The scene repeats in every club across Brazil: camp ends, the phone is full of great photos, and someone asks, "can I post this on the club's Instagram?" The short answer is yes, as long as the parents authorized it in writing. The long answer is this article.
The Pathfinder Club serves boys and girls ages 10 to 15 — meaning every Pathfinder is a child or adolescent in the eyes of the law (staff and teens in leadership training are a different story, covered in the table further below). And when it comes to a minor's image, Brazil has three laws that work together: the LGPD (Law 13.709/2018), the ECA (Law 8.069/1990), and the Civil Code (Law 10.406/2002). None of them require notary red tape: they require a simple, clear, signed document.
Here you'll find what each law requires, a table of who signs at each age, the ready-to-copy consent text, and the step-by-step for when a parent changes their mind. It's the practical companion to child protection in the club, which covers conduct and reporting — this one covers the photo.
Do I really need a consent form to post a Pathfinder's photo?
Yes, you do. And the reason is simple: when the club publishes the photo, the one processing a child's personal data isn't the parent — it's the institution. The LGPD calls this the controller: whoever decides what happens with the data. And art. 14, §1 of Law 13.709/2018 is direct in saying that the processing of children's personal data "must be carried out with specific, highlighted consent given by at least one parent or the legal guardian."
There's an important boundary here, and it tends to cause confusion. The LGPD itself states, in art. 4, item I, that it does not apply to processing done "by a natural person exclusively for private and non-economic purposes." Translated into the club's everyday life:
- A mother posts on her own profile a photo of her own uniformed child: that's private use, outside the LGPD's reach.
- The club posts on its official Instagram, website, announcement group, or enrollment poster: that's institutional processing. That's when LGPD art. 14, ECA art. 17, and Civil Code arts. 20 and 21 come into play.
- A photo in the secretary's internal folder, without publication, is still data processing, but with a different purpose and risk. The Administrative Manual (item 3.4.1, on club secretary records) even provides that each member's individual folder should keep photos, health forms, and copies of certificates.
And what do the official manuals say? Here's where honesty matters: the Pathfinder Club Administrative Manual, from the South American Division, dedicates an entire section to marketing and publicity (section 6.1) and encourages the club to photograph activities, put up a photo board at church, create a social media gallery, and send photos to the Association's website. Except — checked page by page in July 2026 — the manual doesn't include any image consent form: the appendices run from A to F (official letters, fee tracking, letters of recommendation, and outing authorization) and the forms run from A to D (enrollment, health, club diagnostic, and unit evaluation). The enrollment form has no image clause either. In other words: the consent form is a gap each club needs to fill, following Brazilian law and the guidance of its Field.
What do the LGPD, the ECA, and the Civil Code require — article by article?
There's no single "Pathfinder photo law." There's a set of rules that, combined, form the practical standard. This table sums up what each one requires and what changes on a Friday night:
| Law | What it says | What changes at the club |
|---|---|---|
| Constitution, art. 5, X | Privacy, private life, honor, and a person's image are inviolable, with the right to compensation for material or moral damage | Image is a fundamental right, not a detail |
| ECA, art. 2 | A child is a person up to 12 incomplete years old; an adolescent, 12 to 18 | Pathfinders are 10 to 15 years old: none of them is an adult |
| ECA, art. 17 | The right to respect covers "the preservation of image, identity, and autonomy" | A Pathfinder's image is protected by a law specific to childhood |
| LGPD, art. 14, main clause | Data of children and adolescents must be processed in their best interest | If the photo exposes or embarrasses, even a signed form won't save it |
| LGPD, art. 14, §1 | Specific, highlighted consent from at least one parent or the legal guardian | A separate, visible form — not a hidden line on the enrollment sheet |
| LGPD, art. 8, §1 and §4 | If in writing, it must appear in a highlighted clause; generic authorizations are void | Purpose and channels must be listed one by one |
| LGPD, art. 8, §5 and art. 18, IX | Consent can be revoked at any time, through a free and simplified process | The club needs a "take it down" channel |
| Civil Code, arts. 20 and 21 | Art. 20: unless authorized, the publication, display, or use of an image may be banned at the request of the interested party, without prejudice to any compensation owed, "if it harms honor, good reputation, or respectability, or is intended for commercial purposes." Art. 21: private life is inviolable | The basis for a parent to demand removal and, if applicable, compensation — and written authorization is exactly what rules out the ban |
| STJ Precedent 403 | "Proof of harm is not required for compensation for the unauthorized publication of a person's image for economic or commercial purposes" | Extra caution with fundraising campaigns, raffles, and sales |
One point almost no one explains: §1 of art. 14 mentions "children," while the main clause mentions "children and adolescents." This raised questions about Pathfinders aged 12 to 15. In practice, the requirement for parental authorization still holds through two paths: the best-interest principle in the main clause, and the Civil Code, which considers anyone under 16 fully incapable (art. 3) — someone who cannot perform civil acts on their own also cannot authorize the use of their own image on their own.
It's also worth noting that ANPD, Brazil's national data protection authority, issued Statement CD/ANPD No. 1, of May 22, 2023 (published in the Federal Official Gazette on 05/24/2023), recognizing that the processing of children's and adolescents' data can rely on any of the legal grounds in art. 7 or art. 11 of the LGPD — not only consent — as long as the best interest is observed and prevails, assessed case by case. This helps the club with things like attendance lists or health forms — but it does not waive the consent form for image publication, which isn't necessary for the activity and still depends on authorization.
And the Digital ECA (Law 15.211/2025, in effect since March 17, 2026)? It changed the club's routine less than the name suggests: most of the obligations fall on platforms and providers — age verification, parental supervision, moderation — not on whoever posts something. The rule that comes closest to the club is the judicial authorization requirement, detailed by Decree 12.880/2026: it's required when a child's or adolescent's image, voice, or routine is exploited habitually in monetized or boosted content — the "child influencer" case, not the camp photo. Even so, here's a practical warning: if the club boosts paid posts with photos of Pathfinders, it has left the comfortable zone, and it's time to talk to the Field before continuing.
What makes an image consent form valid — and what voids it?
A short, well-written consent form is worth more than three pages of legalese. These are the six things the law requires:
- In writing and highlighted. The LGPD (art. 8, main clause and §1) requires a written statement, in a clause separate from the rest. It can be its own sheet or a clearly delimited block at the end of the enrollment form — never a stray sentence buried in the text.
- Specific purpose. "I authorize the use of my image" is exactly the kind of generic authorization that art. 8, §4 declares void. Spell out what it's for: promoting club activities, historical record, enrollment invitations.
- Listed channels. The club's Instagram and Facebook, website, announcement WhatsApp group, church bulletin board, printed materials, submission to the Association's website. If a channel isn't on the list, it isn't authorized.
- Term and renewal. Ideally, tie it to the club year and renew it along with enrollment — the 10-year-old who authorized it isn't the same person at 15.
- Who signs. See the table below. A signature from an older sibling, an uncle, or "whoever brought the child" doesn't cut it.
- How to revoke. The paper must include a contact (name, phone, and email) and state that withdrawal is free and available at any time.
| Age | Legal status | Who signs the form |
|---|---|---|
| 10 and 11 years old | Child (ECA, art. 2); fully incapable (Civil Code, art. 3) | Parent or legal guardian — specific, highlighted consent (LGPD, art. 14, §1) |
| 12 to 15 years old | Adolescent (ECA, art. 2); fully incapable until age 16 (Civil Code, art. 3) | Parent or legal guardian signs. Good practice: also collect the teen's agreement |
| 16 and 17 years old (TLT, aspiring leaders) | Partially incapable (Civil Code, art. 4, I) | The teen signs assisted by the guardian — both signatures |
| 18 or older (staff, counselors, instructors) | Fully capable (Civil Code, art. 5) | The person themselves. Yes, leaders sign their own too |
The detail about the teen's "agreement" isn't an explicit legal requirement — it's a reading of the best-interest principle in art. 14: a 14-year-old Pathfinder who doesn't want to appear has an opinion the club should respect. It's also the most honest, educational response — teaching that the image is theirs, and that they're allowed to say no.
Read alsoClub enrollment formReady-to-copy image consent form template
The text below was written for this article, is free to use, and covers the requirements of the LGPD, the ECA, and the Civil Code. Replace the bracketed fields with your club's information. Before printing it in bulk, show it to the club leadership and to your Field's department leader — if your Association or Mission already has its own template, the Field's version takes priority over any template found online, including this one.
IMAGE AND VOICE USE CONSENT FORM — PATHFINDER CLUB [CLUB NAME]
I, [guardian's full name], holder of CPF No. [•••], residing at [address], as the father / mother / legal guardian of [Pathfinder's full name], born on [date], AUTHORIZE the [name] Pathfinder Club, affiliated with the Seventh-day Adventist Church — [name of church/Association], to capture and use the minor's image, voice, and name, under the terms below.
- Purpose. The images will be used exclusively to promote the Pathfinder Club's activities, document its history, and invite new families. Any commercial or third-party advertising use is prohibited, as is transfer to companies or other organizations.
- Authorized channels (check all that apply): ( ) the club's official social media profiles; ( ) the club's website and blog; ( ) the club's communication groups with families; ( ) church bulletin board and newsletter; ( ) printed club materials; ( ) submission to the official channels of the Association/Mission and the South American Division.
- Not authorized. No images will be published that expose the minor in an embarrassing situation, in swimwear, receiving medical care, or accompanied by home address, school, documents, health data, or real-time location.
- Term. This authorization is valid for the [year] club year and will be renewed with each new enrollment. Previously published historical materials may be kept in the club's archive, unless an explicit removal request is made.
- No compensation. This authorization is granted free of charge, without any financial compensation, present or future.
- Revocation. This authorization may be revoked at any time, free of charge and without needing justification, under the terms of art. 8, §5, and art. 18, IX, of Law 13.709/2018 (LGPD), by contacting [name of club contact], by phone at [•••] or by email at [•••]. Once the request is received, the club will take down, within [timeframe, suggestion: 15 days], any content still published under its control.
- Acknowledgment. I declare that I am aware that the club does not control republication by third parties and that content already shared by others may remain accessible.
[city], ____ of __________, ______.
______________________________________
Signature of parent or legal guardian — name and CPF
______________________________________
Acknowledged by the Pathfinder — from age 12 (from age 16, signature required, assisted)
______________________________________
Club Leadership — name, role, and date received
Two honest notes about this template. First: it is not legal advice; it's a starting point built on the text of the laws cited in the sources. Second: if your Field has already sent an official form — which usually happens mainly for camporee enrollment — use the Field's version and keep this one only as a reference for what shouldn't be missing.
Can a parent change their mind after signing?
Yes. And it's not a favor from the club: it's a written right. Art. 8, §5 of the LGPD states that consent "may be revoked at any time through the data subject's express statement, by a free and simplified process." Art. 18, item IX, repeats this right in the list of data subject rights, and item VI guarantees the deletion of data processed based on consent. Under the Civil Code, art. 20 allows the interested party to request that publication be banned, without prejudice to any compensation owed — keeping in mind that this article ties the ban to images that harm honor, good reputation, or respectability, or that are intended for commercial purposes; once authorization is withdrawn, though, the most direct path is art. 8, §5, of the LGPD itself.
In practice, here's the club's playbook when an "I don't want this anymore" arrives:
- Record it in writing. A WhatsApp message from the guardian already counts as an express statement. Save it, don't delete it.
- Take down whatever is under the club's control. Posts, highlights, group cover photo, website, any poster still in circulation.
- Set a deadline and meet it. The law calls for a simplified process; a short deadline written into the form avoids arguments.
- Decide about the historical archive. Revocation doesn't retroactively erase what was legitimately done while consent was valid (§5 itself carves out an exception for processing already carried out) — but if there's a deletion request, the club should honor it wherever it can.
- Notify the team. The most common mistake is a counselor who didn't know and reposted the same photo three months later. Keep a simple list of who hasn't authorized.
- Don't embarrass the child. No saying "only so-and-so can't appear" out loud in front of the unit.
And what if the guardian simply doesn't authorize it from the start? The club cannot make participation conditional on image authorization. The Pathfinder joins in, goes camping, gets invested, and takes part in everything the same way — they just won't appear in the posts. This logic follows the spirit of LGPD art. 14, §4, which prohibits making a child's participation in activities conditional on providing data beyond what's strictly necessary. A photo for Instagram isn't necessary for camping.
What the club shouldn't publish — even with a signed consent form
A signed form authorizes the use of the image. It doesn't authorize just any use. The final filter is the child's best interest (LGPD, art. 14, main clause) and the preservation of image and identity (ECA, art. 17). Before posting, run the photo through this filter:
| Situation | Post it? | Why |
|---|---|---|
| Group photo during an activity, with a signed form | Yes | Intended, authorized purpose |
| Full name + school + meeting time and address | No | A combination that lets someone locate the child in real life |
| Child alone, in a close-up, identifiable | Avoid | Prefer group and activity scenes |
| Water activities, river bathing, changing clothes | No | Exposure of the minor's body |
| Health form, allergy, medication, medical report | No | Sensitive personal data (LGPD, art. 5, II and art. 11) |
| Live stream with the camp's location | No | Reveals in real time where dozens of children are |
| Child crying, being disciplined, or embarrassed | No | Violates dignity (ECA, art. 18) |
| Photo used in a raffle, sale, or fundraising campaign | Only with specific authorization | Economic purpose: presumed harm (STJ Precedent 403) |
Add to that a detail few people remember: ECA, art. 143, prohibits any news report that identifies a child or adolescent accused of a delinquent act, expressly banning photographs, name, nickname, and family affiliation. If any club incident turns into a police matter, the rule is absolute public silence about the minor's identity.
There's also the layer of the Pathfinder's own phone, which deserves a rule agreed on with families — a topic that comes up strongly at big events and that we cover in phones at camporee. Whoever photographs the official activity should always be an adult designated by club leadership, with an account and password under the club's control.
Who keeps the form, for how long — and what does the SGC handle?
The signed form is a club secretary document. The Administrative Manual already requires each member to have an individual folder with their entire club history — forms, certificates, photos. The image consent form goes in there, alongside the enrollment form and health form. Also keep a simple log on a single sheet: the Pathfinder's name, the date signed, authorized channels, status (active/revoked).
On the subject of systems, here's the part that needs to be said plainly. The SGC — Club Management System is the official system of the Seventh-day Adventist Church. It's where Pathfinder enrollment, event registration, and the Annual Insurance happen — and no other tool replaces it. If a Pathfinder isn't in the SGC, they aren't insured, period.
Desbravai, which publishes this portal, is a complementary tool for day-to-day communication and organization — gallery, calendar, units, announcements. It doesn't replace the SGC for official registration or insurance, and shouldn't be presented to families as if it did. What a complementary tool can do is the tedious work: remembering who signed the form, flagging who revoked it, and preventing the wrong photo from being posted by mistake. The decision and the responsibility remain with the club's leadership.
How long should it be kept? The LGPD doesn't set a deadline for this case. The standard in art. 15 is the end of the purpose: as long as the club still uses those images, the form needs to exist to prove that authorization was given — and the burden of that proof falls on the club (art. 8, §2). In practice, keep the form at least as long as the published material remains up, and treat the folder like the rest of the archive: with the same discipline described in the official manuals.
One final recommendation from those who manage risk within the church itself: Adventist Risk Management, the Adventist Church's risk manager, advises in its materials that minors don't consent on their own, that photo and video authorization signed by parents is essential, that consent is an ongoing, revocable process, and that organizations should adopt a written social media policy — even providing a sample consent form. The material we consulted was published in 2020 for the North American Division, and we found no equivalent document from the South American ARM on image use; the principle, however, is the same one Brazilian law requires. Worth noting, on ARM in South America, a documented point independent of this: the Annual Insurance coverage is triggered by member enrollment in the SGC.