Responsible AI, Disclosure & ComplianceCopyright, likeness and deepfakes · Lesson 4 of 11

Likeness, voice rights and deepfakes

Article · 15 min · 9 min lecture

Video lecture

Likeness, voice rights and deepfakes

13 chapters · about 9 min · full transcript

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Chapter 1 of 13

Likeness, voice and deepfakes

  • What makes a deepfake harmful
  • The legal strands
  • No-go zones
  • Consent that holds up
  • Protecting yourself

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Chapters

People own their identity

A person's face, voice, name and persona are central to their identity and, for public figures and creators, their livelihood. AI makes it easy to replicate all of these. Using them without permission can be unlawful, unethical and deeply harmful.

What counts as a deepfake

A deepfake is synthetic or manipulated media that realistically depicts a real person saying or doing something they did not. Not all synthetic media is a deepfake in the harmful sense. Your own consented avatar is synthetic, but used transparently it is not deceptive. The harm comes from realism combined with lack of consent or deception.

Laws vary widely and are changing fast, but several strands apply in many markets:

  • Personality, publicity and image rights: many jurisdictions protect against unauthorized commercial use of a person's name, image or likeness, and some explicitly cover voice. Several US states have enacted laws on digital replicas and voice. Some European countries have proposed or adopted specific protections against deepfakes of a person's likeness.
  • Passing off, false endorsement and advertising law: implying someone endorses a product when they do not is misleading under consumer-protection and advertising rules (for example FTC rules in the US and ASA/CAP rules in the UK).
  • Defamation: synthetic content that damages someone's reputation can be defamatory.
  • Privacy and data protection: images and voice recordings are personal data; biometric processing attracts stricter rules under GDPR-style laws, including in the UAE and KSA.
  • Cybercrime and criminal law: impersonation, fraud and non-consensual intimate imagery are criminal offenses in many countries, including under cybercrime laws in Pakistan, the UAE and KSA, and US federal law now specifically addresses non-consensual intimate deepfakes.
  • AI-specific transparency rules: Article 50(4) of the EU AI Act requires deployers to disclose deepfakes from 2 August 2026, and Saudi Arabia's SDAIA deepfakes guidelines stress consent, labeling and watermarking.
  • Intimate deepfakes: in the US, the TAKE IT DOWN Act (2025) criminalizes publishing non-consensual intimate images, including AI-generated ones, and requires covered platforms to remove them promptly after a valid request. Many other countries have similar offenses.

Clear no-go zones

Never create or share:

  • Synthetic media of a real person in sexual or intimate contexts without explicit consent. This is illegal in many places and deeply harmful.
  • Fake endorsements by celebrities, creators, experts or customers.
  • Synthetic political content depicting real candidates or officials saying or doing things they did not.
  • Content impersonating a real person to deceive, such as scam calls or fake announcements.
  • Parody or satire that a reasonable viewer could mistake for real, especially around politics, religion or public safety.

When using a real person's likeness is legitimate

With informed, written consent covering:

  • The specific uses (channels, campaigns, formats, languages).
  • Duration and territory.
  • Approval rights over scripts and outputs.
  • Payment terms.
  • Restrictions (no political, adult or unrelated endorsements).
  • Revocation and deletion of models and assets.
  • For employees: what happens when they leave.

And with transparent disclosure to audiences where the content is realistic.

Your own identity as a creator

  • Protect your accounts (two-factor authentication, limited team access) because voice and face models are valuable targets.
  • Read brand contracts carefully: watch for clauses granting perpetual or broad rights to create AI replicas of you.
  • Consider registering your name or brand as a trademark if relevant.
  • Tell your audience how to identify genuine content and what you never do.
  • Monitor for impersonation and report quickly.

Worked example

A Saudi fashion brand wants to "bring back" a popular creator they worked with last year using an AI avatar built from old campaign footage, without contacting her. The agency advises against it: the original contract did not cover AI replicas; using her likeness would imply a current endorsement; and it could breach her image rights, data protection law and advertising rules. Instead they approach the creator for a new deal that includes a clearly scoped, time-limited avatar license with script approval and fair payment. She agrees, and the campaign carries clear disclosure.

Use this as the basis for any AI avatar, voice clone or digital double. Get it reviewed by a lawyer in the relevant market, and keep it with the project files.

AI LIKENESS AND VOICE CONSENT (summary sheet, attach to full contract)

Person:            [full name]            Role: [creator / employee / actor]
Assets captured:   [face video, voice samples, photos], captured on [date]
Model / tool:      [vendor and product], account owner: [company]
Permitted uses:    [channels], [campaigns], [languages], [formats]
Territory:         [countries]            Term: [start] to [end]
Script approval:   Person approves every script before rendering: [yes/no]
Prohibited uses:   political, religious, adult, financial advice, any
                   endorsement outside this agreement, any use after term
Disclosure:        Content will be labeled as AI-generated voice/likeness
Payment:           [fee] plus [per-use fee or royalty], paid [schedule]
Revocation:        Person may withdraw consent with [x] days' notice
Deletion:          On expiry or revocation, voice/face models and source
                   files deleted within [x] days; written confirmation sent
Employees:         Consent is optional, not a condition of employment;
                   models deleted when employment ends unless re-agreed
Signed:            [person]   [company]   Date: [date]

And a quick decision check before you create or publish synthetic media of a real person:

1. Is the person real and identifiable (face, voice, name, persona)?      yes -> go on
2. Do we hold written consent covering THIS use, channel and term?        no  -> stop
3. Could anyone reasonably think the person actually said or did this?    yes -> label it
4. Is it political, intimate, financial or health-related?                yes -> do not proceed without legal review
5. Is the consent record and label evidence saved in the project folder?  no  -> fix before publishing

Protecting your own voice and face

  • Keep raw voice and face recordings in a restricted folder; they are training data for anyone who gets them.
  • When a brand asks for "perpetual, worldwide rights to your likeness in all media now known or later developed", push back: limit term, territory, media and AI use, and add approval and deletion rights.
  • Register with your platform's impersonation tools and set up alerts for your name.

Pitfalls

  • "It's just a joke" deepfakes of friends, colleagues or public figures that spread beyond the intended audience.
  • Assuming old contracts cover AI uses they never mentioned.
  • Using "AI-generated" labels as a license to depict real people however you like.

Key takeaways

  • Deepfakes are realistic synthetic depictions of real people without consent or with deception.
  • Publicity rights, advertising law, defamation, data protection and criminal law can all apply.
  • Never create fake endorsements, intimate deepfakes, deceptive political content or impersonations.
  • Legitimate use needs specific, written consent and transparent disclosure; creators should protect their own likeness.

Check your understanding

Quick questions to lock in the lesson. They don’t count towards your certificate.

  1. A brand wants to reuse a creator's face via AI from an old campaign that never mentioned AI. What is correct?
  2. What makes synthetic media a harmful deepfake?

Put it into practice

Review one brand or creator contract template and add clauses covering AI replicas of likeness and voice: scope, duration, approval, payment and deletion.

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