'My Face Was Used Without My Knowledge': Berliners Speak Out on Duplicate Image Replacement

A graphic designer living near Hermannplatz in Neukölln first noticed it in March. A portrait she had uploaded to a freelance portfolio site had turned up on at least four separate commercial websites — a Frankfurt recruitment agency, two Berlin-based tech startups, and a lifestyle blog — without her permission. The image had been slightly altered each time, cropped or colour-corrected, the kind of cosmetic change designed to fool a reverse-image search. She is one of dozens of Berlin residents who have come forward in recent weeks to describe the experience of finding their photographs duplicated, redistributed and, in some cases, used as placeholders in AI-generated content pipelines.

The practice, sometimes called duplicate image replacement or image scraping with substitution, sits in a legal grey zone across the EU. It has sharpened as a local controversy this summer partly because of the density of Berlin's creative and tech sectors — both the people whose images get taken and the companies doing the taking tend to operate within a few postal codes of each other. For Turkish-German community organisations in Wedding and Kreuzberg, where residents say their images have appeared in stock-photo style compilations without consent, the issue carries an additional sting: it often involves faces from minority communities being used to give websites a superficial appearance of diversity.

What Residents Are Experiencing

Community members describe a consistent pattern. A photograph — usually pulled from a public-facing social media account or a professional directory — reappears on a third-party site in a context the subject never agreed to. In some documented cases shared with members of the Berlin Digital Rights Initiative, the same face appears across multiple sites under different names or nationalities. One member of a Kreuzberg-based cultural association said her headshot from a 2024 neighbourhood festival programme was later found on a Munich-based real estate portal, attached to a fictional testimonial. She has since filed a complaint with the Berliner Beauftragte für Datenschutz und Informationsfreiheit, the city's data protection authority, located on Friedrichstraße.

The Berliner Beauftragte für Datenschutz und Informationsfreiheit handled more than 4,200 complaints in 2024, according to its published annual report, a figure that includes a growing category of image-related data misuse. Across Germany, the Bundesnetzagentur and federal data protection bodies have flagged AI training datasets as a priority enforcement area for 2026, following the European AI Act's formal application date of August 2, 2026. That deadline is giving affected residents a concrete timeline to push for action.

At Betahaus on Prinzessinnenstraße in Kreuzberg — a co-working space popular with the city's freelance design community — the issue has become a recurring topic. Members there have begun circulating a shared document listing known image-scraping domains, a grassroots response in the absence of any centralised registry. The initiative is informal, but it reflects a real appetite for collective action in a community that feels exposed.

What Comes Next

For those already affected, Berlin-based digital rights lawyers point to Article 17 of the GDPR — the right to erasure — as the most direct legal lever available, though enforcement against non-EU-hosted sites remains complicated. The Verbraucherzentrale Berlin, the city's main consumer advice centre on Hardenbergplatz, offers free initial consultations on data rights and has expanded its digital advice slots since January 2026 to meet rising demand.

The SPD-led Senate has not yet issued specific guidance on image scraping as a standalone issue, though the city's broader AI strategy document, published in late 2025, commits to aligning municipal procurement with the EU AI Act's transparency obligations by the end of 2026. Affected residents say that timeline feels abstract against the daily reality of finding their faces on websites they never visited.

For the Neukölln designer, the practical advice is blunt: watermark everything, set profiles to private, and document every instance with screenshots and timestamps before filing any complaint. She has already sent three takedown requests. Two have been ignored. The third site went offline — though she cannot say whether that had anything to do with her.