For studios and agencies: leak removal for several models

Who files which complaint

Each kind of complaint has its own filer.

• Copyright complaint (DMCA and similar forms). Filed by the copyright owner or a person authorized to act for them: under section 512(c)(3)(A) of US law, that person signs the notice and states under penalty of perjury that they are authorized.
• Request about intimate images shared without consent. The basis is who is shown, not who owns the recording. Under the TAKE IT DOWN Act, it comes from the person shown or a person authorized to act for them. Google also accepts it from the person shown or their representative.
• Report under platform rules. VK says a community report must come from the person affected, and StopNCII accepts image hashes only from the person in the images.

So the model files some complaints themselves, even when the studio handles the rest.

When the studio is the rights holder

Under the Russian Civil Code, the author of a recording is the person whose creative work produced it (Article 1257). A studio gets rights only under a contract, an assignment or a license, and a license does not transfer the exclusive right (Article 1233). Check whether the contract lets the studio file in its own name.

The right to one’s image is separate. Under Article 152.1, an image may be used only with the person’s consent, and the person may demand removal of an image spread online in breach of that rule. The studio can act for the model under a power of attorney, a written authorization to represent them (Article 185).

Without the rights, do not file in the studio’s name: under section 512(f), a person who knowingly misrepresents infringement in a DMCA notice is liable for damages.

What to collect from each model

• A power of attorney: which complaints, which platforms, for how long. VK asks a representative for a copy of the document proving authority.
• The contract giving the studio rights to the recordings, if it files in its own name.
• Usernames, profiles and accounts on every platform, old ones included.
• Direct links to each leak and a description of the original: a DMCA notice must identify the work.
• Screenshots showing the page address and date.
• A reply email, and whose it is: the model’s or the studio’s.

How to run several models’ cases

• A separate case for each model: number, power of attorney, usernames, links.
• A link log: address, platform, complaint type, filing date, complaint number, reply, recheck date.
• Separate complaints for each model: each has their own filer and documents.
• One person in charge of each case, so platform replies are not lost.
• Recheck removed links: a leak can be posted again.

How to protect the models’ data

A passport, a legal name, usernames and leak links together expose a person. A studio in Russia that collects them is a personal data operator under Federal Law 152-FZ and has to:

• notify Roskomnadzor, the Russian data protection authority, before processing starts (Article 22);
• appoint a person in charge and adopt a processing policy (Article 18.1);
• protect the data with legal, organizational and technical measures (Article 19);
• notify Roskomnadzor separately before sending data abroad, for example to foreign hosts (Article 12);
• report a breach within 24 hours and destroy the data within 30 days once the purpose is achieved (Article 21).

Data about intimate life is a special category: it may be processed, for example, with written consent (Article 10). A contractor gets the data under an operator’s instruction with the model’s consent (Article 6).

Keep files in one protected place with personal access, do not forward leaks in group chats, and give a contractor only what the complaints need.

Google may forward DMCA notices to the Lumen project, which publishes them with some personal information removed. Decide in advance whose name goes on the notice.

An estimate for several models

The calculator on the home page prices one order for several models: set the number of models and the leaks for each. Payment is one-off, for the leaks found. Open the calculator or send a request.