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FACTUAL ACTIVITY RECORD · An activity record based on work that took place

Defining publication conditions for AI-generated profile images

Separating confirmed facts, display constraints, and unresolved risks around bilingual disclosure and first image exposure

Activity period:

Purpose

Before implementing the corporate site's public copy and AI Talent profile images, the legal questions around AI personas, AI-generated images, organization and product language, calls to action, and locale display needed to be organized so the presentation would not mislead readers.

The work aimed to determine whether the existing Japanese and English disclosure direction could be retained, separate the confirmed fact that the intended images were AI-generated from unresolved matters such as per-image provenance, rights, and real-person similarity, and turn those boundaries into implementable publication constraints for the downstream UI.

Implementation

publication and legal assessment classified confirmed facts, unconfirmed facts, and prohibited inferences across the intended Japanese and English copy, AI personas, profile images, claims, calls to action, and locale display. It explicitly did not provide final legal advice, jurisdiction-specific applicability, final legal approval, or publication approval.

The CEO confirmed that the intended profile images were AI-generated and had no objection to the direction of the existing Japanese and English disclosures. No copy change was requested. The retained disclosure direction contained three elements: AI Talent represents role-bearing AI personas; they are not humans, real people, or human employees; and the portraits are AI-generated representations of those personas.

  • Place the full locale-matched disclosure in ordinary reading order before the first image in the same profile collection.
  • Do not substitute hover, collapsed content, a tooltip, image alternative text, or a Legal page alone for the notice.
  • When an image is reused away from the collection, such as in a Hero, card, modal, search image, or social image, provide an equivalent nearby disclosure in that context.
  • Keep the notice readable at responsive widths and ordinary zoom with adequate contrast, without relying only on color, an icon, or image metadata, and include it in keyboard and screen-reader reading order.
  • Preserve the meaning of all three elements across locale switching, and do not expose an image in a locale whose disclosure is absent or materially weaker.

In the mobile reading order examined by the assessment, the images appeared before the common disclosure. A later shared notice was not sufficient when a human-like image was encountered first, so the downstream UI constraint required either moving the full disclosure before the images or adding a visible AI-persona and AI-generated label to every image that could appear first.

Every image addition, removal, replacement, or move required another check of the AI-generation fact and its relationship to the disclosure. Because the design showed nine profiles while the asset inventory contained ten files, the assessment also prohibited making a public profile-count claim until the final set was resolved.

The claim boundary excluded unsupported biographies, careers, achievements, quotations, personality, wording that implied human staff or a real person, unverified product information, availability, and link destinations. Calls to action, contact routes, and policy surfaces could not appear available until the accountable owner confirmed the facts and operating process.

The pre-publication questions covered each image's generation method and later edits, provenance, rights and permitted use, real-person similarity and any required consent, publication territories and reachable readers, operator information, every display context, and the final profile set. Where the applicable territory or publication risk required qualified professional judgment, the result could not be described as legally approved until that assessment was completed separately.

The primary diff was checked line by line to confirm that the behavior described above matched the change at the cutoff.

Conditions that preserve disclosure at first image exposure and during reuse

Rendering diagram…

What was confirmed

Verification results

The assessment recorded the three required disclosure elements and the constraint to communicate them no later than the first image exposure, making the conditions testable in the downstream UI.

The CEO confirmed that the intended profile images were AI-generated and conditionally accepted the existing disclosure direction. No copy change was requested.

The mobile order that placed images before the common disclosure and the mismatch between nine displayed profiles and ten inventoried assets remained conditions to resolve before publication.

Per-image provenance, rights and permitted use, real-person similarity, publication territories and readers, operator, contact and policy surfaces, and every display context remained unverified. Final legal approval and publication readiness were not established.

At the cutoff, the legal-risk assessment had been applied to its target. Implementation of the constraints in the site, qualified counsel judgment where required, and production publication were not verified by this Activity.

Basis for completion

The assessment-writing scope was complete when confirmed facts, prohibited inferences, the three bilingual disclosure elements, first-exposure, locale, and accessibility constraints, and unresolved image, territory, and operator information were recorded separately in one assessment, and that result was applied to the target.