The question here is what is the emphasis on the word
require. The way I read the statement below, the DOJ chose not to make it a requirement that the primary producer send sanitized documents, not that they couldn't do so if they wished. This would be consistant with the statement that model ID's have enough information that they can be traced back to the source documents. That statement seems to imply that some information may not be included.
Yet another of those very thin lines that the court will eventually have to decide.
Quote:
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Originally Posted by DOJ communique
Another commenter proposed that secondary producers be required to
store sanitized (i.e., without personal information such as home
address) hard or digital copies of performers' identification documents
along with a notarized affidavit from the primary producer stating the
location of the complete records. The Department declines to adopt this
comment. Although the Department understands the commenter's desire to
protect private information about performers from being too widely
disseminated, it believes that the suggested plan would be overly
burdensome on primary producers and add an unnecessary layer of
complexity to the record-keeping process. Primary producers would be
required first to sanitize the identification documents and then to
draft, sign, and pay for a notarized affidavit. It is simpler and less
burdensome simply to have primary producers transfer a copy of the
records to secondary producers.
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