Patient image use authorization template for HOF

A photo of a face is personal data, and a clinical photo of a patient is health-related data, treated more strictly under the LGPD. That is why taking photos for the medical record, using images in a class and publishing a case are three different things, and each requires clear authorization from the patient, which can be withdrawn.
The template below separates clinical use (medical record) from optional purposes (teaching, scientific publication, promotion), lets the patient tick what they authorize and provides for revocation. It is generic: adjust it to your practice and have a lawyer review it. To understand the concept, read image use authorization.
When should you use this template?
Before taking the patient's first photo, together with the procedure's informed consent, but in a separate document or block. Ask for new authorization when the purpose changes (for example, moving from the medical record to promotion). For the technical standard of the photos, see standardized clinical photography.
How do you adapt it?
- Keep clinical use separate from the rest. No patient should have to accept promotion in order to be treated.
- List only the purposes you actually use. An overly generic purpose ("any use") weakens the authorization.
- Write down where the images will be stored, who has access and for how long.
- Define how the patient requests withdrawal of the authorization: channel, response time and what happens to the material.
- Handle minors and persons without legal capacity with care: the authorization comes from the legal guardian, and publication should be assessed even more strictly.
- Follow your professional board's advertising rules. The form does not replace them. See what you can publish (CFO and CONAR).
- AI-generated simulations (like Harmy's) are illustrative and must never be presented as an actual result.
What must never be missing?
| Item | Reason |
|---|---|
| Types of image (photo, video, simulation) | Defines what was authorized |
| Separate, tickable purposes | Free and specific choice |
| Whether the face appears in full or protected | Reduces the risk of identification |
| Where, for how long and who has access | Transparency and security |
| Right to revoke and a channel to do so | Provided for in the LGPD |
| That refusal does not affect care | Free authorization |
| Place, date and signatures | Validity |
Image use authorization template
Where is the legal basis?
Brazil's General Data Protection Law (Law 13,709/2018) covers consent, revocation and the data subject's rights. For the clinic's photo routine, see also consent and LGPD for photos and medical records and documentation in HOF.
Frequently asked questions
What is the difference between an image use authorization and procedure consent?
Procedure consent deals with the risks and the decision to have the treatment. An image use authorization deals with something else: whether and how the patient's photos and videos may be used. Mixing the two can undermine the patient's free choice, so it is best to keep separate documents or separate options.
Can the patient withdraw the image use authorization?
In general, yes. Brazil's LGPD (General Data Protection Law) provides that consent can be revoked through a simple procedure, and the form should say so and explain how to make the request. The effect on material already published should be assessed with a lawyer.
Can I use the patient's photo on Instagram if they sign the form?
The signature is necessary but not sufficient: publication must also respect the advertising rules of your professional board and the CONAR rules (Brazil's advertising self-regulation body). See what is usually allowed in what you can publish, and consult your professional board.