Checking with FR is much more complicated operation than checking creation date or exact match for a file. Less complicated operations are always done first
And what if you scanned an old picture? The date is put into the JPGE file generated by the scanner....
You can take a 2 years old paper picture and scann it today...the JPEG file created has todays date....and this is legal as far as their instructions that let you to scan pictures...
FR is facial recognition.
I do not know how deep they check that 6 month requirement. It is definitely possible to figure out whether both images come from the same original. But it might take 24 hours per each year. And might require some manual involvement.
Also take into account that the date put into the JPEG files when using a digital camera is determined by the date setup in the camera itself;
Who doesn't have a digital camera or video recorder which date is not update? Mine is set to Jan 1 2004 because I forgot to update it after reseting the batteries...
My point is that not all the photographers have their cameras updated to reflect the updated date....so if this was crucial I think the DV RULES should clearly askf for this to make sure that all the applicants are asking to their photographers to have their cameras updated...
Date in the file does not mean much on it's own, because it could easily be corrected by software.