I have been minding 14 years and have never heard of this one!
It is good practice for you to be able to suggest places for children go to to get emergency or back-up cover, but not obligatory... also you cannot say for certain if other minders will have spaces on the days / times they are needed or whether parents will be happy with this arrangement...
Very odd... I would ask your development officer how she will ensure privacy etc for the photos and which piece of legislation she is working from...
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