Intimate images appearing on foreign-language or internationally-hosted websites create jurisdictional complexity. The framework that applies depends on: (1) whether the foreign site is US-accessible; (2) whether the site is hosted in a country with its own NCII laws; and (3) whether the site is operated by a company subject to GDPR or other international privacy frameworks.

Many internationally-hosted adult and general content sites acknowledge the presence of US-accessible users, which creates exposure. Sites hosted in EU countries are subject to GDPR. Sites hosted in Australia may have specific compliance requirements. UK-hosted sites are subject to the Online Safety Act.

ScanErase identifies the hosting location and applicable legal framework for each site and provides relevant information automatically. For sites with no applicable international framework, users may need to consult an attorney with international practice.

What to do right now

  1. Run a biometric scan to identify all international hosting locationsScanErase's scan covers international platforms and identifies the applicable framework for each.
  2. Use findings to assess next steps based on applicable frameworksScanErase provides insights based on US-accessible sites, GDPR, and other jurisdictions.
  3. Contact country-specific regulatory bodies for non-compliant sitesEU: national data protection authorities. Australia: eSafety Commissioner. UK: ICO.
  4. Request Google de-indexing for all identified URLsGoogle de-indexes intimate image links globally, reducing practical access to foreign-hosted content.
  5. Consult an international attorney for sites with no applicable frameworkSome foreign sites may not have an applicable regulatory framework. Direct legal action through an attorney with international practice may be necessary.