While sharing an image without a person's consent may not be unlawful, the content of the photograph and the circumstances in which it was taken would determine whether the publication of the image would be classified as an offence under the Indecent Publications Act, Ms Aitken said.
"We appreciate that for the women involved this is a very upsetting experience."
This afternoon, Otago's vice-chancellor said the incident had "sullied" the 145 year-old institution's reputation.
Wellington Rape Crisis yesterday criticised the university for not taking "proactive steps" to protect students from sexual abuse.
The university today warned any students found breaching its ethical behaviour policy could face possible suspension, fines or expulsion.
Otago Vice-Chancellor Professor Harlene Hayne said a minority of students had cast aspersions on their peers.
"While it appears that a small number of this Facebook group were actively engaged in posting private photos of women without the women's knowledge or permission, all of those who supported this group in any way should reflect on the hurt and humiliation that they have been party to, through this site," Prof Hayne said.
Prof Hayne said the incident highlighted "a serious social issue around the objectification and degradation of women in New Zealand society and via social media in particular".
Ms Aitken said if women have concerns about any images that may have been placed on the site they should contact Sergeant Janelle Tait at Dunedin police.
- additional reporting John Weekes