Generally, unless the purpose of the image was to disseminate an otherwise copyrighted work contained in the recording, fair use would apply. For example: the famous toddler dancing to Prince video. It recorded a Prince song while the toddler was dancing to it. The primary purpose of the video was to show the toddler dancing, so the recording (and dissemination of the Prince song) was deemed fair use. (There's a bit more to that analysis but that was the gist of it.)