Rolf the Ruf wrote:
Well, this is where it gets a bit tricky. You see, this client is a government agency providing public services -- transit to be exact. Most, if not all of these images will be used in marketing campaigns that are aimed at public education. How to ride transit, New bus lanes, Changes in services, Project information for a public meeting, etc. I don't know if this qualifies as a commercial usage or not. I tend to err on the side of caution in such cases. Just not sure.
If I was a recognizable face, whether in a crowd or not, and I saw my face on the side of a bus or in a commercial whatever the topic, I'd better have been paid a modeling fee and signed a modeling release. If not I personally would be talking to my lawyer. On the other hand you might get away with it with many people who don't know any better, or are just pleased to see themselves in a picture. But safest to get model release's with a token payment, or use a professional model building a crowd of unrecognizable faces around them as needed. Why take a chance?