NHMRC has introduced new guidance on the use of identifiable images of people in grant applications. The guidance will be introduced in the Grant Opportunity Guidelines for MREA schemes, supported by a new declaration in Sapphire.
NHMRC has introduced new guidance on the use of identifiable images of people in grant applications. The guidance will be introduced in the Grant Opportunity Guidelines for MREA schemes, supported by a new declaration in Sapphire.
The guidance is located in the Guide to Applicants and states:
Applicants must abide by the following requirements when including images of people in grant proposals. Identifiable images of a person must only be included where the image is essential to the grant proposal and provides important context that cannot reasonably be conveyed through text alone. Examples may include images necessary to explain a research method, intervention setting or diagnostic feature. Identifiable images of a person included for illustrative, promotional or decorative purposes are not appropriate and should not be included in grant proposals.
Images of individuals are treated as personal information under the Privacy Act 1988 where the person’s identity is clear or can reasonably be worked out from that image. Images of individuals may also contain sensitive information if, for example, the individual’s racial or ethnic origin or religious beliefs is apparent. An identifiable image of a person is any photograph, scan or other visual recording in which an individual can be recognised, or could reasonably be recognised, either directly or indirectly by the individual themselves or by others. An image remains identifiable even if the face is blurred, cropped, masked or partially obscured, and the individual could reasonably be recognised by themselves or others.
Where an identifiable image of a person is included in a grant proposal, applicants must:
- Include a figure title or caption for the image
- Reference the image in the body of the grant proposal text
- Include one of the following 3 statements for each image in the figure caption, as appropriate:
- Valid, written consent has been obtained for the use of this image.
- Reuse rights have been secured for the use of this stock or published image.
- This is an AI-generated image.
- Comply with copyright and licensing requirements when using stock or published images.
Consent requirements
Unless using a stock or published image, applicants must obtain free, prior and valid written consent before application submission for all identifiable images of a person, consistent with applicable ethical requirements, including the National Statement on Ethical Conduct in Human Research (the National Statement).
Particular care is required when images include children or persons at increased risk of harm, in line with the National Statement’s requirements for consent involving limited or developing capacity. Where an image relates to a child, applicants should carefully consider that the child will usually not have the opportunity to withdraw consent when they get older.
Consent documentation must not be uploaded as part of the application unless explicitly requested by NHMRC. However, copies of consent documentation should be retained so that they can be provided to NHMRC if requested.
Legal and policy obligations
NHMRC is required to comply with the Privacy Act 1988, the Commonwealth Child Safe Framework, and NHMRC’s Privacy Policy and NHMRC’s Child Safe Policy. The Privacy Act 1988 protects the personal information of both adults and children alike. The inclusion of an identifiable image of a person without appropriate consent and/or appropriate reuse rights in applications to NHMRC may give rise to obligations under the Privacy Act 1988, including the Notifiable Data Breaches Scheme in certain circumstances.
Applicants and Administering Institutions are responsible for ensuring that personal information is not inadvertently or intentionally disclosed without written valid consent.
Consequences of non-compliance
NHMRC may deem an application ineligible where an application contains an identifiable image of a person without appropriate consent and/or appropriate reuse rights.
From Monday 1 June 2026 applicants must also complete a declaration in Sapphire confirming that valid consent or appropriate usage rights have been obtained for identifiable images of people, where applicable. These questions will be located on the first page of the application form, typically titled ‘Application Details’, and ask the following:
Does your application include any identifiable images of people?
Select ‘Yes’ or ‘No’
If you answer ‘Yes’ to this question you will be required to answer the following question:
You must have obtained written valid consent to use any identifiable images of a person, particularly children, or have appropriate usage rights for use of stock or published images. Usage rights must be detailed in the figure caption for each image.
Have you provided details of the usage rights or consent status in the figure caption(s)?
Select ‘Yes’ or ‘No’
If ‘No’ is selected a warning message will be displayed.
Research Administration Officers are encouraged to familiarise themselves with the guidance on use of identifiable images in Grant Opportunity Guidelines released from Monday 1 June 2026 onwards and to support applicants to consider image use and consent requirements early in application development.
Please direct all enquiries to research.policy@nhmrc.gov.au.