A lot of time pictures of participants are taken during a sports event. These are often sold afterwards for e.g. 10 euro each. Some people just share the watermarked image on social media.

But my question is: is it possible to use the 'right of access' to get all personal information from the photographer including the photographs.

If not, how far does the 'right of access' goes?

1 Answer 1


It should be possible to obtain any Personal Data from the owner of the image (who may or may not be the photographer), but a photograph of a sporting event may or may not be considered Personal Data as defined by 2016/679 (GDPR), depending on the purpose of its processing.

The UK Information Commissioner's Office (ICO) provides the following on page 15 of their interpretation :


At New Year celebrations in Trafalgar Square two almost identical photographs of the revellers are taken by two separate photographers and stored in electronic form on computer. The first photographer, a photo journalist, takes a picture of the crowd scene to add to his photo library. The second photographer is a police officer taking photos of the crowd scene to identify potential troublemakers. The data in the electronic image taken by the journalist is unlikely to contain personal data about individuals in the crowd as it is not being processed to learn anything about an identifiable individual. However, the photo taken by the police officer may well contain personal data about individuals as the photo is taken for the purpose of recording the actions of individuals who the police would seek to identify, if there is any trouble, so they can take action against them.

The people sharing or selling the photograph, and the owners of the medium on which they are shared, could have obligations that the photographer does not.

  • 1
    The second photo example on the linked interpretation is clearer and relates to a photo taken by a real estate agent of a shop as pedestrians pass by: "Therefore, in the hands of the estate agent, the photo does not contain personal data about the pedestrians as it is not processed to learn something about those individuals and nor is it likely to be processed by the estate agent for this purpose." So, no, a photo of someone in a crowd in this context would not be not personal data. Oct 25, 2019 at 16:10

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