Open questions
Everything unresolved, what would resolve it, and who needs to answer. Ordered by how much depends on the answer.
Blocking — a wrong answer changes whether we build at all
Sway's entire function is making a child's Twitch Data available to their guardian. §VI.C forbids that "for any purpose without Twitch's prior written permission". If the parent is a third party, the whole integration needs written permission before launch.
Resolves via: a written answer from Twitch developer relations. Not Sway's counsel. Ask at the same time for authorisation to exceed the 24-hour cache cap — without it no historical trend view is compliant.
The researching agent reversed its own position mid-analysis. The better view is still out of scope, but s.3(2)(a) is live once children are users. Wrong answer means illegal-content risk assessment, children's risk assessment, the Protection of Children Codes and the fee regime — a step-change in cost.
Resolves via: counsel opinion on whether a strictly read-only, provider-generated transparency view survives s.3(2)(a). Highest-stakes legal question in the engagement.
If it works it is materially better than consent or ordinary legitimate interests. But it is Likely only — not retrieved as primary text — and reportedly under six months old with no guidance and no case law. The necessity test survives regardless. UK-only.
Resolves via: verify at legislation.gov.uk (a 10-minute job), then counsel on scope.
The only route to a Roblox integration. Honest expectation: no. The prohibition has no purpose-based carve-out, and the announcement thread drew ~30 replies asking exactly this — Roblox answered none.
Resolves via: written ruling from Roblox, approached through the Trusted Flagger programme — the only sanctioned relationship channel.
Engineering spikes — cheap, and not answerable from documentation
| # | Question | Effort | Blocks |
|---|---|---|---|
| Q5 | Does the child's own sent message echo back on a separate EventSub/IRC connection? | ~½ day | Whether "what your child said" is a capability at all |
| Q6 | What total_cost does channel.chat.message return? |
~½ day | Whether the 10-cost WebSocket ceiling is hit immediately |
| Q7 | Can an under-13 Roblox account complete an OAuth consent flow? | ~½ day | Any Roblox OAuth design — though Q4 likely moots it |
| Q8 | Can a Family Link–supervised Android child account toggle Usage access? | ~1 day | The Android enrolment story |
| Q9 | Apple Family Controls entitlement — turnaround and acceptance rate? | A form | The entire iOS route, and EAS dev clients. Submit now |
Verification — claims we should not publish as fact
| # | Claim | Action | Owner |
|---|---|---|---|
| Q10 | Meta v. BrandTotal | Do not quote. Confidence explicitly retracted by the researching agent | Counsel |
| Q11 | ICO fines — Imgur, Reddit | Verify at ico.org.uk. The Reddit figure is large enough to be quoted back at you | Anyone |
| Q12 | UK under-16 ban, Spring 2027 | Verify before board discussion | Strategy |
| Q13 | UK GDPR Art 25(1A) | Verify at legislation.gov.uk | Anyone |
| Q14 | CJEU C-184/20, C-21/23 | Retrieve judgments before relying on them | Counsel |
| Q15 | Twitch Family Center detail | Launch date, age range and the weekly email were independently corroborated. Open the help pages in a browser for the rest | Anyone |
| Q16 | DSA Art 28 guidelines §§80–82 | Get the PDF — para 80 is directly relevant to Q19 | Counsel |
| Q17 | Roblox help-centre pages | Two of three prohibition sources are Wayback snapshots dated 4 and 6 July 2026. Open both URLs in a browser to confirm live text still matches | Anyone |
Product & design
Q18 · The objecting teenager
The ICO puts the child's wishes at the centre; the parent's objection is not determinative. Sway has no statutory duty to invoke under Art 17(3) — a commercial product cannot borrow a social worker's justification. The most likely point of overreach. Decide what the parent is told, and disclose it to both at onboarding.
Q19 · Verifying the parent is the parent
No verification exists today. Split-custody and abusive-parent scenarios are the highest-harm failure mode of this product.
Q20 · Under-13s on Twitch
Twitch ToS prohibits the account outright — but a child in that cohort having one is itself a safety finding. Feature, or support conversation?
Q21 · Rendering permanent gaps
Roblox will have permanently empty regions where chat and friends would be. The prototype proposes explicit "not available" treatment. Needs design sign-off — a substantial departure from the social layout.
Q22 · Is spend in scope at all?
Twitch exposes no balance or purchase history; Roblox is prohibited. A spend card with no data source is worse than no card.
Strategic
Twitch now emails guardians a weekly list of channels watched and hours spent — the exact data point Sway most wants and provably cannot build, free. Sway's defensible ground is cross-platform aggregation, real-time whisper and AutoMod detection, and interpretation. That is a narrower proposition than "we show you their Twitch activity", and the positioning should reflect it before engineering starts.
Likely, unverified — reportedly Spring 2027, covering TikTok, Instagram, YouTube and Snap. If UK under-16 accounts on those platforms cease to exist, a product whose value is showing a parent their UK under-16's activity there loses its data source for its core cohort.
Roblox and Twitch are not on the named list — which argues for gaming expansion, and makes the Roblox prohibition more commercially painful, not less. Board-level, not a compliance line item.
The Apple 5.1.1(v) exposure is live on the shipped product today, independent of gaming, and adding platforms four and five to the same pattern increases it. This research surfaced the issue rather than creating it.