Unfocussed Mike said
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The main problem I suspect is that they have found a niche that the laws protecting novice models specifically will not expand to prohibit.
It is after all on the surface somewhat equivalent to you or me being paid by a model or actor to produce some headshots, which is legitimate commerce (actors routinely expect to pay).
So it's much more Trading Standards turf, and there the claims are more nebulous and more complex.
Actor and model agencies, combined, are also regulated, and fees are allowed. I suspect that those who act and model are less entry-level, although Miss Worthington's ambitions might be.
Long ago, and far away, my father had business making actor head shots, portraits, cards. He seems to have been good at that. I enjoy doing that sort of shoot, but I can't prove the ability is heritable ;(
That, for money, is general photographic business, without promises, I think, and the general expectation would be that someone coming along for a shoot has actually acted in something without becoming a salad*.
Trading Standards, yes. Geography is a problem for them, I think they still trail behind the Internet. Their landlords, web hosts, web designer, and photographers are no doubt behaving perfectly lawfully, but I think the modern fashion for taking no position on customers' nature and activity may have swung too far.
* a Ham salad, perhaps