From a legal perspective, I'm a professional, obviously no details, the law is VERY clear, you have to disclose with the intention of causing distress. If there is no evidence of disclosure with the intent to cause distress, quite simply there is no case to answer. Additionally there is an additional protection in paragraph 8:-
(8)A person charged with an offence under this section is not to be taken to have disclosed a photograph or film with the intention of causing distress merely because that was a natural and probable consequence of the disclosure.
This is not an area they can really close down too much generally in law because it will rapidly start moving into areas of free speech and expression and also copyright. There is already protection for if the person in the photos received 'reward', so that solidly protects anybody paying.
---
Disclosing private sexual photographs and films with intent to cause distress
(1)It is an offence for a person to disclose a private sexual photograph or film if the disclosure is made—
(a)without the consent of an individual who appears in the photograph or film, and
(b)with the intention of causing that individual distress.
-----
(8)A person charged with an offence under this section is not to be taken to have disclosed a photograph or film with the intention of causing distress merely because that was a natural and probable consequence of the disclosure.
http://www.legislation.gov.uk/ukpga/...ion/33/enacted