Data Non-Disclosure, Misuse of Medical Records, and the Retaliatory EPO of 23 June 2025
Metadata
Filed: 18 August 2025
Reference: SWANK Addendum – ICO Complaint / Data Retaliation
Filename: 2025-08-18_SWANK_Addendum_ICOComplaint_AuditEPO.pdf
Summary: Formal ICO complaint showing Westminster’s refusal to disclose safeguarding records, misuse of sensitive disability data, and retaliatory removal of four U.S. citizen children.
I. What Happened
6 June 2025: Audit Demand served on Westminster seeking disclosure of safeguarding removals and unlawful practices.
7 June 2025: Instead of disclosure, Westminster issued a procedural threat.
16 June 2025: Follow-up filed; silence persisted.
23 June 2025: An Emergency Protection Order was executed, removing four U.S. citizen children under disproven allegations, while data remained deliberately withheld.
This was not safeguarding — it was data concealment dressed up as child protection.
II. What the Complaint Establishes
That Westminster engaged in willful non-disclosure in breach of UK GDPR and the Data Protection Act 2018.
That sensitive disability and medical data were repurposed as weapons to justify a safeguarding intervention.
That transparency was abandoned: internal records, emails, and case notes behind the EPO remain hidden.
That the wrongful removal of children was not an isolated tragedy but the direct product of a data crime.
III. Why SWANK Logged It
Because the ICO must not be permitted to treat safeguarding files as exempt from scrutiny.
Because the fusion of data secrecy + retaliatory removal represents the worst excesses of bureaucratic power.
Because when institutions misuse the disability records of children to shield themselves, the matter ceases to be parochial — it becomes a precedent for tyranny.
IV. Violations
UK GDPR & Data Protection Act 2018 – failure to disclose, misuse of sensitive data.
Article 6 ECHR – right to a fair hearing, obstructed by data concealment.
Article 8 ECHR – interference with family life without lawful, transparent justification.
Equality Act 2010 – discriminatory misuse of disability data.
UNCRC & UNCRPD – violation of children’s and disabled persons’ international rights.
V. SWANK’s Position
Westminster did not simply hide its files; it converted hidden files into false triggers for an EPO.
The ICO complaint makes plain that this was data abuse with children as collateral.
SWANK does not regard this as clerical negligence.
It is institutional perjury by database.
Closing Declaration
The ICO now holds the choice Westminster fled from:
whether safeguarding law may operate as an unchecked veil for data misuse — or whether disclosure will finally pierce the borough’s cultivated fog.
✒️ Polly Chromatic
Founder & Director, SWANK London Ltd
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