You're right Chris.
It just crossed my mind, that Vodafone should actually know the date of purchase as Vodafone SIMs need to be registered upon purchase. So if they have a database linking each IMSI (SIM card identity) with the IMEI (phone serial number) of the bundled phone, they can conclude from the SIM registration date when the phone was bought, even without gathering data from their network.
To prove this theory, I just got an IMEI from a friend's locked Vodafone phone and entered it in the mentioned form, which resulted this message:
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Ihr Entsperr-Code ist leider noch nicht freigegeben. Sie können ihn erst im Januar 2010 hier finden.
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in English:
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Unfortunately your unlock code has not been released yet. It won't be released until January 2010.
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So obviously this unlock procedure is completely automatized these days and you'll only need the IMEI of the locked phone to unlock it not earlier than 24 months after purchase.