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The guidelines are less cut and dry than I remember them, but the rule I was thinking of was the general notability guidelines (WP:GNG).
Over a quarter of the publications cited in the article are non-independent sources provided by Blizzard, and of the 18 secondary publications, he is only a trivial mention in sources 1, 3, 4, 11, and 15. Almost the entirety of the Gameplay and Appearances sections provide an exhaustive amount of indiscriminate information with no added context indicating the significance of said information.
This article reads less like a page from an encyclopedia and more like a page you would find on a wiki made specifically for overwatch. Unlike, say, the Wicked Witch of the West, who is an enduring character with countless adaptations and definite cultural significance, Winston is a character whose cultural significance hasn't really eclipsed his role in his source material. I think the strongest argument for the existence of an entire article dedicated to Winston is his prominence in internet meme culture. But this article doesn't even mention that aspect of the character, let alone his iconic mimetic phrase "did someone say peanut butter?"
