S1-S6 Visual Arts: likeness and image rights — five judgements, three outcomes, two 60-minute lessons and a one-page image-use declaration

• StageS1-S6
• SubjectVisual Arts
• Learning strandreflection on the application of AI
• Official documentsBlueprint for Digital Education Development in Primary and Secondary Schools · AI Literacy Learning Framework for Primary and Secondary Schools · Guide to Using AI in Teaching in Primary and Secondary Schools · Visual Arts Curriculum Guide (Primary 1 to Secondary 6) (2024) · EDBCM No. 156/2026
• Time to preparetwo lessons, 60 minutes each

A decision about a generated image of a person is usually made in under a minute: whose face is it, was anyone asked, is the source usable, where will it be shown, and is it labelled. Five judgements in a fixed order resolve into three outcomes — can do, ask first, cannot do — across two 60-minute lessons: identifying and appreciating, then making and declaring.

• AudienceTeachers Students
• ThemeResponsible AI use

• Equipmenttwo editable Word documents (the five judgements with the image-use declaration, and the two-lesson plan); the judgement cards and the declaration print one page each and can be copied separately; the plan is for subject-team planning and lesson observation
• Version1.0
• Last updated2026-11-06

A decision about an image of a person is usually made in under a minute: whose face is it, was anyone asked, is the source usable, where will it be shown, and is it labelled. Work the five judgements in their fixed order and they settle into three outcomes — can do, ask first, cannot do — which gives a pupil a line they can say out loud instead of a feeling.

What this solves

The scene repeats in most Visual Arts rooms: a pupil generates an image of a person within a few minutes and then asks whether it can go online. The teacher has to answer, on the spot, a question with no simple answer.

• Judging by feel. One pupil believes a fictional figure is automatically fine; another believes any photograph is automatically out. Two pupils in one class reach opposite conclusions and neither can give a reason.
• Assuming a label settles it. The pupil writes “AI-generated” on the image and treats the matter as closed. But labelling and consent are two different things: a label says where the picture came from, and consent is about the face inside it.
• Merging two questions into one. “Was anyone asked” and “may this be shown publicly” become the same question, so an agreed display inside the school and an unagreed post on a social platform get the same answer.
• No record. At the end of term, when portfolios are handed in, nobody can remember whether the figure in a particular image was invented or was a classmate’s photograph. The teacher is left relying on memory.
• A misleading name. Some say Hong Kong has an image rights law; others say that without one anything goes. Neither is accurate, and a lesson has no time for a law lecture.

This page fixes the five judgements, keeps their order, resolves them into three outcomes, and uses a one-page six-column declaration to keep the decision on record. Two lessons of 60 minutes: identifying and appreciating, then making and declaring.

Three statements to read first, and to print on every pupil sheet:

1. The name, the five judgements, the three outcomes and the declaration are this resource’s suggestion, not an Education Bureau requirement. What the Bureau asks of this material is three things: respect copyright, obtain permission before uploading anyone else’s image to the internet, and respect intellectual property. No document prescribes five judgements, three outcomes, or the columns of a declaration.
2. There is no statute in Hong Kong called “portrait rights”. The protection this page refers to comes from the Personal Data (Privacy) Ordinance (Cap. 486), the Copyright Ordinance, defamation and the common law. This page names them only: it quotes no sections, states no penalties, and gives no legal advice. An individual case follows school policy and professional advice.
3. This page deals only with the judgement made while working in the classroom. Publishing approval, informing parents and complaints procedures follow the school’s existing arrangements; nothing here replaces any of them.

Two sentences that must not go into the teaching material: that Hong Kong has a portrait rights statute — there is no such statute, so writing it would be false; and that labelling an image as AI-generated makes it acceptable — labelling and consent are two different things, and a labelled image may still need permission and may still be one you cannot make.

This page also names nobody: no artist, no case, no platform, no tool. Every example is marked fictional, and no real school or person appears.

Learning objectives

By the end of the two lessons, pupils can:

1. Work through the five judgements in their fixed order and say what each one asks.
2. Place any image of a person into one of the three outcomes — can do, ask first, cannot do — and give the reason.
3. Distinguish consent from labelling: one is about the person’s face, the other about where the picture came from.
4. Complete a one-page six-column image-use declaration, stating who is in the image, consent, source, audience and how AI was used.
5. Make the judgement while they are working, rather than repairing it just before publishing.

The page addresses one of the three learning strands of AI literacy: reflection on the application of AI. It sits between critical thinking and respect for intellectual property: critical thinking means not mistaking “this sounds acceptable” for “permission was obtained”, and respect for intellectual property means not treating another person’s face or work as free material. Of the four attitudes, the two that matter most here are integrity and empathy: integrity is filling in the declaration honestly when nobody is checking, and empathy is asking once what it would be like if the face were your own.

Teaching steps

The attachments are two Word documents: the five judgements with the image-use declaration (the judgement cards, the three outcomes and the six-column declaration) and the two-lesson plan (with its three columns for learning area, learning elements and notes on AI).

Step 1: Five judgements, in a fixed order

The five judgements are in a fixed order and must not be rearranged. The order is itself the teaching point: who the face belongs to comes first, and whether the image is labelled comes last — because labelling is the easiest step and the one most often mistaken for the finish.

Four points for pupils to hold on to:

• “Not sure” is an answer to judgement 1, and choosing it is not a failure. It means stop and ask. Choosing wrongly is the failure.
• “Obtained” has to be withdrawable. Consent is not a one-off licence; a pupil should be able to say “they can tell me to stop showing it at any time” before consent counts as obtained.
• Judgement 3 asks about the source, not the quality. A low-resolution image from the internet is still an image from the internet.
• Judgement 5 is the last and the lightest of the five. It cannot stand in for the other four; a labelled image still has to answer judgements 2 to 4.

Step 2: Three outcomes, fixed at three

Once the five judgements are answered, they resolve into three outcomes, and no more. An outcome is not a mark; it is an action.

Four points to be explicit about:

• “Cannot do” is a creative instruction, not a punishment. The work can still be finished with an invented figure; what is ruled out is that method, not the idea.
• A public figure’s face is “cannot do” even for a classroom display. Consent does not enter into it: a public figure’s face is not available merely because nobody objected.
• “Removing or adding anyone’s body” is the one rule with no exceptions. It goes on the card, on the declaration and in the brief for the work.
• The three outcomes and the audience are separate questions. A “can do” piece still has to answer judgement 4 before it goes on a social platform, and an “ask first” piece still needs asking even for a display inside the school.

Step 3: Lesson 1 — identifying and appreciating (60 minutes)

Step 4: Lesson 2 — making and declaring (60 minutes)

Step 5: The one-page image-use declaration, fixed at six columns

The declaration is one page and six columns, no more and no fewer. It is not an administrative form; it is the pupil’s account of their own work.

Three notes on using it:

• Columns 3 and 5 have to agree. If column 5 says “outside the school”, column 3 cannot say “not applicable” or “still to obtain”. This is where a declaration most often contradicts itself, and it is the check worth giving the pupils to run on their own work.
• The class in column 1 is not there to identify anyone. It lets the teacher match a work to a class before a display; the declaration has no student number and no parent signature line.
• The pupil signs it. A parent handles consent for a minor, but the declaration is filled in and signed by the pupil, because the judgement being practised is the pupil’s own.

Answer key and marking notes

Worked examples: five fictional cards

All five are fictional, for classroom demonstration only, and correspond to no real person, school or event.

Marking points

• Order. Were the five judgements answered 1 to 5? Starting from judgement 5 (writing “AI-generated” first) counts as unfinished.
• Specificity. Judgement 3 needs a named source, not just “online”; judgement 4 needs an audience, not just “sharing”.
• Consistency. Do the outcome and the five answers match? “Cannot do” with a reason that mentions only the missing label is unfinished — the label is not what made it impossible.
• The declaration. Are all six columns filled in, and do columns 3 and 5 agree?
• Language. In the appreciation stage, can the pupil use the words consent, identifiable and source to explain the decision, rather than only “you can’t”?

One common wrong answer, and how to answer it: a pupil says “I’ve written AI-generated on it, so I can post it”. The reply is about order: labelling is judgement 5 and audience is judgement 4, so answering the fifth leaves the fourth — and the second — still to answer.

Files

Likeness and image rights: five judgements and image-use declaration (editable Word document)

Four sections, each usable on its own: the five header facts (stage, subject, learning strand, official documents, time to prepare), the five judgements and the three outcomes on one page to copy separately, the five worked cards, and a one-page six-column image-use declaration for each pupil. The declaration carries no student number and no parent signature line.

Likeness and image rights: two-lesson plan (editable Word document)

Two 60-minute lessons, each with times, stages and what the teacher does, plus three columns for subject-team planning and lesson observation: learning area — Arts Education, learning elements — creating, appreciating, visual elements, organisational principles, and notes on using AI. The plan names no artist, case, platform or tool.

Official documents

Every resource in this library is written to the AI Literacy Learning Framework for Primary and Secondary Schools and falls within the policy scope of the Blueprint for Digital Education Development in Primary and Secondary Schools.

This resource maps to:

• Blueprint for Digital Education Development in Primary and Secondary Schools (three-fold leaflet, p.2): requires digital and AI education to be planned in the School Development Plan, with the arrangements explained to teachers, pupils and parents; turning “may this image be shown” into five judgements a class can say out loud is part of explaining those arrangements.
• Supplement I: AI Literacy Learning Framework for Primary and Secondary Schools (p.1-4): sets out the three learning strands; this resource addresses reflection on the application of AI.
• Supplement II: Guide to Using AI in Teaching in Primary and Secondary Schools (p.2-4): putting people first with technology as an aid, and requiring teachers to exercise professional judgement; this page puts the judgement inside the making, rather than leaving it to be repaired by the teacher before publication.
• Visual Arts Curriculum Guide (Primary 1 to Secondary 6) (2024): the subject’s learning content includes creating and appreciating; the two lessons lead with making and support it with appreciation, and the learning elements are drawn from creating, appreciating, visual elements and organisational principles.
• EDBCM No. 156/2026 (Supplement I, section 3): maintaining professional judgement; the five judgements and three outcomes are one way of exercising that in a classroom, but the judgements, the outcomes and the declaration are this resource’s suggestion, not an Education Bureau requirement.
• EDBCM No. 156/2026 (Supplement II, Teacher Information Pack, “4. Key messages, 4. For students”): critical thinking and deepfakes — respect copyright, obtain permission before uploading anyone else’s image to the internet, and respect intellectual property.

Learning strand: reflection on the application of AI

Official documents page: https://www.edb.gov.hk/en/edu-system/primary-secondary/applicable-to-primary-secondary/it-in-edu/debp.html

This page is an independent Beets teaching resource, not an official EDB document. The name, the five judgements, the three outcomes and the declaration are this resource’s suggestion for schools to adopt, and a school may adjust them; they must not be presented as an Education Bureau requirement. The Bureau’s requirements are to respect copyright, to obtain permission before uploading anyone else’s image to the internet, and to respect intellectual property. There is no statute in Hong Kong called “portrait rights”; the protection referred to here comes from the Personal Data (Privacy) Ordinance (Cap. 486), the Copyright Ordinance, defamation and the common law, and this page names them without quoting sections and without giving legal advice. This page does not replace the school’s publishing approval process, and the school’s existing arrangements decide.

Feedback

If you have any comments or questions about this resource, or an idea for the next one, tell us on the feedback page.