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One of the reasons the DOJ gave for declining to adopt the suggestion of allowing sanitization, was the burden they perceived it placing on some webmasters. According to the preliminary legal opinion I got yesterday, the key issues in this section are that they did decline that option and that by extension, the information some had proposed "sanitizing" must therefore be included in plain.
I'm sure anyone who has spoken to a lawyer will have been told that in matters like this, even expert opinions will vary. The opinion you decide to adopt is likely to reflect the degree of risk you are willing to take and this is a good example.
It is clear that the DOJ wants to see all the details that would allow them to identify fully the models involved. Apart from what they have actually written, how could they check the validity of the information a site operator provides, with nothing more than a photocopied ID showing a name and birthdate? So you make a choice either to give them what they want, or to take advantage of what you or your counsel perceives as a loophole, and hope you can successfully argue that defense if the need arises.
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