in a video,” but actually “Appear in an advertisement promoting residence halls to potential students.” 
  • Express all choices. Do not omit options, even if they may seem obvious. 
  • Make students aware of their rights. Emphasize that students are not required to participate.
  • Be aware that you know more about university processes than students.  Coercion is often not intentional but happens through forgetfulness. You may not mention that alternative options exist because you assume students are aware. Therefore, too much explanation is better than too little. 
  • Be aware that you may be seen as a figure of authority. Students may feel obliged to do something simply because an employee asks. This does not mean stop asking but rather be aware of such pressures.

Commitment to Diversity 

It is important to seek diversity in marketing materials because it represents the community we are and want UMass Lowell to be — but it is important to have the right intentions too. Aim to represent diverse populations because it empowers those groups and those students. Do not incorporate students with disabilities into your photos just because it looks good or checks a box. Instead ask yourself, “How is this photo advancing these students’ interests?”  

Manufacturing diversity is inauthentic to the university’s mission, to students’ experiences and to the target audience.    


Directly recruiting students can be coercive and result in inauthentic representation. To avoid these issues, make use of passive recruitment tools, like the Student UML Announcements or group communications from Student Affairs staff, and emphasize student choice in your outreach.

Recruiting student volunteers requires deliberate outreach. However, thoughtful practices recruit student volunteers who are more eager and helpful. 

  • Be transparent.
  • Intentionally make your outreach inclusive.
  • Don’t target students to create visual diversity.
Before Performing Outreach
  1. Identify & cultivate recruitment channels - Volunteer recruitment should mostly be relationship management, with occasional requests for participation. It is easier to recruit volunteers when you have maintained open channels to student groups, offices serving students and an existing volunteer list.  Just as importantly, open channels allow students to provide feedback, to stay informed of their rights, and to control their own representation. 
  2. Determine the scope of your project. Establish the details of your photo or video shoot (length, location, activities, etc.). As much as possible, outreach materials should include concrete expectations.

Student Volunteer Outreach 

  • Direct outreach  - Attend the meeting of a student group. Be clear about expectations and usage. Do not require students to sign up in the moment but instead provide business cards or an email. 
  • Print & digital marketing  - Every effort will be made to relay photo or video shoot information before the shoot. Explain the following: 
    1. Dates, times and contact information.
    2. Purpose of the photography/videography. For example, “Your image will be used on social media to promote the XYZ Club.” 
  • Student Ambassadors - Reach out to student leaders that represent student groups. Ask them to communicate either to a group directly or through other channels, like social media.
Refrain from directly asking a student leader to volunteer, and do not ask for a set quantity of volunteers from that student group (e.g., “Steven, will you find three students from the Hispanic Heritage Student Association to volunteer?”).

TEMPLATE | Email  

University Relations is looking for student volunteers to participate as models in a photo or video shoot. I know that you are involved with [Student Group], and I would appreciate it if you could share the details with members. No one is expected to participate and no one has to participate, but I would love to involve members of [Student Group] now or at another time. 

Thank you! 

[Photo/video shoot details]  The images will be used in [social media, print advertisements, etc.]. 

Volunteers will receive [a gift card / swag]. 

  • Mailing lists - Maintain the relationships that you develop during a volunteer recruitment campaign. Create a mailing list of past volunteers and reach out when recruiting for a new photo or video shoot. As with any mailing list, do not spam your recipients.

University Relations is looking for student volunteers to participate as models in a photo shoot. Respond to this email if you are interested.

[Photo or video shoot details]  The images will be used in [social media, print advertisements, etc.]. 

Volunteers will receive [a gift card / some cool swag].

We thank Pacific Oregon University for its Best Practices in EDI for Marketing, on which our guidelines are based.