I agree with @Plotinus 's logic, but corporate policies don’t always follow common logic.
So - I just gave the ACT a call and asked if a student who received a copy of their test (TIR can be ordered for $20) and consequently ordered a copy of their essay (another $22) is allowed to post that essay on the Internet. The answer was yes. Yess!
The CB, with its many shortcomings and transgressions, does this part right: not just three times a year, but after each test administration writing prompts are posted on their website, and later all the students are able to see their essays scans as soon as writing scores become available.
The ACT actually makes essay images available (at no charge) to schools and colleges through their “ACT Essay View” service for all the test events:
https://www.act.org/essayview/college.html
One might ask…