Yes. The right to be forgotten as organized by the ECJ is, in effect, the right to the withdrawal or personal information. An image is considered to be personal data.
The directive 95/46/CE of the European Parliament and Counsel on October 24, 1995 defines personal data as such: “All information concerning a person physically identified or identifiable; a person is deemed as identifiable if they can be identified, directly or indirectly, especially by reference to an identification number or one of any other specific elements, such as their own physical, psychological, mental, economic, cultural, or social identity.”
This definition easily includes images that contain personal information and such a reading is regularly confirmed by the national tribunals.
The right to be forgotten is aimed directly at personal data, which is why you can request the removal of images representing you in search engines. However, as with all of the other data, the use of any withdrawn images should be obsolete, inappropriate or irrelevant.
Last update: 2014-11-13