Their faces appear on websites they have never visited, selling products they have never used, endorsing causes they have never supported. For a growing number of Londoners, the unauthorised reuse of personal photographs — so-called duplicate image replacement, where scraped photos are repurposed across digital platforms — has become a daily reality with real-world consequences.
The issue has gained urgency in 2026 as the UK's Online Safety Act regime beds in and the Information Commissioner's Office ramps up enforcement activity. Campaigners argue that enforcement has not kept pace with the scale of the problem, particularly for working-class communities in south and east London whose members are less likely to have legal resources to pursue takedown requests individually.
In Bethnal Green, the Brady Arts Centre has been running informal digital rights workshops since March 2026, drawing residents who have encountered similar problems. The sessions, held fortnightly on Thursday evenings, have attracted participants from across Tower Hamlets, many of them recent migrants who were unaware they held any rights over images posted on social media. Organisers say attendees frequently arrive having already lost access to the original platform accounts where the images were first uploaded, making formal complaints procedurally difficult.
Hackney Council's Digital Inclusion team, which operates out of the Hackney Service Centre on Mare Street, flagged the issue to the ICO in a submission dated February 2026, noting that several residents had found their images embedded in AI training datasets without consent. The council stopped short of quantifying the number of affected residents in its submission, citing the difficulty of independent verification.
What the Data Shows — and What It Doesn't
The ICO published figures in its 2025-26 annual report showing it received more than 4,200 complaints related to image misuse in the twelve months to March 2026, a figure the regulator described as a significant increase on the prior period. Complaints involving AI-generated or AI-redistributed imagery accounted for roughly a third of that total, according to the same report. The ICO did not break down complaints by region, so London-specific figures are not publicly available.
Legal costs remain prohibitive for most individuals. Solicitors specialising in data protection work in central London typically charge between £250 and £400 per hour for image rights casework, according to published fee schedules from firms including those listed on the Law Society's Find a Solicitor directory. A standard takedown and compensation claim can run to several thousand pounds before any hearing — well beyond the reach of most market traders or community centre users.
Southwark Law Centre, based on Peckham Road, has taken on a handful of pro bono image misuse cases this year, but staff there have said publicly their caseload is already oversubscribed and they cannot accept every referral that comes in.
For those looking for a first step, the ICO's online complaints portal accepts image misuse reports without a fee and can issue enforcement notices compelling platforms to remove content. The process typically takes between eight and sixteen weeks. Separately, the Centre for Data Ethics and Innovation, a government advisory body, is consulting until 31 August 2026 on new standards for image data use in AI systems — a process that community groups including Brady Arts are formally engaging with. Residents in affected areas can submit evidence directly via the CDEI's consultation page before that deadline, a route that costs nothing and requires no legal representation.