Not on that fact alone. Section 201 distinguishes copyright in a collective work from copyright in individual contributions; section 204 sets a writing-and-signature rule for transfers of copyright ownership, with its stated exception. Actual licences and employment facts still need review. §201; §204.
Use an archive-cohort table: employee work, freelancers, syndication, commissioned photographs, acquired collections and third-party embeds. Record the contract version, holder of each right, allowed uses, geographic limits and unresolved items. Keep unclear cohorts out of the initial sample until the appropriate reviewer approves them. This is a practical evidence workflow, not a conclusion that every old contract needs a new signature.