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From 2257
".... shall create and maintain individually identifiable records pertaining to every performer portrayed in such a visual depiction."
I don't know about you, but I read that as a record for each performer, not for each shoot, day, set, or any other way you want to separate things.
It does require you to review the performer's picture ID when creating the content, but nowhere I could find did it indicate that you need to keep separate records for each shoot. Further, if you have a record on file with information of a performer that you know to be of legal age (a record captured and maintained by you, not by someone else), why would you need a copy of a current form of ID at a secondary shoot? Yes, yes, I know it's good business practice, but you already have identifying information showing they were legally allowed to do what they were doing at a previous date. Has this person somehow magically aged in reverse and therefore we must require proof that they were of legal age the second time we shot with them just in case? Maybe because their identification has expired? By sheer logic any investigating authority would skim right over that and look for situations where you didn't have a record for a performer or even more sinister, for a performer that was assumed to be under 18.
I shoot a girl one time... she's legal and has proof of it, we're golden. Why would I ever need to verify she's 18 again? I already have proof of it. I honestly don't even care if her identification is valid at the next shoot because I have already done my job and I am maintaining a record of it. I think the airlines would care because her ID should be valid to fly, but for me an expired ID on a secondary shoot would mean nothing.
BTW, in regards to the record keeping, for compliance, I would need to annotate her file and indicate that another shoot was performed with her on such and such a date. Easy.
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