That obviously makes sense to me, but IANAL, so I'll refrain from making any definitive judgement. A huge percentage of pictures are immediately shared with a third party (by being uploaded to the cloud).

Beyond that, while the rules outlined above deal with publishing, there are also rules for merely taking pictures. The exact rules for that aren't 100% clear to me[1], but if it's permissible to publish them, it must also be permissible to take the photo in the first place.

[1] https://de.wikipedia.org/wiki/Recht_am_eigenen_Bild_(Deutsch... it seems complicated