Quote:
Originally posted by LadyMischief
Nobody here is bothering to mention if this is retroactive or not :P 
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It is NOT retroactive.
"This requirement is not a retroactive application, but a requirement that any future change in the records must ensure that all records relating to that performer are
complete."
So you do not need to go back and contact people you photographed 5 years ago for example to be in compliance.