The photographs that would answer a claim against me have no dates or locations
Photos with no date, no location and no context are worth very little when a claim against me turns on them.
Updated: . By Jack Butler-Kettle, Construction Claims Consultant.
What's happening?
You may have thousands of progress photos, but many carry no date or location. Forwarding a photo through a messaging app can strip that data out, and a personal phone may not keep the original file. When a claim turns on a photo, you need to know who took it, when, where, what it shows and what else was recorded that day.
Without that, the photo is easy to challenge. Your main contractor can say it shows a different area or a different week. A date or place you only remember should not be presented as certain. Even a well-dated photo shows a condition without proving its cause, how long it lasted or what it cost. A backlog can be sorted later, but data and context that were never kept cannot be recreated.
The solution
Keep the original file and find where it came from. Record the date, location, subject, reason and who took it, and link it to the diary entry or event it shows. Check each detail against the diary, access logs and drawing revisions, and mark it verified, inferred or unknown. Write the context for handover and condition shots on the day.
A photo and evidence log gives you a searchable record of where each photo came from, not another photo folder. Counterclaim Prevention builds it into your handover routine, so a defects or damage claim can be answered with dated photos.
Example
Illustrative example. The scenario and figures are invented.
The facts
A flooring subcontractor's main contractor claims £9,500 from it for repairs to the fourth floor screed. The finance lead has to show the screed was finished and undamaged before the next trade took the floor. There are 2,400 photos in a shared chat, and none carries a date or location, because forwarding stripped them out.
What happens
- The photo and evidence log is started from the originals. The phone that took each photo is found, and the original file is copied off with its data intact.
- Each entry records the source, who took it, the date, the location, the subject and the diary entry or event it belongs to. Every detail is marked verified, inferred or unknown.
- For the fourth floor, 180 photos are verified against the diary and the access log, 40 are placed from what they show, and 60 stay unknown.
- Twelve verified photos, dated by their original files and matched to the diary, show the screed complete and clean on handover day.
- From that week, the log is filled in as photos are taken, one entry per photo.
The outcome
The claim drops from £9,500 to £2,000, for one corner the photos do not cover. Everywhere else, the photos show the screed complete and clean on the handover date. Who damaged that corner is argued from other records, and the log does not claim to settle it. The old photos could be sorted, but the context they never had could not be given back.