Scope determination
Counsel must determine the platform’s exact obligations under 18 U.S.C. §§2257/2257A and implementing rules based on how UnlockMyPage receives, manages and publishes content.
Records architecture
For covered content, the system should associate each submission with the verified performers, required identity/age records, consent/release records, record custodian information and any required labeling statement.
Storage
Sensitive identity records should be segregated from ordinary application data, protected by least-privilege access and audited. Do not expose raw identity documents through creator or ordinary admin interfaces.
Publication gate
Content that requires performer records should remain non-public until all required performer records and consent links are complete.