I’m up there with the most libertarian people on phone alert annoyances and I think this is a non-issue. If you’re able to get out of the car, you’re taking the phone with you. You need to take pictures for insurance purposes — and of the other driver’s license (if there are others involved). If there are other people involved, you may need to call emergency services for them. If you’re too dazed to remember the phone, it probably _should_ notify emergency services.