Wednesday, 23 May 2018

Data Day

Tick, tick, tick, runs the clock, to Friday when, as every fule no, the General Data Protection Regulation comes into force. Your inbox will almost certainly, like mine, be clogged with endless emails from various organisations asking you whether they can continue to use your data. I'm curious about the ones who haven't got in touch with me, ranging from Hedges Direct, from whom I bought some hawthorn saplings last year, to Gunner Faerber, the German mineral salesman who regularly sends me updates about which interesting stones he'll be peddling in Stuttgart in July or Vienna in October. I don't care, but the mere fact I've got on his mailing list is so bizarre it tickles me to see the emails arrive.

At Swanvale Halt church we have to comply, ultimately, along with everyone else. Our senior churchwarden to whom the task has been deputed is remarkably relaxed about the whole thing, remarking repeatedly at meetings that 'we need to demonstrate that we're doing something, but not have it all done by the 25th'. While this may be true, it appears to translate into not doing anything at all by the 25th, which strikes me as over-relaxed, so I've roughed out a Privacy Policy which we can use for now, based on the diocese's templates. 

As well as the fairly obvious details such as email addresses for various contact lists and sub-groups within the church, we hold a bewildering variety of data. I have some pastoral notes about people, for instance - and remember, we are told to write down accounts of conversations we have with people in difficult pastoral situations - and copies of material used by wedding couples and those seeking marriage licences from the Bishop's Registry to prove their identity, all of which are potentially very sensitive. Then there's more superficial stuff such as lists of who's attended Toddler Group, Church Club at the Infants School, or Messy Church over the years, whether they regularly come to church or not, and so on. None of it is a patch on the notebook I found when looking through the archives of the church I used to worship at in High Wycombe. It was Fr McManus's personal register of all the families in the area in about 1955, with details of names, schools, occupations, addresses, and helpful comments alongside the entries such as 'Bad family' or 'No hope'. Anyway, there's no way all of our data storage can possibly be compliant by Friday ...

In this connection I was thinking today about what constitutes a 'member' of an Anglican church. People on the Electoral Roll are certainly members, but what about those who come along to church yet aren't on the Roll? The ambiguity is that legally everyone in a parish is assumed to be a 'member' of their Anglican parish church. Anyone in a parish has the absolute, undeniable right - with certain protected exceptions - to marry in their parish church. They cannot be absolutely denied other sacramentals, either, although churches have the right to set certain conditions such as requiring attendance at worship or preparation classes before children are baptised. Anyone in the parish, literally anyone, can vote in the election for churchwardens, and being on the Electoral Roll merely indicates that a person wishes to take part in the governance of the church. Article 9 of the GDPR mentions that data can be held without explicit consent for people who are 'members or former members (or those who have regular contact with [the organisation] in connection with [its] purposes; and [where] there is no disclosure to a third party without consent'. Now, as I read it, for an Anglican church that could essentially mean everyone within the parish boundary, covering our pastoral and general evangelistic work. At any rate, we won't be sending out any of those emails asking people to hit 'YES' before the end of the week. 

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