Photography & Videography Guidelines (“Guidelines”)
1. Introduction
These Guidelines set out the procedures, approval processes, and responsibilities for conducting photography and videography activities within the Premises (as defined below), to ensure compliance with the Company’s policies and all relevant laws (“Guidelines”).
2. Definitions
| Term | Definition | |
| “Activity(ies)” | means (a) any photography and/or videography activity within the Premises; and/or (b) the processing e.g. editing, reviewing, formatting, compiling and transmitting of Media Content, by the Media Creators. |
|
| “Company(ies)” | means the owner of the Premises and PPBHB. | |
| “Media Content(s)” | means all media content (such as photographs, images and videos) featuring any of the following: (a) the Company’s personnel; (b) activities conducted at the Premises; (c) the Premises; (d) visitors at the Premises; and (e) Company’s intellectual property and brand assets, regardless of the device used. |
|
| “Media Creator(s)” | means third parties (photographers, videographers, influencers, content creators, contractors, suppliers, vendors, and their agents, assignees, representatives, and employees) who are appointed by PPBHB and/or the Company(ies) to carry out the Activity (defined herein) and/or to process the Media Contents (defined herein). | |
| “Premises” | means the land, building and/ or facilities including operational, commercial, administrative areas such as offices, meeting rooms, facilities, and event sites owned and/or managed by PPB Hartabina Sdn Bhd and its subsidiaries, affiliates, and related companies. | |
| “PPBHB” | PPB Hartabina Sdn Bhd [197201000946 (12505-M)] |
3. Who do these Guidelines apply to?
These Guidelines apply exclusively to Media Creators. For the avoidance of doubt, these Guidelines do not apply to public or casual visitors of the Premises.
4. Who enforces these Guidelines:
The Marketing Communication and Sustainability Department of PPBHB (MARCOM & SUS) oversees compliance with these Guidelines and serves as a primary contact for approvals and clarifications.
For any inquiries or requests, please contact MARCOM & SUS at [email protected].
5. Purpose
These Guidelines aim to:
(a) safeguard the privacy, confidentiality, and security of individuals and sensitive information;
(b) ensure that media content captured during events, campaigns, and Corporate Social Responsibility (CSR) initiatives at the Premises is respectful, ethical, and protects the dignity of all individuals, especially those from vulnerable groups; and
(c) promote compliance with the relevant laws, regulations and the Company’s policies.
6. Guidelines Framework
6.1 Approval
(a) Prior written approval must be obtained before commencement of any Activity by the Media Creators.
(b) Request for approval must be submitted to MARCOM & SUS at [email protected] prior to the Activity.
6.2 Circumstances where Approval may be granted
Approval may be granted for Media Contents recorded for the following purposes:
(a) Internal or external training
(b) Inspections and reviews
(c) Corporate events, official campaigns, and CSR initiatives
(d) Promotional or awareness campaigns
(e) Such other purposes as the Company deems fit.
6.3 Conditions for Approval
(a) Generally, any approval given for the carrying out any of the Activity by a Media Creator is subject to the following conditions:
(i) that such Activity is carried out solely for its approved intended purposes;
(ii) such Activity adheres to ethical and professional standards appropriate to the Media Creator’s profession, ensuring respect of privacy, safety, and the Company’s values; and
(iii) such Activity adheres to relevant laws, regulations, and policies of the Companies such as the Personal Data Protection Act 2010 (“PDPA”).
(b) In particular, the Activity must adhere to the following requirements:
(i) Protection of Vulnerable Groups
When photographing or filming minors or vulnerable individuals (e.g. elderly, differently abled):
(aa) Blur or cover faces if no explicit consent is provided.
(bb) Avoid exploitative or patronizing portrayals.
(cc) Promote respectful and empowering representation.
(ii) Consent & Ethical Practices
Do’s:
(aa) Obtain and record verbal or written consent from all individuals featured in Media Contents before filming or photographing – refer to Paragraph 8 below.
(bb) Be transparent about the purpose of the media capture.
(cc) Represent individuals respectfully and accurately.
(dd) Ensure high production quality (lighting, angles, composition).
Don’ts:
(aa) Do not coerce or force anyone to participate in a photo or video shoot; participation must be voluntary.
(bb) Do not misrepresent, stereotype, or demean.
(cc) Do not share content without approval.
(dd) Do not include personal data unless express consent have been obtained.
(iii) Use of Company Branding
(aa) Please refer to PPBHB’s Guidelines for Use of Company’s Intellectual Property.
(bb) Ensure it is displayed professionally and does not overshadow subjects in the image.
(iv) Photography Standards
Ensure all photos and videos:
(aa) Are clear, well-composed, and contextually relevant.
(bb) Avoid cluttered or inappropriate backgrounds and do not include unrelated or sensitive information.
(cc) Maintain balanced, inclusive framing for group shots.
(dd) Do not inadvertently infringe on others’ privacy (e.g. background conversations, screens, documents).
(v) Use of Drones
(aa) Drone usage is strictly regulated and must not be used unless with the Company’s prior written approval.
(bb) All operators must hold valid permits and licenses as mandated by the Civil Aviation Authority of Malaysia (CAAM), in accordance with applicable local aviation regulations.
(c) Media Content can only be used for and/or published subject to the following:
(i) Confidentiality and Ownership
(aa) Ownership of all Media Content is the property of the Company unless otherwise agreed in writing.
(bb) Media Creators must not use or share Media Content without prior written approval.
(cc) Media Creators may photograph or film on the Premises solely for the intended Activity. Any unauthorized photography or filming, including personal or unrelated use by Media Creator is prohibited.
(ii) Contents of Media Content must be approved
Media Creators must not publish, share, or distribute Media Content (including on personal or company social media) without prior written approval.
(iii) Publication of Media Contents by Media Creators
To protect the Company’s brand image, uphold data privacy, and ensure accurate representation:
(aa) Media Content may only be used for authorized purposes and shared with approved audiences.
(bb) All content must accurately represent the Company’s activities or events and must not be misleading, distorted, or taken out of context.
(cc) Public-facing content must reflect professionalism and align with Company values and branding guidelines.
(dd) Consent must be obtained before tagging, mentioning, referencing, or naming individuals in any public facing Media Content.
(ee) The Company reserves the right to review, approve, and require removal of the Media Content or any part thereof that conflicts with its branding
guidelines or public image.
(iv) Compliance with laws
Notwithstanding any approval granted by the Company, Media Creators must ensure that the use and publication of Media Content complies with all applicable laws, regulations, and statutory requirements.
7. Indemnity
Media Creators shall indemnify and hold harmless the Company from and against any and all claims, liabilities, losses, damages, costs, and expenses (including legal fees) arising out of or in connection with any Media Content captured, created, processed, or published by the Media Creator in breach of these Guidelines and/or any applicable laws, regulations and statutory requirements.
8. PDPA
Media Creators must:
(a) Obtain and record explicit consent from individuals featured in Media Contents prior to capturing, processing, or publishing any Media Content containing personal data.
(b) Provide the Company with copies of all consent whether in written form or media recording collected pursuant to paragraph (a) above.
(c) Not publish, share, transfer, or disclose such content to third parties without the Company’s prior written approval and the necessary consents from the individuals concerned.
(d) Implement security measures at least equivalent to those required under the PDPA to protect personal data from loss, misuse, unauthorized access, disclosure, alteration, or destruction.
(e) Ensure that personal data is only transferred or disclosed to third parties if permitted under the PDPA and subject to those third parties undertaking to maintain confidentiality.
(f) Upon request, promptly make available for audit by the Company all relevant books, records, and documentation relating to personal data processing activities.
(g) Immediately notify the Company in the event of an actual, suspected, or potential data breach and provide all reasonable assistance to meet notification obligations under the PDPA.
9. Breaches & Enforcement
(a) Breaches of these Guidelines may result in the Company taking the following actions:
(i) Revoke access or entry into the Premises by the Media Creators; and/or
(ii) Initiate legal action against the Media Creators including termination and/or cancellation of any contracts entered between the Companies and the Media Creators at the Companies’ sole and absolute discretion, without prejudice to any other rights and remedies available to the Companies including to claim for any losses and/or damages arising from the Media Creators actions and/or inactions.
(b) In the event of breach of any requirements under these Guidelines, the Media Creators shall take the following actions as and when directed by the Company:
(i) To immediately cease any planned and/or ongoing Activity and delete and/or destroy any unauthorized Media Contents; and/or
(ii) Publish formal retractions or public clarifications.
10. Review of these Guidelines
These Guidelines will be reviewed periodically and may be updated by PPBHB from time to time.
Notwithstanding the provisions contained in these Guidelines, the Company reserves the right to impose additional obligations, requirements, restrictions and/or limitations as it deems necessary.
3 March 2026