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AI Headshots for Staff: Consent, PDPA and Brand Consistency

AI headshot tools turn a handful of selfies into polished, matching portraits for a fraction of a studio shoot, which makes them popular for team pages, LinkedIn and proposals. But staff faces are personal data under Singapore's PDPA, the selfies go to an overseas vendor, and the results are images of real employees presented to customers. This guide covers how to get consent properly, what to check in a vendor's retention terms, what to do when someone leaves, how to keep the photos honest, and a simple workflow for a consistent look across the team.

By IT Sorted teamReviewed 7 min readHow we write guides
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Key takeaways

  • Staff photos used on your website or marketing are personal data under the PDPA.
  • PDPC's guidance says an organisation publishing a photo for business purposes needs the person's consent.
  • Check where the vendor stores selfies and when it deletes them; HeadshotPro lists 30 days after generation.
  • Staff can withdraw consent; plan how to remove their photo from the site and old materials.
  • Never add AI-made people who don't work for you; a fake team misleads customers.
In this guide · 8 sections
  1. 01Why staff photos are personal data under the PDPA
  2. 02Getting staff consent the right way
  3. 03Choosing an AI headshot vendor: retention and training terms
  4. 04When staff leave or withdraw consent
  5. 05Honest representation: real people, realistic photos
  6. 06A workflow for consistent, brand-friendly team photos
  7. 07Do it yourself or get help?
  8. 08Frequently asked questions

Short answer

You can use AI headshots for staff, but treat them as personal data: get each person's written consent, choose a vendor that deletes uploaded selfies and does not train on them, remove photos promptly when staff leave or withdraw consent, and only show real team members who look like their portrait.

Why staff photos are personal data under the PDPA

The Personal Data Protection Act defines personal data as data about an individual who can be identified from it. A recognisable photo, real or AI-generated from their selfies, clearly qualifies.

PDPC's Advisory Guidelines on Selected Topics has a chapter on photography. Its example is close to this case: when a photo is published for an organisation's publicity purposes, such as its brochures or website, the PDPA's data protection provisions apply to the organisation, and it will have to obtain the person's consent before publishing it.

AI headshots add two more steps: you send several selfies to a third-party vendor, often overseas, and that vendor may keep them or a trained model of the person's face. Both are uses of personal data that staff should know about. This guide is general information, not legal advice.

Choosing an AI headshot vendor: retention and training terms

Vendors differ a lot in how long they keep selfies and whether they use them for anything else. Read the privacy and security pages, not just the marketing.

Question to checkWhy it mattersExample (vendor docs, Oct 2026)
When are uploaded selfies deleted?Less data held means less riskHeadshotPro: input photos deleted 30 days after gallery generation
Are photos used to train AI models?Faces should not end up in a general modelHeadshotPro says it does not use customer content to train models
Where is data stored?Overseas transfer under the PDPAHeadshotPro: data in the EEA, application servers in the US
Can you delete an account on request?Needed when staff leaveAragon: delete account and data from settings at any time
Is there a team account?Keeps control with the business, not personal loginsMost vendors offer team plans
Sources: HeadshotPro security overview and Aragon privacy page, October 2026.

Sources: HeadshotPro security overview, HeadshotPro pricing (one-off packages listed at US$29, US$39 and US$59 per person, approximate, October 2026) and Aragon's privacy page. If a vendor does not state retention and training terms clearly, choose another.

General design tools such as Canva and Adobe Express also have AI photo features; see our Canva vs Adobe Express comparison for their business terms.

Honest representation: real people, realistic photos

AI headshots are meant to make real staff look professional, not to invent a bigger company.

Acceptable

  • A real employee, consistent background and lighting across the team
  • Light retouching that still looks like the person on a video call
  • Business attire generated for someone who usually dresses casually
  • A note on the team page that portraits are AI-assisted, if you want to be transparent

Avoid

  • AI-generated people who do not work for you
  • Headshots of former staff left up to make the team look bigger
  • Changing age, ethnicity or features so the person is unrecognisable
  • Fake reviewers or "customers" with AI faces

A workflow for consistent, brand-friendly team photos

Consistency is the main reason businesses choose AI headshots. A simple brief gets you there.

  • Pick one style for everyone: background colour, framing (head and shoulders), clothing tone. Save it as a written brief.
  • Use a team account so the business, not individuals, controls galleries and deletion.
  • Let each person choose their own final photo from their gallery.
  • Export at one size and crop for the website, and compress the files so the team page loads quickly.
  • Add alt text with the person's name and role for accessibility and search.
  • Review yearly: update photos that no longer look like the person.

Copyright in fully AI-generated images is uncertain in Singapore because the law requires a human author; see our guide to using AI-generated images commercially for the details. Mention the photos and their purpose in your website's privacy notice too; our website privacy policy and cookie consent guide covers what to include.

Do it yourself or get help?

Running AI headshots for a small team is easy to do yourself: agree the brief, collect consent forms, use a team account, and add photo removal to your offboarding checklist.

We can build or refresh the team page itself: consistent layout, fast-loading images, alt text, and a simple way to add or remove people without breaking the design. Our Business Website package (S$1,490) includes this as part of a new site. We do not take or generate the photos.

Frequently asked questions

Yes, you should get it. A recognisable photo is personal data under the PDPA, and PDPC's guidance says an organisation publishing a person's photo for its own business purposes, such as its website, needs that person's consent. Get it in writing, explain the AI vendor involved, and make it genuinely optional.

Some are better than others. Check how long the vendor keeps uploaded selfies, whether it trains AI models on them, where data is stored and whether you can delete accounts on request. For example, HeadshotPro states input photos are deleted 30 days after generation and not used for training. Use a business team account.

Remove it from your website, templates and directories on their last day unless they agreed otherwise, delete their gallery with the AI vendor, and confirm the removal to them. Under the PDPA, people can also withdraw consent at any time, so have the same process ready for current staff.

No. Showing people who do not exist, or former staff, as your team misleads customers about your business. Use AI headshots only for real current employees who agreed to it, and keep the portraits recognisable as the actual person.

The vendor's terms decide what rights it claims, and most assign or allow commercial use of outputs. Under Singapore law, copyright requires a human author, so a purely AI-generated image may have little or no copyright protection. The person shown still has rights over their personal data under the PDPA.

Rather have it done for you?

Fixed price, set up in your own accounts.

Order online, get a written scope, and keep full ownership of everything we set up. Questions first? Ask us in writing.