
Maintenance
Part of Synthetic image consent guide for creators
Synthetic media consent checklist: source, person, purpose, disclosure and removal
A synthetic media consent checklist covering source rights, the people depicted, authority, purpose, model records, disclosure, reuse and removal.
This synthetic media consent checklist covers the five things every production must settle before a generated or altered depiction of a real person goes out: source, person, purpose, disclosure and removal. Work through it before you generate, approve or publish, and keep the record it produces.
What to take away
- Copyright permission and likeness permission are two separate files. Clearing one does not clear the other.
- The production record should name the model, version, account owner, region and the date you read the terms.
- Disclosure belongs where the audience meets the media, not in a footer or a credits page.
- Provenance metadata proves where a file came from. It does not prove the person agreed to this use.
- Someone must hold the pause button, and that name goes in the plan before publication, not after a complaint.
- Separate a test from a release. A closed prototype approval does not clear a public campaign.
- The workflow suits a real project using an adult's likeness. It is not a route for turning scraped material into permission.
Use this before generating, approving or publishing a synthetic depiction of an identifiable person. It is a production review. It does not decide whether a given use is lawful where you are.
Source and person
- List every photo, video, audio file, script and reference going in.
- For each one, record creator, owner, license, release and which adaptations are permitted.
- Identify every person recognizable by face, voice, body, mannerisms, name or context.
- Note age at capture and current legal capacity.
- Keep the copyright file and the likeness, privacy and data file separate.
- Reject scraped or leaked material with no documented basis.
- Note whether each file carries metadata or hidden identifiers, and whether it may enter a hosted model.
- Note any deletion or return requirement attached to the source files.
- Do not upload identity documents, unreleased masters or third-party images just because the tool accepts them.
A performer's release usually covers a defined production, not a synthetic likeness of that performer in a different scene. When the two disagree, the narrower document governs the conversation, and a licensed attorney in your jurisdiction reads it.
Source and person checks
- List each photo, video, audio, script
- Verify creator, owner, license, release
- Identify every recognizable person
- Confirm age and legal capacity
- Separate copyright from likeness and privacy
- Reject scraped or leaked material
Authority and purpose
- Name who is granting each permission and how you verified they can.
- Describe the exact synthetic change in the words a viewer would use.
- Write down the product, message, scene, script, audience, channel, dates and territory.
- Describe the setting, the level of realism, the languages and the channels before any test render.
- Stop before making even a test if that description is broader than the person expects.
- Mark whether this is paid promotion, political communication, fundraising or sales.
- Flag intimate, medical, financial, biometric, criminal, employment, religious, grief, endorsement and child-related contexts.
- Record prohibited uses and prohibited variants.
Those contexts need review by a licensed attorney. A production checklist does not replace legal advice.
Regulatory statements on AI-generated imagery ask for transparency, accessible removal routes and stronger protection for children. Exact duties vary by jurisdiction, so confirm them with a licensed attorney where you operate.
In the US there is no single federal synthetic-media consent statute. Commercial use of a name, voice or likeness is governed mainly by state right-of-publicity law: California Civil Code §3344, New York Civil Rights Law §§50–51 and the Tennessee ELVIS Act, which reaches AI-cloned voices. The federal Take It Down Act covers non-consensual intimate imagery, including AI-generated material, and the FCC has declared AI-generated voices in robocalls illegal under the Telephone Consumer Protection Act.
Model and prompt
- Record service, plan, model, version, region and account owner.
- Save the terms and privacy notice you actually read, with the date.
- Ask for the vendor's data processing addendum before you upload a recognizable face or voice, and keep the signed version with the production record.
- Check input and output retention, training use, human review, vendor access and deletion.
- Restrict who can open prompt and source files.
- Review negative prompts, reference strength and personalization settings.
- Test outputs for accidental resemblance to people who never consented.
- Refuse instructions that invent sensitive facts or put words in a real person's mouth.
- Record the account controls and the deletion limit on the plan you hold.
- Note any broad license grant over inputs or outputs.
Output approval
- Show the person the final media, the caption, the landing page and the claims beside it.
- Record hashes of approved files and keep rejected versions.
- Confirm edits, crops, languages, aspect ratios and audio substitutions.
- Require fresh approval for new conduct, new words, a new product or a sensitive context.
- Set an approval expiration date.
- Tie that date to the release term, so an approval cannot outlive the contract it rests on.
The current C2PA technical specification describes cryptographically bound manifests, assertions, claims, signatures and provenance for media assets. It also states that the system validates association and tamper evidence rather than judging whether the asserted information is good, bad or true. Other provenance tools are narrower than they look: the IPTC Photo Metadata Standard's digital source type field can label an image as trained algorithmic media, and watermarking such as Google DeepMind's SynthID survives some edits but proves nothing about consent. Keep a human reviewer beside the credential.
Disclosure and audience
- Write a direct label naming the generated or altered element.
- Place it before or with first exposure.
- Test small screens, muted playback, audio-only use, crops, reposts and translations.
- Avoid vague labels such as "enhanced" when a person says or does something synthetic.
- Explain paid or sponsored relationships in their own line.
- Keep the label attached to downloadable files where the format allows.
- Record the exact label wording and its placement for each channel.
- Add machine-readable marking where the EU AI Act, a platform or a licensing deal requires it, in addition to the visible label.
Show the rendered placement to someone who did not work on the file. Ask what they think is authentic, what was changed, who approved it, and whether any commercial relationship is clear.
The EU AI Act sets transparency duties for certain generated or manipulated content, including disclosure for deep fakes, with tailored treatment for evidently artistic, satirical and fictional works. Application dates, the role your organization plays, exceptions and national enforcement all need current EU advice.
Provenance, reuse and security
- Keep source IDs, releases, approved prompts, model details, operator, edit log, disclosure and distribution list.
- Minimize location, identity-document and biometric exposure.
- State whether affiliates, licensees or viewers may remix or download.
- Block training or model reuse unless it was separately approved and supported.
- Limit access to reusable voice, face and body assets.
- Rotate keys and revoke vendor access when the project ends.
Removal and correction
- Name the person who can pause publication and paid media, and write the stop and removal route before the first release.
- Serve a DMCA §512 notice on the host's designated agentthe contact is listed in the US Copyright Office's Designated Agent Directory — for copies of media you own.
- For non-consensual intimate imagery, use the platform's NCII report flow and a Take It Down Act request; covered platforms must remove reported material within 48 hours of a valid request.
- Register the image with a hash registryStopNCII.org for adults, NCMEC's Take It Down for anyone under 18. Re-uploads are then matched and blocked automatically.
- Send search de-indexing requests, including Google's personal content removal request for non-consensual explicit imagery, and keep platform, host, search, licensee and vendor contacts in one place.
- Use withoutmyconsent.org, the Cyber Civil Rights Initiative's removal guide and help line, for intimate-image cases.
- Set response and escalation times, and write the retention period into the release — a defined campaign term, not "indefinitely".
- Preserve correction and takedown case numbers.
- Delete expired inputs, models, outputs and working files under the retention plan.
If the synthetic likeness is of you
Order matters when AI-generated explicit images of you are already circulating: file the platform's NCII report, register the image with StopNCII.org so copies are hashed, send a DMCA §512 notice to any host carrying your copyrighted photo, then request search de-indexing. In January 2024, AI-generated explicit images of Taylor Swift spread on X; the platform blocked searches for her name and removed the images, but only after copies had reached other sites. Keep every case number — repeat notices are normal, and the material often reappears.
Common questions
Is a Content Credential a consent record?
No. It can carry provenance assertions about a file. Permission scope and legal authority need their own records, signed by the people involved.
Must disclosure say which model was used?
Not always. The detail required depends on law, policy, audience need and risk. Your production record should capture it either way.
Can one approval cover unlimited variants?
That is risky. Define a narrow variation range and send material changes back for review. Approval expiration dates close the gap.
What if a distributor strips metadata?
Keep visible disclosure and an external rights record. Test the actual distribution workflow before launch, not after.







