I don't believe you need to put the MODEL's id's on your website ... you just need to list YOUR Name or Company Name and the address of where you do business out of so that Big Brother can show up and go over your documentation. So as far as a Joe Surfer is concerned, he doesn't have access to that information. Unless you have a sponsor site that doesn't require a login to get the content ... then that's a concern of course.

BUT, if you're doing an affiliate program, and provide the required documents along with downloadable content/galleries for instance, and an AFFILIATE stalks a guy and kills him (which you'd have records of his being one) ... I don't see how you'd be accountable for his actions or violating privacy since you were complying with regulations. But I'm not a lawyer, and this certainly is one of the many parts of the whole that most of us are bristling at in the new regs.

I know I totally disagree with the whole secondary producer part of it, but the US stance that content coming in from another country where they have privacy laws and are unwilling to break THEIR laws to give us the ID's is moot if they want to do business with US Webmasters is way off base.

Saying that other countries must meet our import and trade regulations and labeling is one thing when discussing a pound of macadamia nuts, it's something else altogether when it applies to a PERSON, even in a sideways fashion.

Ok, climbing off my soap box ... just needed to vent a bit.