Play it safe and
ask for a photo consent.
How it works.
Today, for many kind of photos or even casual snapshots it is essential to get approval and thus the signature of model to publish this photo.
This is what FaceAgree is for.
With online service FaceAgree it is easy to obtain and manage declarations of consent for photo publications.
Photographer can easily upload the pictures and the model (or group of people) can simply release publication and directly sign on the smartphone or any other device.
With FaceAgree it's so easy to get the required model release contract and agreement to your privacy statement according to GDPR.