That's a good counterpoint.
It would still have to live somewhere in the filesystem, and have a userspace program load it in to the kernel, just as `utsname.nodename` is loaded from /etc/hostname.
Yes; that area of the filesystem can be readable only to root. It could also have other avenues of entry: it could come from the boot firmware via the kernel command line, or be in a device tree blob or whatever.
Counterexample: struct utsname and the uname system call.