For readers of this site who live particularly in Europe, and especially in the UK, the not-so-catchy acronym that is causing a bit of a stir is GDPR.
What is GDPR?
GDPR stands for General Data Protection Regulations. These regulations will come into force on May 25, 2018, and will affect how legal entities, such as corporations managed by the Organization of Jehovah’s Witnesses, keep records on citizens. Do these new regulations have the potential to financially impact JW headquarters in the USA? Consider that the law will expose corporations operating within the EU to heavy fines for non-compliance (up to 10% of revenue or 10 million euros).
There is much data available about GDPR from Governments and on the internet including Wikipedia.
What are the main requirements?
In plain English, the GDPR requires the data collector to specify:
- What data is requested;
- Why the data is needed;
- How it will be used;
- Why the business wants to use the data for the reasons indicated.
The data collector is also required to:
- Obtain consent to gather and use a person’s data;
- Obtain parental consent for children’s data (under the age of 16);
- Give people the ability to change their mind and request their data be deleted;
- Provide the individual a real choice as to whether he/she wishes to hand over data or not;
- Provide a simple, clear way for the individual to actively and freely consent to their data being used.
In order to comply with the new rules around consent, there are a number of things required from the data collector, such as the Organization of Jehovah’s Witnesses. These include:
- Ensuring that all marketing materials, consumer contact forms, emails, online forms, and requests for data, give users and potential users the option to share or withhold data.
- Providing reasons why the data may be used and/or stored.
- Proving the benefits of sharing data, while clearly giving the consumers the ability to actively consent to so doing, perhaps with a check box or by clicking a link.
- Providing the means on how to request one’s information or data be deleted from all corporate and partner databases.
What has been the response of the Organization?
The Organization has created a form which they want every baptized witness to sign by the 18th May 2018. It has the designation s-290-E 3/18. E refers to English and March 2018 version. There is also a letter to the Elders giving instructions on how to handle those who show reluctance to sign. See below for extract. The full letter can be seen on the FaithLeaks.org website as of 13 April 2018.
How does the “Notice and Consent for use of Personal Data” form and the Online policy documents on JW.Org match up to the requirements of the GDPR legislation?
What data is requested?
No data is requested on the form, it is purely for consent. We are pointed to an online document on jw.org for the Use of Personal Data—United Kingdom. It states in part:
The Data Protection Law in this country is:
General Data Protection Regulation (EU) 2016/679.
Under this Data Protection Law, publishers consent to the use of their personal data by Jehovah’s Witnesses for religious purposes, including the following:
• participating in any meeting of a local congregation of Jehovah’s Witnesses and in any volunteer activity or project;
• choosing to participate in a meeting, an assembly, or a convention that is recorded and broadcast for the spiritual instruction of Jehovah’s Witnesses worldwide;
• attending to any assignments or fulfilling any other role in a congregation, which includes the publisher’s name and the assignment being posted on the information board at a Kingdom Hall of Jehovah’s Witnesses;
• maintaining the Congregation’s Publisher Record cards;
• shepherding and care by elders of Jehovah’s Witnesses (Acts 20:28;James 5:14, 15);
• recording emergency contact information to be used in the event of an emergency.
While some of these activities require data to be stored—emergency contact information, for instance—it is hard to see the requirement applying to shepherding and care by the elders. Are they suggesting that unless they can keep the publisher’s address on record and share it with the worldwide community of JW organizations, it will not be possible to provide shepherding and care? And why would participating in a meeting, by giving a comment, for example, require data sharing? The need to post names on the announcement board so that assignments like handling the microphones or giving parts on the meetings can be scheduled would require some data to be exposed to the public, but we’re only talking about the person’s name, which isn’t exactly private information. Why do such assignments require a person to sign away his right to privacy on the world stage?
To Sign or Not to Sign, that is the question?
That is a personal decision, but here are some additional points to bear in mind that might help you.
Consequences of not signing:
The document continues, “If a publisher chooses not to sign the Notice and Consent for Use of Personal Data form, Jehovah’s Witnesses may not be able to evaluate the publisher’s suitability to fulfill certain roles within the congregation or to participate in certain religious activities.”
This statement actually breaks the regulations as it is not specific as to what the publisher may no longer be able to participate in. Therefore, ‘giving or withholding consent is not possible on an informed basis’. This statement should at the very least state all the roles and activities that would be affected. So be aware that any existing roles might be removed because of non-compliance.
From the letter to elders named ‘Instructions for use of Personal Data S-291-E’ of March 2018
Notice that even if one refuses to consent to the sharing of personal data, the congregation elders are still directed to keep his personal data in the form of the Publisher Record Card, shown here:
So even if you withhold consent, they still feel they can violate your data privacy by recording your name, address, telephone, date of birth, date of immersion, as well as your monthly preaching activity. It would seem that the organization is not about to lose control, even in the face of international regulations by the superior authorities that Jehovah requires us to obey in such instances. (Romans 13:1-7)
Consequences of signing:
The letter further states, “Personal data may be sent, when necessary and appropriate, to any cooperating Organization of Jehovah’s Witnesses.” These “may be located in countries whose laws provided different levels of data protection, which are not always equivalent to the level of data protection in the country from which they are sent.” We are assured that the data will be used “only in accordance with the Global Data Protection Policy of Jehovah’s Witnesses.” What this statement does not make clear is that when moving the data between countries, the stricter requirements of data protection will always take precedence, which is a requirement of GDPR. For example, under GDPR, data could not be transferred to a country with weaker data protection policies and then be used according to the weaker data protection policies as this would be attempting to circumvent the requirement of GDPR. Despite the “Global Data Protection Policy” of the Organization of Jehovah’s Witnesses, unless the United States has data protection laws equal to or more restrictive than those of the EU, the UK and European branch offices cannot, by law, share their information with Warwick. Will the Watchtower corporations comply?
“the religious Organization has an interest in permanently maintaining data regarding an individual’s status as one of Jehovah’s Witnesses” This means that they want to keep track of whether you are ‘active’, ‘inactive’, ‘disassociated’, or ‘disfellowshipped’.
This is the form that is being provided to all EU and UK publishers:
The Official Policy document continues: “Upon becoming a publisher, a person acknowledges that the worldwide religious Organization of Jehovah’s witnesses…lawfully uses personal data in accordance with its legitimate religious interests.” What the Organization may view as “legitimate religious interests” may be quite different to your view and is not spelled out here. Additionally, the consent form allows them to share your data in any country they wish, even countries without data protection laws.
Once you sign consent there is no simple online form to remove consent. You would have to do it in writing via the local body of elders. This would be intimidating for most Witnesses. Will most Witnesses feel strong psychological pressure to sign, to conform? Will those who care not to sign or who later change their minds and request their data not be shared do so free from any form of peer pressure?
Consider these legal requirements under the new regulations and judge for yourself whether they are being met by the Organization:
- Requirement: “A data subject’s consent to processing of their personal data must be as easy to withdraw as to give consent. Consent must be “explicit” for sensitive data. The data controller is required to be able to demonstrate that consent was given.”
- Requirement: “’That consent is not freely given if the data subject had no genuine and free choice or is unable to withdraw or refuse consent without detriment.”
What if you hear that pressure from the platform is being exercised by the user of such phrases as, “If you don’t sign you are not obeying Caesar’s law”, or “We will want to comply with the direction from Jehovah’s Organization”?
Other Potential Consequences
Only time will tell what other consequences these new regulations will have on the Organization of Jehovah’s Witnesses. Will disfellowshipped persons request that their data be removed from congregation archives? What is someone does that but at the same time asked to be reinstated? Would it not be a form of intimidation, of pressuring someone into releasing the confidential data, to require a person sign the consent form before their reinstatement case can be heard?
We shall have to see what the ramifications of these new laws are over the long term.
Could be harvest time and this is their way of picking out the wheat from the weeds.
Sign and you are wheat, don’t sign and you are a weed. Just one more way of counterfeiting the Christ.
That wouldn’t work according to their theology. Based on the last Memorial figures, there were 18,500 partaking (includes mental ill ones etc.) and only these are the Wheat! The vast majority could not qualify as Wheat.
To do what you suggest, they will need to do a new “light has flashed forth” article and then explain how people become weeds. (ha ha Ha)
That’s interesting, compared to the number of partakers in 1992 which was 8,683 according to the proclaimers book page 243 second paragraph. Also interesting is that in 1938, 39,225 partook of the emblems, same book same paragraph. Now that tells me that they were preaching death and destruction at (H)armageddon way before some of the anointed were even born. It has been said that numbers don’t lie but I’m here to tell ya they do. (Has anyone here ever heard of the missing dollar syndrome?)
This may be something the superior authorities require in various parts of North America and the EU, but the Org. Will use it to it’s advantage as a straw man argument that “the government is making us do it”. All the while making note on the local level through BOE to report any who refuse to sign! We know they monitor this and other sites in order to counteract Apostates making inroads into the congregations as more are waking up due to the internet. They can easily see the negative response to signing this document and now have a “red… Read more »
Meleti has been mighty quiet on this issue, I would love to hear his personal viewpoint on this matter, since we all kinda look up to him ( in a patriarchial way) and value his opinion.
Maybe Meleti is booking a round of golf, like I am in the process of doing…….
Nothing wrong with that, I hope you enjoy the round with a few birdies and an eagle. Best regards, Psalmbee
Thanks Psalmbee, will do!?
Maybe he got a call from Hollywood to go make a movie.
Just one more thought on this topic. Reading the WT releases on this, I see that if you refuse to consent to having your personal data managed by WT, you cannot be a pioneer, MS or elder. Presumably, if you already are one, those positions will be revoked. Since they consider the publisher record card as separate from “other” data, surely they know who a given person is. Are they saying that unless they are allowed to maintain a dossier on you, you are one step away from being treated as if DF’d ? I thought this GDPR law was… Read more »
Well Robert, since you asked, here it is. I think that no matter what the specific issue is, the Org will react in a fairly predictable manner. In this case, we are talking about the use/abuse of personal data. The mandate has been issued by “Ceasar,” so predictably, the Org recoils in defense and in effect says, “You can’t tell us what to do, we only listen to God”, misapplying Acts 5:29. Romans chapter 13 gets shined-on completely. Is it heavy-handed? Of course it is. Complete obedience is required or you will lose your “priveleges” now, and very likely lose… Read more »
Exactly what privileges am I going to lose ?
Good Morning LJ,
Have you read the letter that accompanies the form? It is posted on Faithleaks. Long story short- if you are “serving” in an “appointed position” (privelege), and you refuse to sign?
As the Soup Nazi on Seinfeld said ” No soup for you!!”
Hi Leonardo The organization’s documents are not clear on this. Potentially all except being a publisher is the inference. That is the illegal threat because they don’t spell out the repercussions, but they leave it up to people’s imaginations. They need to be able to deny any removals of privileges being the result of refusal to sign. On recent past track record They are perfectly capable of it being all privileges. I think it is definitely likely to mean no new appointments of those who haven’t signed. Maybe one driver behind it all is that they maybe conducting criminal background… Read more »
I would have to agree with that speculation Tadua, all their hidden agendas are for pleasing Ceasar, it seems as if they prefer that over pleasing God, it always boils down to the legal eagles of the incorporation. The first century Christians didn’t have the legal grounds to stand on as does this outfit known as the WTBTS (Incorporated). For Heavens sake I wouldn’t want to lose my privilege of holding a mic or passing around some bread and wine that nobody’s gonna eat or drink.(lol, let’s get real!)
I’m not sold on the Org wanting to please Caesar. They may outwardly indicate this, but in reality they think they are above Caesar. They won’t be told what to do by “Worldly Governments”.
I stand corrected, thank you Warp Speed.
It wouldn’t surprise me Warp if the GB or their lackeys have made secret deals with the government. They had no problem with joining the UN , only because it got media attention did they drop the association. There are at the moment people wanting to change the US constitution, one of the things is the protection given by the 1st amendment, it is well recognised that all sorts of crooks and shysters have used the 1st amendment to avoid legal prosecution, sadly even JWorg is hiding behind it , preventing the exposure of the extent of the peadophile problem… Read more »
Howdy Tadua, Very interesting indeed. You mentioned the new CO visit protocol of getting any recommendations a month before his visit. One year ago I was still an elder, and our CO told our Body verbally that in fact the real reason why there is the “new” arrangement for CO’s making appointments was not necessarily to follow 1st century procedure, but rather, for legal reasons. Yes, they have to submit any potential appointments to basically get a criminal background check. The manner in which this accomplished however, is very convoluted. It is done in such a way as to leave… Read more »
Hi Warp Speed
Thank you for confirming that. I was 99% convinced that was going on but had not been able to get any confirmation.
Yes, the Organization is rapidly becoming a chameleon. The changes over the last 5 years make it almost unrecognisable from the organization that I knew from when I was young.
Yes, Tadua, it really has changed. I never got the impression we had to believe what we were taught. You felt part of an organisation trying to do its best. We weren’t threatened at assemblies, with items based on fear. Maybe we didn’t know what was going on behind the scenes, but maybe that was a good thing. And it Is the very thing they were scared of which is coming back to bite them, the Internet.
That pretty much agrees with what I had concluded about how the new CO arrangement worked, and why. The CO becomes everyone’s “alibi”. Say that someone is appointed who turns out “bad” for one reason or another. You can’t sue the congregation for making a bad decision because the CO did it. You can’t sue WT HQ for the same reason. Suppose you wanted to sue the CO himself. What good would that do? They are volunteers, paid by the congregations and are all but broke. A CO doesn’t belong to any one congregation, nor is he “close” to WT… Read more »
A “legal firewall”. Very well put Robert. This is HQ’s way of insulating itself from possible legal repercussions for sure.
What Would Jesus Do? I don’t think any of us here would believe He would select this Org to be His “Faithful Slave”.
It astounds me that the Org is always beating the drums about “loyalty”. It is a one-way street to them, be loyal to us, but all of you are ultimately expendable.
Sorry, Tadua, I think I was being a bit flippant, like I don’t have that many privileges to lose.
AFAIK, to become an elder, one has to sign something about obeying all the orders from WT. So they probably have no way to refuse to give their consent without stepping down. I don’t remember the deal with pioneers. They might or might not be free to refuse. MS’s probably could refuse. In theory. All these positions are advertised as privileges, which are available only to exemplary. On this basis it is very easy to divest the dissenters. So, yes, I think after a while there will be no one holding any of these positions, who has not signed. And… Read more »
Nothing to sign when I was appointed, tykik. The most committing document I have ever seen is the vow of poverty, but that only applies to Bethel workers, special pioneers, and some other full time workers.
This is a most interesting post . Speaking from my own perspective I feel that this whole GDPR thing is a small part of a much bigger puzzle that is slowly been put together world wide. I have been studying the two kings in Daniel and the Wild Beasts. I feel that the king of the north and the first Wild beast are one and the same, the King of the north brings about a world situation that gives birth to a mega totalitarian state, this being the 666 beast. Reading the description in Rev13:16-18, to me anyway, is like… Read more »
W/O, it could be they are getting ready for a mass exodus, maybe they are feeling the uprising of a rebellion and are legally preparing for it. It could be and does seem so that the WTBTS is a “legal wild beast” (Re 17:17)?? Did any one catch what the one form said? … “and similar cooperating organizations of Jehovah’s Witnesses” Hmmm. I guess most of them will just read right over that just like they do the Bible.
I am fortunately not affected by this any more. If I were still a member, this would totally creep me out. For the sake of any JW reading this article and wondering how to answer the question you pose, here is my honest opinion: You do realize that once you sign, there is no practical way to “un-sign”, don’t you? Think really long and hard before you sign this. Then, FOR THE LOVE OF GOD, DON’T SIGN. And, if they ask again and keep pressuring you to sign, refer them to Deuteronomy 3:26: “That is enough of you! Never speak… Read more »
I think many would echo your sentiments.
It is a true if sad statement that what people don’t know about you can’t be used against you and what people know can and at sometime will be used against you.
If a corporation even our employer asked us to sign such a document we would be well advised to think very seriously. There are far to many examples including one in the world news where a well known social media application sold its data without its customers permission.
Doesn’t Jehovah already have everyone’s personal information? Sounds to me like a contract with the devil. Tadua You said that “we shall have to see what the ramifications of these new laws are over the long term”, well I got news for ya: these are the ramifications of the long term. It’s really disgusting how they have become the disgusting thing that we have been warned to stay away from. Wake-up folks, you might want to see the rest of the show.
Please don’t forget to sign your “Spiritual credit application” form #SCA1914.
If you have bad credit, don’t worry form #SCA1975 is always available. Wow what a joke this outfit has become and I’m loving it! BTG (Babylon the Great) has taught them well.
Actually, they ARE Babylon the Great. Or should I say, just one of the many cogs that constitute it.
Hi Tadua. Thank you for keeping us up to date. Goodness knows what areas will be affected by these rule changes, but I am sure it will keep the elders busy. Does anyone really understand the DP laws ?