'Our photos are everywhere and nobody asked us': Zürich residents speak out on duplicate image replacement

A graphic designer living near Langstrasse found her headshot on three different websites last spring — none of which she had worked with. A doctoral researcher at ETH Zurich discovered that a photograph taken at a public seminar on Rämistrasse had been cropped, recoloured, and republished by a commercial firm in Frankfurt. Neither received notice. Neither was asked.

The issue of duplicate image replacement — the practice of reusing, overwriting, or substituting photographs and visual assets without the original subject's knowledge — has simmered as a secondary concern in digital rights discussions for years. It is breaking into sharper focus in Zürich now, partly because the city's dense concentration of pharmaceutical companies, financial institutions, and internationally ranked universities generates a high volume of professional imagery that circulates far beyond its original context.

A city with a lot of faces in circulation

Switzerland's federal data protection law, the revised nDSG, came into force on 1 September 2023, strengthening individual rights over personal data including images. But residents and advocates say enforcement remains patchy, and that the specific problem of image duplication and replacement — where an original photo is swapped out on a platform while retaining its metadata or SEO footprint — occupies a grey zone the legislation does not cleanly address.

Organisations including Digitale Gesellschaft, the Zürich-based digital rights association headquartered in the city, have flagged the gap in their published guidance on nDSG compliance. The association notes that image rights cases typically require individuals to identify the infringing party themselves before any formal complaint process can begin — a significant burden for private citizens.

In the Wipkingen neighbourhood, a community health worker described noticing that a photograph taken at a Zürich Stadtspital event had been used on a third-party wellness platform. The image had been resized and re-uploaded, effectively creating a duplicate that displaced the original in search results. She contacted the platform twice through its online form. No response came within the six weeks she tracked.

At the Zentralbibliothek Zürich on Zähringerplatz, librarians who help patrons navigate digital literacy questions say requests for guidance on image rights have grown noticeably since 2024. Staff there describe a pattern: people arrive confused about whether a photograph of themselves counts as personal data, whether a Creative Commons licence covers commercial re-substitution, and where exactly to file a complaint in Switzerland when the platform hosting the duplicate is based outside the country.

What residents are asking for

The practical ask from community members is not abstract. Several people who described their experiences pointed to the same basic gap: there is no simple, publicly accessible registry or reporting pathway in Zürich — or at the federal level — where someone can flag a duplicate image replacement and expect a traceable response within a defined timeframe.

The Federal Data Protection and Information Commissioner, the FDPIC, based in Bern, handles complaints but does not operate a rapid-response channel for image-specific cases. Response timelines under the nDSG process can extend to several months for preliminary assessments.

For now, residents are largely navigating the problem through a patchwork of tools: reverse image searches, direct platform takedown requests under each site's own policies, and occasional outreach to cantonal consumer protection offices. The Zürich-based consumer organisation Konsumentenschutz has published general guidance on image rights, though its resources focus primarily on product photography disputes rather than personal image duplication.

ETH Zurich's Chair of Information Security, which has published research on digital identity and data integrity, has not yet produced public-facing guidance specifically on image duplication as a privacy harm — though researchers there are understood to be active in adjacent areas of digital rights scholarship.

For anyone in Zürich who believes their image has been duplicated or substituted without consent, the most direct current step is a written complaint to the FDPIC, which under nDSG Article 49 can initiate an investigation. Legal clinics at the Universität Zürich on Rämistrasse 74 also offer free initial consultations on data protection matters, typically on Wednesday afternoons during term time. The wait for an appointment currently runs to about three weeks.