Came across this blurb in the DOL's guidance found at https://www.labor.ny.gov/formsdocs/ui/ia318.14.pdf 4. Professional models who model for, or who consent in writing to transfer use of their name or likeness for advertising or trade to, a person or entity that controls assignments, hours of work or performance location and that compensates them, in return for a waiver of their privacy rights, unless they perform services under a written contract that states the model is an employee of another covered employer. We have an individual that literally comes in once a week as a fit model. I think the above is "n/a", but figured someone in the Proformative knowledge community may have run into this. The images are not used for adverts and face is not displayed 99% of the time. Clothing is displayed on the individual's physical frame.