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USE OF ARTIFICIAL INTELLIGENCE (AI) IN THE MODEL INDUSTRY CODE OF PRACTICE

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This Code of Practice has been developed in alignment with the requirements of the Data Protection Act 2018, the UK General Data Protection Regulation (2021, Article 9), and the EU Artificial Intelligence Act (2024, Article 50), which, together establish the legal framework governing the processing of biometric and special-category personal data.



  1. AI should always be used responsibly, ethically and in ways that build consumer trust in the use and work of models in brand marketing & advertising.

  2. AI must not be used to mislead audiences - particularly through synthetic / AI-generated digital humans, undisclosed digital replicas of models, manipulated likenesses or fabricated endorsements.

  3. Agencies, clients and partners must be transparent about their use of AI – disclosing both to consumers when AI-generated models or enhancements are used and to each other when sharing materials that include AI/CGI-generated or AI-modified content.

  4. The environmental impact of generative AI (including large image/video generation workflows) should be considered when planning shoots or content production.

  5. AI must not discriminate or introduce bias in casting, representation or client deliverables.

  6. AI must not undermine individual rights, including model consent, image rights, privacy rights, personal data, copyright, trade marks, and the lawful use of likenesses. Specifically, individuals must retain ownership of & have complete access to any personal data (including but not limited to biometric data and any digital version or twin generated from that data).

  7. Prior written consent must be obtained from the Model prior to any capture, storage & manipulation of their data in any AI system/software, as must any commercial usage of that data by a client or third party.

  8. Data collected from a model or talent through photography or videography must not be used in any AI training datasets.

  9. Agencies and clients must consider the impact of AI on intellectual property, licensing, usage rights and the protection of original work by photographers, creators and models.

  10. AI should support and not replace human talent.

  11. Only AI tools that have been pre-disclosed and properly vetted for safety, security and ethical use should be used in casting, retouching, talent management or content creation.

  12. Human oversight and accountability must always be maintained.

  13. Agencies and industry bodies should continually monitor and evaluate AI use, keeping up with emerging risks such as impersonation, exploitation, deepfakes or talent displacement.

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