Some shoots happened years ago. Some models have moved on and cannot be reached. And a great deal of content is bought rather than shot, arriving with a folder of paperwork attached. In none of those cases is a ProntoTag available — but doing nothing is not the only alternative.
The Archive stores what you already have, binds your account of it to a verified identity, and records honestly why nothing stronger was possible.
We would rather tell you that plainly than have you discover it during a dispute. If you shot the content and can still reach the model, close this page and create a ProntoTag instead. If you bought the content, this is a different matter: a ProntoTag was never available to you, and 28 C.F.R. § 75.2(b) points here. Then the question is not which tool, but how complete the file you were given is.
Both parties identity-verified. The model is notified and actively confirms consent for that specific content.
One verified identity — but that identity is the person depicted. Account-level authorisation for self-posted content.
Only you are verified; the model's participation is asserted, not witnessed. Weak as consent evidence — yet for acquired content it is the route the regulation actually prescribes.
Signed releases and identification are stored encrypted at rest with a per-file KMS data key, and retrievable on demand. Paper fades, floods, moves office and gets thrown out by someone tidying up.
Your statement about the shoot is signed against a KYC-verified identity and timestamped when you make it. A self-serving statement made today is weak; the same statement made years before any dispute arose, by a provably identified person, is a different thing entirely.
The record states plainly why a ProntoTag was not created and what your contact position with the model is. Volunteering the weakness is what makes the rest of the file credible.
Records sit under a retention rule rather than in your memory, and can be produced when a platform, processor or counsel asks for them.
On acquired content we ask four questions about the file you were given — is the ID card number unredacted, were all aliases supplied, do you have the production date and a street address for the producer. Whatever you answer is recorded, and anything missing comes back as a list of what to ask your source for.
The second point is the one that matters most. A statement you make today about a shoot from 2019 is self-serving, and everyone knows it. The same statement, made before any dispute existed, by someone whose identity was verified against a government document, and sealed so it cannot be quietly revised afterwards — that is a materially different object. It is not consent. It is a contemporaneous, attributable account, which is the next best thing available when consent cannot be obtained.
Most files bought with content are incomplete, and the buyer usually has no way of knowing. § 75.2 lists what a record contains; almost nobody checks the delivery against it.
The same blind spot applies to scope. A release you were handed may exclude a territory or a medium you are actively publishing in — we wrote about how that happens.
So we ask, we record your answers — gaps included — and we hand you back a list of what to go and ask for. You can still submit with every box unticked. A gap on the record is worth more than a gap nobody wrote down.
Sellers may redact addresses and phone numbers. § 75.2(b) expressly does not permit redacting this number — and a privacy-minded seller reaches for it first.
Not just the one on the invoice. § 75.3 requires the record to be findable by any of them.
What shows the identification was examined before the shoot rather than afterwards.
Not a PO box, not an email. § 75.2(b) makes it an element of the record you keep.
Read this section properly. Every one of these is a real limitation, and knowing them is what stops you relying on the Archive for something it was never built to carry.
We never met them and never examined their document. What we hold is a scan you supplied and your word about where it came from.
Nobody on the other side confirmed anything. There is no bilateral agreement here, only your account of one that happened offline.
We cannot tell a genuine signature from a forged one, or a valid release from one whose terms do not actually cover what you are doing.
If the release was too narrow, or the identification was expired, or the model was not who they said they were, archiving it preserves the problem rather than fixing it.
28 C.F.R. § 75.2 also requires the depiction, its URL and a title index. Under § 75.2(h) no service can take on the producer’s liability.
A model who does not know the record exists cannot exercise rights against it. Where we can reach them, we notify them; where we cannot, we record why.
You acquired the material with its paperwork and are publishing or reselling it. 28 C.F.R. § 75.2(b) is written for exactly this, and the flow branches to match.
Shoots from before you used any verification system, where a signed paper release exists and the content is still published or still earning.
People who have moved on, changed names, left the industry, or whose details you simply no longer hold.
When an acquirer, payment provider or platform asks what documentation you hold for older material, and the honest answer is currently “a folder somewhere”.
Buyers do diligence on records. A structured, dated, identity-bound archive is worth more at sale than a box of paper, even where it cannot be upgraded.
Bought it rather than shot it? Say so at the start. The flow branches: you are never asked to claim you were at a shoot you did not attend. Instead you record your source and their street address — the element 28 C.F.R. § 75.2(b) is specific about — and confirm what you actually received. See our guide to buying content and § 2257 for what a complete file looks like.
Two fields in the upload flow do most of the work, and both of them invite an uncomfortable answer. That is deliberate. An honest record is worth more than a flattering one, and every option we offer is accepted without judgement.
Exact day, month and year, or year only. For older material, pick what you actually know. A guess recorded as an exact date is worse than an honest approximation — because precision that turns out to be invented calls everything around it into question.
From “they can be reached but have not completed a ProntoTag” through to “I hold no contact details at all”. This is the question a regulator asks first. Answering it before anyone asks, rather than reconstructing an answer afterwards, is most of the value here.
We should be direct about what is happening here. You are uploading another person’s identification document and signed release, and in most Archive cases they do not know you are doing it. That is lawful in the right circumstances, but it is not consequence-free.
ProntoID is an independent controller of the record. Where personal data is obtained other than from the individual, Article 14 GDPR generally requires them to be informed — with an exception at Article 14(5)(b) where doing so would involve disproportionate effort. Your recorded contact position is what that assessment rests on, which is another reason to answer it honestly.
Models can contact us directly at privacy@prontoid.com to exercise their rights, and we will never ask anyone to send us images to prove who they are. Documents are encrypted at rest with a per-file KMS data key.
No, and we will not pretend otherwise. A ProntoTag is bilateral: both parties are identity-verified and the model actively confirms consent for that specific content. An archived paper release is unilateral — only you are verified, and the model's participation is something you assert rather than something we witnessed. Where you can still reach the model, create a ProntoTag. The Archive exists for the situations where you genuinely cannot.
Four things a drawer cannot give you. The paper is preserved, encrypted and retrievable rather than degrading in a filing cabinet. Your account of the shoot is bound to a KYC-verified identity and dated at the moment you make it, rather than being asserted years later during a dispute. The reason bilateral consent was not obtained is recorded contemporaneously — which is the question that actually gets asked. And the record sits under a retention schedule instead of your memory.
No. It helps you hold and retrieve part of what 28 C.F.R. § 75.2 requires. The regulation also requires a copy of each depiction, the URL where it is published, and indexing by title — and under § 75.2(h) engaging any records service never relieves the producer of liability. The Archive is storage and attestation, not compliance certification.
Because it is the first thing anyone reviewing the file will want to know, and answering it before a dispute is worth far more than answering it during one. Every option is accepted — including that you hold no contact details at all. We are recording the position honestly, not judging it. An optimistic answer helps you far less than an accurate one.
Because a guess recorded as an exact date is worse than an honest approximation. If you only know the year, say so. A record that claims precision it does not have is the kind of detail that undermines everything around it when examined closely, whereas an acknowledged approximation is simply an acknowledged approximation.
It can be, but it creates obligations. ProntoID is an independent controller of the record, and where personal data is obtained other than from the individual, Article 14 GDPR generally requires them to be informed. Article 14(5)(b) provides an exception where doing so would involve disproportionate effort — which is precisely why we ask you to record your contact position. We handle notification where contact is possible, and document the position where it is not.
Yes, and they can contact us directly at privacy@prontoid.com. They have rights of access, rectification, objection and erasure, subject to the Article 17(3) exceptions where a record is needed for legal claims or a legal obligation. If they dispute that they signed the release at all, that is a matter between you and them — but the dispute will be recorded against the file.
Yes. Tell us at the start that you acquired it, and the flow changes: you will not be asked to say you were at the shoot or that you examined anyone's identification, because you were not and you did not. Instead you record who you got it from and their street address — which 28 C.F.R. § 75.2(b) makes an express element — and confirm what you received from them. That provision exists precisely for people in your position, so this is the designed route rather than a workaround.
This page is general information, not legal advice. ProntoID and Brooks & Keitt Sàrl are not a law firm.
If there is any chance of reaching them, a ProntoTag is worth far more than an archived paper release. The Archive is here for when that chance has genuinely gone.
Brooks & Keitt Sàrl · Place du Midi 30, 1950 Sion, Switzerland