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AaronM · 05-26-2005, 09:45 AM

Allow me to start by saying that I have yet to discuss this issue with an attorney, I'm simply reading these new regulations and trying to find ways to work within them.

"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."

Now, the way this reads to me is that the DOJ has decided not to "require" us to sanitize the docs. BUT...Nowhere in that paragraph does it say that we can't do so voluntarily.

Your thoughts?

05-26-2005, 09:45 AM
AaronM GFY Royality ;) Industry Role: Join Date: Oct 2001 Location: ┌∩┐ ◣_◢ ┌∩┐ Posts: 46,922	Sanitized 2257 Docs. Allow me to start by saying that I have yet to discuss this issue with an attorney, I'm simply reading these new regulations and trying to find ways to work within them. "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." Now, the way this reads to me is that the DOJ has decided not to "require" us to sanitize the docs. BUT...Nowhere in that paragraph does it say that we can't do so voluntarily. Your thoughts?