Until Facebook states they won't store/analyze faces they can't recognize then everyone who has never had an account or deleted their account are at a disadvantage.

I've always wondered if COPPA could be used against Facebook with regard to this. Theoretical situation: I'm a parent and I find an image of my child (under 13 years of age). Facebook never notified me of they were storing my child's image. Facebook would argue they didn't know. But Facebook already scanned the image and likely guessed the child's age - and knew they were under 13. In that situation Facebook should be required to remove the image based on the fact they cannot notify the guardian. I realize this would have severe repercussions to their operational model, but that's also the point. Or... If I find an image Facebook didn't notify me about - then I'll take that $42,000 per image.

Seems fair.