Quote:
Originally posted by scoreman
c) The ids are kept in a two folders. In folder one all of the ids have only the models face and birthdate. The rest is blacked out. These ids will be freely viewable and will provide the webmasters reassurances that the ids are in fact in existence. In folder two is all of the ids unedited, only these ids sit inside of a password protected/encrypted folder.
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I am extremely dubious about this approach:
1. "all such records shall be organized alphabetically, or numerically where appropriate, by the legal name of the performer (by last or family name, then first or given name), and shall be indexed or cross-referenced to each alias" ...how will this index and cross-referencing be possible if you only show the model face and birthdate?
2. "Each record shall be maintained for seven years from the date of creation or last amendment or addition. If the producer ceases to carry on the business, the records shall be maintained for five years thereafter." ...so the sponsor (in this context) goes out of business and can no longer be contacted with the ease you have described.
There is a possible 5-year prison sentence and a hefty fine hanging on these rules. With due respect even to a sponsor such as yourselves, you are asking for an enormous amount of trust on the part of the affiliate. NOT in terms of you possibly having photographed minors, but as you point out, this is a record keeping issue.
And if I would be concerned - if there were a knock on the door - that someone like you might be unavailable (for the password) or that errors might then be found, I can't think of more than a half a dozen other sponsors I would trust even that far.