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Actor lookalikes submission rules: three hard cases
Actor lookalikes submission rules are clauses with jobs, tested against three hard cases: the child performer, the background performer, and your own likeness.
Most submission policies are just lists of things not to send, which is the weakest form a policy can take. A list invites the reader to find the case it does not cover.
The stronger form is a set of clauses, each with a job and each tested against awkward cases the Lookalike Face Matches desk receives. This page sets out the actor lookalikes submission rules in that form, then works through three cases where the desk is most tempted to bend.
What to take away
- A policy is a set of clauses with jobs, not a list of prohibitions.
- A child with a public role is still a child. Public visibility removes nothing from the exclusion.
- A face on screen does not make a person a public figure. Background performers are private individuals.
- You may submit your own likeness, and the site still will not tell you who you look like, because the answer is a claim about someone else.
The clauses and their jobs
| Clause | What it has to do |
|---|---|
| Scope | Say what the site publishes at all, so that most submissions are ruled in or out before anyone reads them |
| Public figure | Define the term narrowly: a person with a professional relationship to being seen, an audience, and a route to reply |
| Minors | Exclude every person under the age of majority from every format, with no consent route and no public-role exception |
| Private individuals | Exclude every person who is not a public figure, in every form: image, name, description, location |
| Identification | Refuse any request to say who a person in an image is, and refuse to point to any means of finding out |
| Evidence | State what a submission must carry to be considered: a source for each image and a stated reason it is within scope |
| Decision | Name one person who decides, so the standard does not drift between reviewers |
| Correction and removal | Publish the route, act on it quickly, and never require the subject to justify the request |
| Retention | Delete what is refused. Do not archive images of people the policy has excluded |
| Responsibility | Say who answers for the policy and how to reach them |
The general reasoning behind the exclusions, and why consent does not rescue them, is set out in the published submissions policy of Lookalike Face Matches, User submissions submission rules, clause by clause. What follows is the part specific to performers.
Submission clauses and their jobs
- Scopewhat the site publishes
- Public figurenarrow, with reply route
- Minorsexcluded, no consent route
- Private individualsexcluded in every form
- Identificationrefuse to name anyone
- Evidencesource plus stated reason
- Decisionone named decider
- Correction and removalfast, no justification
Case one: the child performer
The argument arrives in a predictable shape. The child is a working actor. Their face is on posters. They have a public role. Surely the public-figure clause covers them.
Does the public-figure clause cover a child?
Is the person under the age of majority?
minors clause excludes them, no consent route
public-figure test applies as written
It does not, and the minors clause sits above it so the order is unambiguous.
A public role is something adults placed a child in, and the child did not choose it or understand what being looked at for a living involves. It gives them no audience, representation, or reply route that makes public-figure asymmetry tolerable in an adult.
A resemblance claim about a child performer is a public statement about a child's body. The child's job does not change what it is.
The law draws the same boundary. In the US, COPPA — the Children's Online Privacy Protection Act, enforced by the FTC — counts a photograph containing a child's image as personal information, so a site that takes one in has to account for holding it. A minor performer works under a permit issued by a state labor department, such as California's Division of Labor Standards Enforcement, and California's Coogan Law, named for the child star Jackie Coogan, requires that a share of a minor performer's earnings be held in trust. In each case an adult signs, an adult holds the right, and the child supplies the face. None of it hands the desk a consent it can act on.
The clause also has to cover the adult performer's early career. A comparison built on an image of a well-known adult taken when they were a child is an image of a child. The exclusion follows the age in the picture, not the age today.
Case two: the background performer
Someone appears on screen for two seconds in a crowd scene, or in a small part with a line, and a viewer decides they resemble a well-known actor. The submission names the production and the timestamp.
That person is not a public figure. They were paid for a day's work in a frame. They have no audience, no representation, and no way to answer a claim about their appearance now tied to a production they appear in.
Naming the production and the timestamp identifies them precisely. The private-individuals clause forbids that as plainly as it forbids a name.
The doubling trades show that productions hire on silhouette, and the job of standing in for a performer in specific shots is matched the same way, so a background performer may well have been placed for that reason. That is a fact about casting, not an invitation to publish their face.
Case three: your own likeness
A reader sends their own headshot and asks who they look like. This is the one submission where consent is real: the person consenting is the person in the picture.
Consent is not the only thing a sender brings. Under the CCPA, as amended by the CPRA, a California resident can ask what personal information an organization holds about them and have it deleted, so a self-submission arrives with a data right attached as well as a permission.
The policy still declines to answer for two reasons.
First, any answer is a resemblance claim about the named performer, made without them, and a person's interest in the use of their own name and likeness does not pause because somebody else asked.
Second, "who do I look like" is "who is this" with the intent reversed, and a site that performs one cannot credibly refuse the other. The answer is "not here", not "no one".
What the site can do with a self-submission is more useful: discuss what in the photograph produces the impression the reader already has. That conversation about lens, light and hair needs no third party.
Readers who do this work professionally, as stand-ins or tribute performers, are welcome to write about their own practice. For them, the trade is the better subject and one they can speak to.
Why the exclusions are total
A threshold rule, one that weighs the public role, the age, the context and the intent, gives every submitter something to argue with, and the argument is conducted through an inbox where nothing can be verified. Age cannot be checked from a photograph. Consent cannot be checked from a message. Intent cannot be checked at all.
A categorical rule asks one question of the image: is this a public adult, and if the answer is not clearly yes, the submission is refused and deleted.
That costs some interesting material. It also means the site never becomes the place where a child or a stranger was identified, the outcome the whole policy exists to prevent. The over-detecting eye will keep generating candidates; the policy is what stops them becoming publications.
Common questions
Does the site accept submissions about adult performers?
Observations about the photography, corrections and accounts from the trade, yes. Pairings and resemblance claims, no.
What happens to a refused image?
It is deleted. A refused image of an excluded person is not kept, because keeping it recreates the risk.
Can a parent or agent consent on behalf of a child performer?
No. The minors clause has no consent route by design.
