Sex workers, Scarlet Alliance and state and territory sex worker organisations are aware that Scarlet Blue, an Australian sex worker advertising site, has recently decided to engaged a third party verification platform (Sum and Substance Ltd) that requires sex workers to submit photo identification in the form of a passport in order to pay for advertising via credit or debit card. Sex workers who have built a clientele via paid advertisements on Scarlet Blue now have either lost that income or agreed to have their passport collected by Sum and Substance Ltd, or are forced to pay via Bitcoin.
Sex workers making contact with Scarlet Alliance and local sex worker organisations over these changes are expressing dismay, anger and frustration, and expecting financial strain if the new rules are to stay.
This move by Scarlet Blue is a continuation of generalised discrimination by advertising platforms and payment processors against sex workers and sex industry businesses.
Scarlet Alliance is vehement that the collection of sex worker photo identification should not be required in order to post an ad, and to require sex workers to submit passports is a serious violation of privacy. Repeated data breaches around the world have demonstrated the fragility of even the most “robust” IT infrastructure. The practice is unethical and cannot be defended.
Scarlet Blue is based in Cyprus and the passport data is being collected and processed by Sum and Substance Ltd in the UK.
WHAT ARE MY RIGHTS AND WHAT CAN I DO?
If you have provided photo identification to advertise on Scarlet Blue, you can request to have it deleted by writing them a letter of complaint. For assistance please contact us here.
Scarlet Blue are required to respond to you within 5 days to acknowledge the correspondence. Their Privacy Policy states they will try to resolve your complaint within 30 days, and if that time frame is “not reasonably possible”, they are obliged to contact you within that time to let you know how long it will take.
If you are not satisfied with their decision, you can refer your complaint to the Office of the Australian Information Commissioner by phone on 1300 363 992 or online at www.oaic.gov.au
You can also contact Sum and Substance directly.
From Sum and Substance’s Privacy Notice (Sumsub Service):
Please note that if you, as a User [in this case, a Scarlet Blue advertiser], would like to make a request to delete the personal data that you have provided for the purpose of a particular Client [in this case, Scarlet Blue], please make that request directly to the Client that controls your verification process. For more information about how to do this, please see Provision 10.
In general, personal data, including biometric data, will be retained and stored by Sumsub and will be permanently destroyed based on the Client’s instructions when the Client’s initial purpose and/or retention period prescribed by applicable law expires.
To ask Sumsub to execute the rights mentioned above or redirect the request to the Client, you should send a free-form email to privacy@sumsub.com or use this form.
Correction (20 June 2023): This statement has been updated to reflect that photo ID is only required for payment made via credit or debit card, and that payment via Bitcoin does not require photo ID.