Hungary’s Authority for Data Protection and Freedom of Information issued new guidance on the lawful use of employee photos. An employee photo can only be taken or processed lawfully if there is a specific underlying purpose, for example, as needed for a workplace ID card. For group or event photos, it may not be necessary to obtain consent for the publication of photos on a website if the photos are taken of employees who attend an open, work-related event and the “image is not unique”. Employers should investigate whether a photo qualifies as a “crowd shot”. If not, then consent from the relevant person must be obtained before publishing.