I wholeheartedly agree: there is an audit question here too. The contents of the database are by far the most dangerous part of this equation, malicious or not, targeted or not. I don't like the privacy implications about this, nor the potential for abuse. I would love to see some kind of way to audit the database, or ensure that it's only used "for good." I just don't know what that system is, and I know that PhotoDNA is already in use on other cloud providers.
Matthew Green's ongoing analysis [0] is really worth keeping an eye on. For example, there's a good question: can you just scan against a different database for different people? These are the right questions given what we have right now.
[0]: https://twitter.com/matthew_d_green/status/14233782854682091...