Sending an employee--or a computer program doing the same job--around to document the existence of a ton of photos and then offer a service where people come to

Sending an employee--or a computer program doing the same job--around to document the existence of a ton of photos and then offer a service where people come to my office and we search our records and memory to figure out where those photos are to send them to see the photos is not copyright infringement. It might be some kind of terms of service violation--if you believe those actually have legal merit, as they often don't--or (much more likely) a violation of someone's right to privacy (as faces are personally identifiable information); but, if you aren't retaining copies of the photos (and most of these companies don't even internally as they simply don't need to) and you aren't redistributing the photos (which they aren't: they just tell you what they learned and how to find the originals) and you aren't producing new photos similar to the old photos or modifying the photos in any way (which would undermine the entire point) and you aren't even slightly in the same market as the original photo (which would be an absurd argument to try to make), then this clearly has nothing at all to do with copyright.