Beneficiary Depiction Guardrails

1. Why depiction rules matter here

LWD serves people in the last months of their lives. That fact places every content decision in a moral context that most charities do not face daily. Three specific risks are elevated:

1. Diminished capacity risk. Terminal illness reduces cognitive capacity in many patients over the final months. Consent given today may not be defensible in retrospect if capacity was already compromised at the moment of signing. Every consent process must include a capacity-check step, not a blanket “patient signed the form” defence.
2. Family standing risk. Once the beneficiary dies, the family becomes the party with standing to object to continued use of a story — and their consent was not sought at the time. Every consent process therefore requires family concurrence at the time, and a family-nominated point of contact for post-death continuation decisions.
3. Extraction risk. Charities have historically extracted stories from beneficiaries to serve fundraising campaigns. The transaction is not always fair to the beneficiary. Every story LWD publishes must pass the test: would the beneficiary, given full information about how this story will be used, still choose to give it? If we can't answer “yes” confidently, we don't publish.

2. Six operating principles

3. The consent framework

3.1 The seven-step consent process

3.2 What the consent form contains (v0.1 outline)

The Consent Form (a separate template — drafted by Deen in Sprint 0's governance pack review) must include, at minimum:

• Beneficiary's full name; nominated family contact's name and relationship.
• The specific story text or image being consented to (not general “LWD may use my story” language — specific asset consent only).
• The specific platforms and audiences for which consent is given (e.g. “LWD website, LWD social channels, LWD annual report, LWD grant applications — but not third-party media or advertising campaigns unless separately consented”).
• The retention period (default: 5 years post-publication, then reviewed with family; longer only with explicit family agreement).
• The unconditional withdrawal clause in plain language.
• The family concurrence clause and family contact's signature.
• The capacity confirmation (attached).
• The Privacy Act 1988 (APPs 1–13) notice about how the beneficiary's personal information will be collected, held, used, and disclosed.

4. Absolute stop-signs (never published)

• STOP No named beneficiary story published without all 7 consent steps completed and documented.
• STOP No photograph or video of a beneficiary in a hospital bed, hospice bed, or clinical setting — even with consent. These images invite emotional manipulation of donors and undermine beneficiary dignity.
• STOP No named beneficiary story where family concurrence has not been obtained, even where beneficiary insists. LWD's exposure is to the family post-death.
• STOP No image or name of a deceased Aboriginal or Torres Strait Islander beneficiary without explicit family, kin, and community consent, per First Nations cultural protocols. Where any of these three are unclear or contested, we do not publish.
• STOP No use of terminal-diagnosis language or death imagery to prompt urgency in donors. (“Give now, before it's too late”-style copy is prohibited — it exploits the illness itself as the fundraising lever.)
• STOP No before/after framings (“before LWD helped, they were desperate; after, they were at peace”) — this pattern reduces the beneficiary to a transformation product and misrepresents the reality that debt-negotiation outcomes are variable.
• STOP No advertising placement of a beneficiary story on gambling, alcohol, funeral-industry, or predatory-lender-adjacent pages — whether via automated ad networks or otherwise. Media buys must include contextual exclusion lists.
• STOP No beneficiary story used in any political-campaign context, whether by LWD or by third parties LWD has authorised to use content.
• STOP No AI-generated depiction of a real beneficiary, ever. AI-generated depictions of fictional or composite beneficiaries only with explicit “illustration” labelling.

5. What is permitted — with process

• PERMIT Named written story, first person or third person, with all 7 consent steps and both editorial and compliance desk sign-off.
• PERMIT Photograph of beneficiary in a non-clinical setting (their home, garden, community) with all 7 consent steps plus a specific image-consent addendum listing the photograph.
• PERMIT Short-form video of beneficiary (their words, their environment) with 7 steps plus image-consent addendum. Video subject to Personality Rights standards analogous to Sprint 0.15 (Laurence's PRA) — a separate simplified beneficiary PRA is filed.
• PERMIT Anonymous or pseudonymised named story (e.g. “Robert, 68, Perth” with details generalised) with only steps 3–7 of consent required if the beneficiary explicitly requests pseudonymisation.
• PERMIT Post-outcome family testimonial (a family member speaks about the process after the beneficiary has died) with a separate family-consent-only process (no beneficiary consent needed post-death, but family capacity + cooling-off apply).
• PERMIT Composite story clearly labelled — see §6 below.
• PERMIT Quotation from a beneficiary letter/email (short, no identifiers) with consent-in-principle from beneficiary and family.

6. Composite stories — use and labelling

Because the real-consent pipeline is deliberately slow, composite stories are the default vehicle for illustrating LWD's work through Sprints 2–5 (the first 12 weeks of room content). A composite story is a factually grounded narrative that draws elements from multiple real cases but does not depict a single identifiable person.

6.1 Rules for composite stories

1. Every composite story must be explicitly labelled in the copy. Standard footer language: “Composite story — drawn from Laurence Hugo's 30 years of practice; identifying details changed. Every fact type (debt levels, creditor responses, prognosis timelines) is drawn from real cases.”
2. Composite characters cannot be named with real-sounding first-and-last names that could be mistaken for a real beneficiary. Use first-name-only conventions (e.g. “Robert”, “Anh”) or non-name descriptors (“a 71-year-old pensioner in regional Victoria”).
3. Composite characters cannot be photographed. Use typography-only quotation cards, illustration where necessary, or generic landscape/interior photography without identifiable people.
4. Numbers in composite stories must be true. Debt totals, creditor counts, outcome types — drawn from real cases. Only identifying details (name, town, exact age, exact illness) may be altered.
5. Composite stories must not aggregate to imply typicality. Never write “most of our beneficiaries…” from composites — that requires real dataset evidence.

6.2 Migration from composites to real stories

The intent is that by Sprint 6 (Video Pillar A production, week 13–14), 2–4 real beneficiary stories are through the full consent pipeline and can begin to displace composites. By Sprint 9 (launch), the majority of on-site stories are real; composites are retained only where a specific narrative type has not yet had a real consenting participant.

7. Photography & video protocol

7.1 Setting

• Beneficiary's home, garden, or community — never clinical.
• Natural light. No flash. No dressing the room.
• The beneficiary chooses what they wear.
• Family members photographed only with their own separately-signed consent.

7.2 On the day

• The beneficiary has an unconditional right to stop the shoot at any moment. This is stated verbally at the start of the shoot, not just written in the consent form.
• A support person of the beneficiary's choice attends.
• The photographer/videographer is briefed on the Charter's visual identity direction (Charter §4.3) and on this Guardrails document.
• Every image or clip is reviewed with the beneficiary before departure. Beneficiary can delete any frame or clip on the spot.

7.3 Post-production

• The beneficiary is shown the intended selects before finalisation. Beneficiary can veto any image or clip.
• No slow-motion cutaways to distressed facial expressions. No music that emotionally leads the audience.
• No captions that infer emotion the beneficiary did not state (“fighting for peace in her final days”-style).

7.4 Beneficiary Personality Rights (simplified)

Sprint 0.15 covers Laurence's Personality Rights Assignment. A simplified equivalent applies to beneficiaries who appear on camera: a one-page “Beneficiary Image & Voice Use” agreement, drafted by Deen alongside 0.15, executed at the end of the shoot day (before departure), covering the specific media captured that day only.

8. Social-media specifics

9. Post-death representation

When a beneficiary who consented dies, LWD's obligations continue. Specifically:

1. Existing published content remains published subject to the retention period on the consent form — unless family withdraws (see §12 below).
2. No new use of the beneficiary's likeness or story is created post-death without separate family consent — new grant applications, new videos, new annual reports referring to the beneficiary must obtain fresh family concurrence for each new use.
3. The family-contact relationship is maintained. LWD's staff make contact with the nominated family contact at 12 months post-death to review continued consent. If contact declines or does not respond after two attempts (30 days apart), retained content stays live for the remainder of the retention period, but no new use is authorised.
4. Stewardship of the family after publication. If a beneficiary's story raises donations, the family is offered (not required) to be told the impact of their contribution. Some families want to know; some do not. LWD asks, does not assume.
5. Death notifications from third parties. LWD monitors known beneficiary status and ensures no live campaign refers to a beneficiary as though still living. On notification of death, a 48-hour review of all live content mentioning that beneficiary is triggered.

10. First Nations audiences

In addition to the general guardrails, the following apply where a beneficiary or family identifies as Aboriginal or Torres Strait Islander:

• No images or names of deceased persons published without explicit family and community consent. If community consultation is not possible (e.g. the person's community is unknown or the family requests LWD not to consult), the content is not published in identifiable form.
• Community consultation as a step in the consent pipeline. Between step 5 (family concurrence) and step 7 (signature), a community consultation step is added. The nature of that consultation is determined by the beneficiary's community (elders, land council, appropriate representative).
• Language conventions. Sensitivity warnings are placed on pages that may reference deceased First Nations persons, per the widely-adopted convention.
• No use of Country imagery or ceremony imagery as backdrop or context without specific permission from the community whose Country or ceremony it is.
• The right of the community to speak for the person, in some circumstances, is recognised. LWD does not centre its own editorial preferences over community protocol.

11. Minors & families

Children of terminally ill beneficiaries may appear in family stories, but under strict conditions:

• Under-18 identification prohibited. No first-name-and-photo combinations that identify a minor. Backs-of-heads photography or pseudonymous referencing (“his teenage son”) only.
• Both parents / all guardians must consent to any depiction. Where custody is disputed, no publication until legal position is clear.
• Children under 12 not asked to consent themselves — parental consent only. Children 12+ asked to assent (age-appropriate explanation of what's happening) as a supplementary step, though legal authority remains with the parent.
• Right of withdrawal on 18th birthday. Any content published with parental consent while the person was a minor: at 18, the person is proactively contacted and asked whether they want the content to remain live. Silence is treated as withdrawal after two contact attempts.

12. Withdrawal & takedown protocol

12.1 The 5-day rule

On receipt of a withdrawal request (from beneficiary, family contact, or minor now adult), LWD removes the content from every platform under its control within 5 business days. This includes:

• LWD website (removed within 24 hours; the 5 days are for CDN/cache clearance and social platforms)
• All LWD-controlled social channels (posts deleted; if reshared by third parties, LWD makes reasonable takedown requests)
• YouTube (video unlisted immediately, deleted within 5 days)
• Any live-hosted PDFs (annual reports, grant applications) — the specific story is redacted from current-year materials; historic PDFs are annotated with a redaction notice
• Any external partner materials LWD provided content to — formal takedown request within 24 hours

12.2 What LWD cannot remove

Content copied by third parties, archived by the Wayback Machine, or reshared beyond LWD's reasonable control cannot be forced back. This is stated on the consent form so it is not a surprise to the beneficiary/family.

12.3 Confirmation to the requestor

Within 7 business days of a withdrawal request, the requestor receives a written confirmation from LWD of what was removed, when, and any residual exposure LWD cannot control. Filed in the consent register.

13. The consent register

LWD maintains a Consent Register — an internal record of every beneficiary story published, the consent trail behind it, and its current status. Sprint 0's governance pack includes a template for this register. Fields:

Register is Board-visible; individual entries are staff-restricted; personal information is stored in accordance with the LWD Privacy Policy (see privacy-policy.html) and Australian Privacy Principles 1–13.

14. Governance & version control

14.1 Adoption

This Guardrails document is a Board-adopted policy of Life Without Debt Ltd once the company is incorporated. Sequence:

1. v0.1 — Draft (this version). Circulated to Deen (Legal), Carla (CFO), Laurence, Lisa.
2. v0.2 — Post Sprint 0.16 cultural-protocol consultation. §10 rewritten.
3. v0.3 — Post Deen's Sprint 0 bundle review. Consent form template drafted separately by Deen; cross-referenced here.
4. v1.0 — Board resolution to adopt at first Board meeting post-ACN issue.

14.2 Exception authority

None of the §4 stop-signs may be waived below Board level. Any request comes with Deen's Legal-Advisor opinion. Non-stop-sign judgment calls (e.g. whether a composite story is sufficiently anonymised) sit with the Editorial + Compliance desks per Charter §5.1.

14.3 Related documents

• Sprint 0.1 — Brand & Editorial Charter (§3.4, §5)
• Sprint 0.6 — Compliance Guardrails One-Pager (Compliance desk process)
• Sprint 0.15 — Personality Rights Assignment (Laurence's PRA; template for beneficiary simplified PRA)
• Sprint 0.16 — Cultural-protocol consultation record (§10 depends on it)
• Privacy Policy — consent register data-handling
• Marketing Mix Backlog v1.0 — every beneficiary-story asset in the backlog complies with this document

14.4 Version history

v0.1 (this version) — 2026-05-17. Initial draft under delegated authority. Awaits Deen (Legal Advisor) red-line. §10 First Nations section is placeholder pending Sprint 0.16 consultation.