'They Used Our Faces Without Asking': Londoners Speak Out on Duplicate Image Replacement

A Hackney-based community theatre group noticed it first in March. A promotional banner for a housing development near Bethnal Green Road featured what appeared to be a stock image — except one of the faces belonged to a member of their ensemble who had never signed a release form. The image had been scraped from the group's own website and digitally substituted into a composite scene. The developer had no idea. The image provider claimed it was licensed. Nobody had asked the woman in the photograph.

The practice of duplicate image replacement — pulling existing photographs of real people from public-facing websites, running them through AI-editing pipelines, and reinserting them into new commercial contexts — is drawing increasing scrutiny in London this summer. It sits at the intersection of two live policy debates: the government's ongoing AI regulation consultations under the Data (Use and Access) Act 2025, and Mayor Sadiq Khan's push to tighten accountability standards for developers and advertisers operating on publicly funded or council-adjacent projects across the boroughs.

The Boroughs Where It's Hitting Hardest

Community workers in Peckham and Tower Hamlets say they are fielding a rising number of complaints from residents who have spotted themselves — or people they know — in materials they never authorised. The Southwark-based digital rights advice service Mosaic Legal has seen a roughly 40 percent increase in image-related enquiries since January, according to a casework summary circulated at a Borough Market community forum in June. Haringey Council's equalities team flagged the issue internally after a resident on Tottenham High Road found her image used in a Transport for London consultation document; TfL has since confirmed it is reviewing its third-party image procurement process.

A volunteer coordinator at the Whitechapel-based charity Migrant Roots, who works with communities that are already wary of surveillance and data collection, described the emotional toll without mincing words: people feel their identity has been borrowed and commodified without consent, she said, and for communities with historic reasons to distrust institutional use of their images, the breach feels particularly acute. The coordinator asked not to be named because the charity is in the middle of a formal complaint process.

The technical mechanics matter here. Duplicate image replacement is distinct from deepfake manipulation. It typically involves sourcing a real photograph, using AI image tools to alter backgrounds or context, and placing it in promotional or documentary materials. The altered image may be technically unrecognisable under existing copyright tests — which focus on the original image, not the person depicted — meaning the individual has no automatic legal remedy under current UK law.

What the Law Currently Does — and Doesn't — Cover

The UK has no standalone right of publicity equivalent to those in several US states. The closest protections come through the GDPR-derived provisions in the UK Data Protection Act 2018, which covers identifiable personal data including photographs. The Information Commissioner's Office confirmed in guidance updated in April 2026 that AI-modified images may still constitute personal data if the original subject remains identifiable — but enforcement action against a specific use requires a formal complaint and investigation, a process that typically takes several months.

Legal aid for image-rights cases is effectively non-existent under current civil legal aid thresholds. A single consultation with a specialist data protection solicitor in central London runs between £200 and £400 per hour, placing formal redress out of reach for most of the people raising complaints. The Equality and Human Rights Commission has acknowledged the gap in a written submission to the Culture, Media and Sport Committee, dated May 2026, calling for a review of whether image misuse by AI systems should trigger a new category of enforceable individual rights.

For anyone who believes their image has been used without consent, the ICO's online reporting portal at ico.org.uk accepts complaints directly, with no legal representative required. Organisations including Mosaic Legal and Hackney-based digital rights group Open Iris are offering free initial assessments through July and August. The Southwark Law Centre on Peckham Road has also added image-rights queries to its weekly drop-in rota, running every Thursday from 10am. Borough councillors in at least three London authorities — Lambeth, Islington, and Greenwich — have tabled motions asking for procurement guidance to explicitly ban use of AI-modified community imagery in public consultation materials.