Protecting children's privacy in a fast changing digital world

You may have seen some comment recently about the decision Goodstart made in October 2025 to press pause on commercial photographers taking ‘class’ photos in our centres. 

At Goodstart, we have strong protections in place for the storage, retention, and destruction of children’s images. We made this class photos decision because we wanted to be completely sure that the tens of thousands of images taken by those external photographers were being safely and securely stored.  We know from the work of Australia’s e-Safety Commissioner that it is incredibly important in the AI era that all steps are taken to prevent photos of children carrying serious risks, including of child exploitation, AI manipulation into fake explicit material, possible data harvesting by perpetrators and long-term loss of privacy. 

This year our centre teams have been busy ensuring they are meeting the new digital safety model code for the use of electronic devices in our learning spaces. It’s been a major investment in time and money to implement the new code which is designed to help keep children safe. 

While the code provides better protections like banning personal mobiles from learning spaces, we’ve gone a step further, deciding Goodstart’s corporate team will not carry mobile phones or other electronic devices into learning spaces unless they are required to do their work. 

To stay ahead of emerging technology, we continually review and improve our cyber-safety framework.  

In practice, that means our policies make it clear that images must be held in approved Goodstart systems rather than on personal devices or personal accounts, that access is limited and images are not held for longer than required. 

Where we rely on an external provider, we expect them to meet our high standards, and we require information on image storage, access and how long the pictures are held until they are destroyed. 

This approach sits alongside the work we do to meet our obligations under the Privacy Act and the Australian Privacy Principles. This ensures we notify families and regulators if information is ever compromised, that we meet the national child safe standards, and that we’re compliant with the record-keeping rules under the national law. 

We expect to see further changes to the law to protect children’s information. A new Children’s Online Privacy Code will set clearer expectations for how all organisations collect, use and store children’s personal information online. We are already doing the work to make sure Goodstart is ready to meet the new rules.  

Goodstart is also working closely with Storypark which has signed agreements with our families to allow educators and teachers to share images of children’s learning with families and carers via their closed platform. This work has included new measures in an effort to ensure images of children are even more secure and cannot be copied via screen shot on the Storypark app. 

We’ve also been thinking about our responsibilities as a high quality provider when it comes to the photographs and videos we use to talk about our centres and the extraordinary work they do. Photographs have always been an important part of our work right across the early learning sector – they help us explain what we do, connect with families, and celebrate children’s uniqueness and achievements. We understand how important they are to families. 

Many of our teams are already actively engaged in creating thoughtful, informative photographs which demonstrate children’s learning and development. Photographs that focus on the activity and the learning environment. Pictures that show children at a distance rather than up close. 

In September 2025 we also made a decision to only use employed paid child actors in our national marketing campaign. We had expert teaching and learning and child safety advisors on site when the campaign was shot who worked to ensure that the children were happy and engaged. We will continue to do this for all our major campaigns. 

There’s more to do, and during National Child Protection Week our Head of Safeguarding, Sara Evans, and our Chief Children’s Officer, Professor Cathrine Neilsen-Hewett, will be working with our educators and teachers to explore pedagogical practices with digital technologies while considering safeguarding young children and upholding their rights. 

With new guides under development, we look forward to sharing some advice with families and visitors to our centres very soon. 

The pace of change, and the power of AI to manipulate and distort images, demands deep thinking and thoughtful responses. We will continue to work with experts, our families, and our teams on this journey as we explore new ways of celebrating the vital work our educators and teachers do in supporting children’s development and their joy as they learn.