This Code of Practice sets out Arch Agency’s standards for the ethical, lawful, and transparent use of Artificial Intelligence (AI) within the modelling, creative, influencer, and UGC sectors.

It is aligned with:

• Data Protection Act 2018

• UK GDPR (2021, Article 9)

• EU Artificial Intelligence Act (2024, Article 50)

• BFMA industry guidance

• Arch Agency Safeguarding Policy

• Arch Agency Client & Talent Terms & Conditions

This Code applies to:

• Arch Agency all represented Talent

• all clients, partners, and third parties working with Arch Agency

• all production teams, photographers, and content creators

 

1. Responsible & Ethical Use of AI

AI must always be used responsibly, ethically, and in a manner that protects the rights, dignity, and wellbeing of Talent. AI must support — not replace — human creativity and human talent.

 

2. No Misleading or Deceptive AI Use

AI must not be used to mislead audiences, including through:

• synthetic or AI‑generated digital humans

• undisclosed digital replicas

• manipulated likenesses

• fabricated endorsements

• deepfakes or impersonations

Any AI‑generated content must be clearly disclosed.

 

3. Transparency & Disclosure

Clients, partners, and agencies must:

• disclose when AI is used in casting, retouching, or content creation

• disclose when images or videos include AI‑generated or AI‑modified elements

• disclose to Arch Agency and Talent when AI tools are used on their likeness

• disclose to consumers when AI‑generated models or enhancements appear in campaigns

There must be no hidden AI use.

 

4. Environmental Considerations

The environmental impact of generative AI — particularly large‑scale image or video generation — must be considered when planning shoots or content production.

Where possible, sustainable alternatives should be prioritised.

 

5. No Discrimination or Bias

AI must not introduce or reinforce bias in:

• casting

• representation

• selection processes

• deliverables

• automated decision‑making

AI systems must be assessed for fairness and inclusivity.

 

6. Protection of Individual Rights

AI must not undermine:

• model consent

• image rights

• privacy rights

• personal data rights

• copyright

• trademarks

• lawful use of likenesses

Talent retain full ownership and access to:

• their personal data

• biometric data

• any digital version, replica, or twin generated from their data

 

7. Consent Requirements

Prior written consent from Talent is required before:

• capturing biometric data

• storing biometric data

• manipulating likenesses

• using any likeness in AI systems

• generating digital replicas

• creating avatars or virtual models

• using likenesses in AI‑driven campaigns

• commercialising any AI‑generated content

Consent must be specific, informed, and revocable.

 

8. No AI Training Using Talent Data

Photography, videography, or any captured likeness of Talent must not be used in:

• AI training datasets

• machine‑learning systems

• generative AI models

• deepfake tools

• dataset enrichment workflows

This applies to all clients, partners, and third parties.

 

9. Intellectual Property & Licensing

AI use must respect:

• copyright

• licensing agreements

• usage rights

• photographer rights

• creator rights

• Talent image rights

Any AI‑generated or AI‑modified content must be licensed appropriately and transparently.

 

10. AI Must Support, Not Replace, Human Talent

AI should enhance creative workflows — not replace working models, creatives, or content creators.

Clients must not use AI to:

• replicate Talent without consent

• replace booked Talent

• generate synthetic alternatives to avoid paying Talent

• create digital doubles without compensation

 

11. Approved AI Tools Only

Only AI tools that are:

• pre‑disclosed

• vetted

• safe

• secure

• ethically compliant

may be used in casting, retouching, talent management, or content creation.

Unapproved AI tools must not be used.

 

12. Human Oversight & Accountability

Human oversight must be maintained at all times. AI must not make autonomous decisions about:

• casting

• representation

• usage rights

• likeness manipulation

• consent

• safeguarding

Accountability remains with the human decision‑makers.

 

13. Monitoring, Risk Management & Emerging Threats

Arch Agency, clients, and partners must continually monitor AI use and remain alert to:

• impersonation

• exploitation

• deepfakes

• identity theft

• unauthorised digital replicas

• talent displacement

• misuse of biometric data

 

Arch Agency reserves the right to withdraw Talent or terminate a booking if AI is used in a way that breaches this Code.