⟡ On the Coexistence of Ice Skating and Data Protection ⟡
Filed: 16 February 2026
Reference: SWANK/CFC/PC23453
Download PDF: 2026-01-22_PC23453_Addendum_Photography_WelfareBoundaries.pdf
Summary: An addendum recording consent boundaries regarding photography and data use during ongoing proceedings.
I. What Happened
During ongoing proceedings — those famously serene environments — the children attended a group ice-skating activity.
There were blades.
There was balance.
There was municipal joy.
Photographs were taken.
No written consent had been requested.
No advance clarification provided.
No elegant little form fluttered into existence beforehand.
The camera, however, arrived fully prepared.
An Addendum was therefore filed ahead of the Issues Resolution Hearing.
Not dramatically.
Just… formally.
II. What the Document Establishes
This entry records:
• A parental clarification that “ice rink” is not a synonym for “content creation studio”
• A distinction between safeguarding necessity and recreational photography
• A polite request to identify who stores what, where, and why
The document does not allege misconduct.
It simply introduces the concept of perimeter to a situation that appeared to believe in open-plan governance.
III. Why SWANK Logged It
This entry has been archived because:
• Privacy boundaries are structural, not seasonal
• Prolonged proceedings sharpen one’s appreciation for predictability
• Ice skating and data retention are not, in fact, conjoined twins
Ice skating is recreational.
Photography is administrative.
They may coexist.
They are not automatically married.
The distinction required articulation.
It has now been articulated.
IV. Applicable Standards & Considerations
The matters engage:
• Children’s privacy and dignity
• Data protection governance
• The radical idea that consent usually precedes documentation
Such frameworks ordinarily anticipate:
• Clear advance consent
• Defined storage and access protocols
• The absence of surprise archives
An activity may be ordinary.
Image retention, however, enjoys a long afterlife.
The difference is procedural.
It is also quietly permanent.
V. SWANK’s Position
This is not objection. It is boundary-setting in sensible footwear.
• Participation does not imply publicity.
• Recreation does not dissolve data protection.
• Ongoing proceedings are not a “buy one skate, get one archive free” arrangement.
The archive does not dramatise.
It clarifies.
⟡ Formally Archived ⟡
No allegation has been introduced.
No motive has been inferred.
If governance now appears slightly more alert, that is a property of clarity, not temperament.
Because occasionally,
the camera takes its bow
before consent has even laced its skates.
© 2026 SWANK London LLC