If an employee gives us consent to appear in a promotional film and later withdraws it, must we remove the film? But nothing disappears from the Internet.

ANSWER

Withdrawal of consent/authorisation to disseminate an image operates for the future and does not have retroactive effect. Dissemination of the image before consent was withdrawn is lawful.

If the promotional film has already been disseminated/made public in accordance with the arrangements then in place between the parties, withdrawal of consent does not require withdrawal/removal of all recordings already disseminated on the Internet. Withdrawal of consent will only mean that from that moment the film/recording containing the image may no longer be further disseminated in the future.