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Yes, secondary producers needing to be custodian of records is nothing new.
There are thousands of webmasters who've been in violation, and I don't see most of those ID's ever being sent out to them.
The bad part about that is if you've EVER published a photo, then you've got to be custodian for a number of years afterwords too. So even if you pulled content now, you'll still be breaking the law for years to come.
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