2257 Record-Keeping: An Organising Guide for Producers

What the term refers to

"2257" is shorthand for 18 U.S.C. § 2257 and its related regulations, a federal record-keeping law that can apply to producers of certain visual content. In general terms, it concerns keeping records about the people who appear in that content, including records that verify identity and age, and keeping those records in a way that can be located and shown when required.

This is a very general description, not a summary of the statute. Whether and how it applies to your work is exactly the kind of question an attorney should answer. What this guide covers is the practical side: once you know what you need to keep, how do you keep it organised?

The practical problem

Many record-keeping problems come from disorganisation rather than intent. An ID photo is in one folder, the release is in a different one, the shoot date is in a calendar, and nobody can say with confidence that a particular performer's records are complete. Common trouble spots:

• A release exists but is not linked to the shoot or content it covers.
• A performer's ID record has expired, or was never captured.
• Records are spread across phones, email, cloud folders and paper.
• Old releases from before you had a system are scattered and unmatched.
• You cannot quickly show which records belong to which performer.

How software can help you organise

Software cannot decide what your obligations are. It can make the records you decide to keep easier to create and find. A good set of 2257 record-keeping tools should help you capture records at the moment they are created, link each one to a performer and a shoot, and show you at a glance where something is missing.

• Capture on set. Model Release Pro captures the ID and the signed release on your phone at the time of the shoot, instead of reconstructing them later.
• Link records together. When you press Sync, releases arrive in My Content Tools and are matched to the shoot and the performer.
• See what is missing. A Records Check lists problems it finds in your records, such as a performer with no signed release on file for a shoot, and offers a fix for each one. Nothing changes until you confirm.
• Backfill old releases. A release backfill tool scans a folder of your existing releases and helps you match each one to the right performer. You confirm each one.
• Where records are stored. Your records are stored on your own computer. If you use Model Release Pro, what you capture on your phone is sent through our cloud service so it can be delivered to your computer when you press Sync.

Who is responsible

Responsibility for your records rests with you as the producer. My Content Tools does not act as custodian of your records, and using it is not a substitute for understanding your own responsibilities.

A sensible way to start

Whatever tools you use, a few habits help. Capture records when the shoot happens, not weeks later. Keep a consistent profile for each performer in your roster. Link every release to a shoot. Review your records on a schedule rather than waiting for a problem. And write down who in your organisation is responsible for them.

Ask your attorney how records kept for 2257 purposes should be organised, including whether they must be kept separate from your other business records; the roster and shoot records in My Content Tools are not a substitute for that advice.

If you want to see how this looks in practice, read about how a model release app works or see how studios use My Content Tools. The site also carries our 18 U.S.C. 2257 page.