⟡ “You May Access Your Own Data — After You Prove Who You Are. Again. And Again. And Again.” ⟡
This Wasn’t Transparency. It Was Bureaucratic Gatekeeping With a GDPR Gloss.
Filed: 30 May 2025
Reference: SWANK/WCC/SAR-DELAYTEMPLATE-PROOFBLOCK
📎 Download PDF – 2025-05-30_SWANK_SARResponse_Westminster_ProofDelay_Ref40092693.pdf
Westminster City Council reply to Subject Access Request 40092693, demanding redundant ID and residency proof despite known records, delaying access and attaching bureaucratic conditionality.
I. What Happened
On 30 May 2025, Westminster responded to Polly Chromatic’s subject access request regarding misconduct, safeguarding misuse, and retaliation. Rather than begin the search:
They reclassified it from FOI to Subject Access — without notice or consultation
Demanded additional proof of identity and address, including government-issued ID and utility bills
Requested full names and birth dates of her four children — already held by them
Refused to begin the 30-day response clock until all demands were met
Included a veiled threat: if no reply in three months, the request would be closed
II. What the Complaint Establishes
Westminster used technical formality to delay lawful access
Known identity and records were dismissed until re-submitted
The reply imposed a delaying conditionality, not a data disclosure process
Instead of honouring statutory rights, Westminster forced the requester to re-establish their existence
This wasn’t privacy. It was postponement in procedural prose.
III. Why SWANK Logged It
Because demanding your name, your address, and your children’s identities from a person you’ve already taken children from is not compliance — it’s institutional gaslighting.
Because bureaucracy that requires re-identification in order to identify records is not neutral — it’s jurisdictional theatre.
Because this wasn’t the start of a search — it was a warning to stop asking.
IV. Violations
UK GDPR, Article 15 – Right of access obstructed through excessive identity requirements
Data Protection Act 2018 – No accommodation for known disability access format
Equality Act 2010, Section 20 – Failure to make reasonable adjustments
Human Rights Act 1998, Article 8 – Interference with data access as part of family life
ICO SAR Code of Practice – Discourages unnecessary identity tests where history is known
V. SWANK’s Position
This wasn’t a disclosure process. It was data custody theatre staged to deter the truth.
This wasn’t good faith. It was conditional access requiring self-verification of what they already know.
This wasn’t lawful transparency. It was administrative resistance dressed in GDPR jargon.
SWANK hereby archives this reply not as cooperation, but as the bureaucratic twin of safeguarding retaliation.
The Council took the children.
Now it denies the record.
But the archive keeps both.
⟡ This Dispatch Has Been Formally Archived by SWANK London Ltd. ⟡
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