A GDPR-friendly client gallery
Under the GDPR the photographer is the controller of personal data in client photos, and a gallery service is a processor that needs a data processing agreement (Article 28). In SilverAlbum (silveralbum.art) that agreement is § 12 of the terms and applies to every account; photo files are stored in the EU, and there is no face recognition — no biometric processing under Article 9.
Who is responsible for what
- You
- A lawful basis (contract, consent for likeness), information for clients, and the decision who gets the link and password.
- SilverAlbum
- Secure storage, serving files only to authorised visitors, confidentiality, help with data subject requests, breach notification.
- Your client
- Views and downloads. No account; when selecting photos they give an email so the selection is signed.
Why face recognition is a problem
This isn’t legal advice. For unusual jobs, ask a lawyer.
Finding guests by face means building a biometric template of every person in the photos. Biometric data used to identify someone is special-category data under Article 9 GDPR, which needs explicit consent from each person or another narrow basis.
At a wedding that is a hundred guests; at a school shoot, children. So SilverAlbum doesn’t offer it and won’t: a likeness stays an ordinary photo.
A practical checklist
▸ 1
Client contract
State where and for how long you share photos, and who may view them.
▸ 2A
Processing agreement
Check your gallery provider has one. In SilverAlbum it’s § 12 of the terms.
▸ 3
Access
Password-protected gallery, a separate guest password, private frames hidden.
▸ 4A
Lifetime
Galleries expire after 12 months; deleting an account deletes the files.
GDPR questions
Do I need a data processing agreement with my gallery provider?
Yes, if the provider stores photos of your clients on your behalf. In SilverAlbum the agreement is § 12 of the terms and applies from sign-up.
Are SilverAlbum’s photos stored in the EU?
Yes. Photo files are stored in Cloudflare R2 in the EU region.
Does SilverAlbum train AI on my photos?
No. The terms explicitly exclude using your photos to train machine-learning models or to promote the service.
Do galleries show up in Google?
No. Password and link-only galleries are not indexed. Only what you mark as public in your portfolio can appear in search engines.
What if someone in a photo asks for it to be removed?
The request goes to you as the controller. You can delete or hide the photo in your dashboard; if they write to us, we pass it on and help.
Read next
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