Full-face photographs are treated as identifiers

What the source requires

Full-face photographic images are a Safe Harbor identifier. Cropping does not de-identify them.

Why this is hard to satisfy

No practical way to detect faces across a photo library, and a widespread belief that cropping or angling is sufficient.

What we do about it

Face detection flags a full face the page presents as a patient — a before/after, a testimonial, a gallery — and asks for the authorization behind it. It does not block: whether the face is a patient’s, staff’s or a licensed model’s is not on the page.

In build · phase two