The trouble with data is not what you can do with it – it is what else you can do with it.
There are so many interesting things that one might do with data these days which were simply not possible a few years ago. The question is, how many of them should we attempt to do?
For example, a few years ago we started using dedicated customer (or, I suspect we should say, congregational) relationship management software to manage our congregational roll rather than it being kept on a piece of paper in the office or even keeping it on a spreadsheet. All of a sudden it was possible for those of us who need access to the congregational roll to all be able to access it from wherever we were and know that we were dealing with the most up to date data and we wouldn’t get into a cycle of version control trouble where no-one knew which was the most recent updated list of members of the congregation.
All of a sudden though we could do things with that data that we couldn’t do before and perhaps the most striking thing was that at the push of a button we could have a map which showed where everyone lived. I can print off or save a map of how to get to a house if I am visiting though this is largely superceded by having gps on my phone. What was much more interesting was seeing where the congregation lived as a whole.
As soon as the map came on the screen, I remember saying, “Oh look, our congregation doesn’t cross the Clyde to worship”.
Now there are a few people who do come from the dark far side of the river but by and large, most people worshipping on a Sunday at St Mary’s don’t come from over yonder but live over here.
They shall come from the east and from the west and from the north, but not, in large numbers, from the south.
And that was quite interesting.
But what else could be done with data?
Well, the technology exists to do things that would be acceptable to me and help me in my ministry enormously but which I don’t think would be acceptable to members of the congregation and which might overtread the boundaries of legality.
For example… Most (but not all) people who come to a church would like it to be noticed, perferably by their minister or priest if they should be absent from church for a bit. If you do research on why people leave churches, not being noticed if you are missing is something that does often come up.
But of course, that’s hard to do. Some people are better at it than others, but pretty much no cleric in charge of even a moderate sized congregation can get that right all the time.
Now, new technology exists which would, with the addition of a couple of discrete cameras allow facial recognition technology to track who has been in church from week to week.
How lovely it would be for clergy to have a printout on Sunday afternoon of who was there this morning and a list of who has been missing for the last few weeks. And who could object to that?
Well, the trouble is not what can be done but what else can be done of course and there’s all kinds of people who might not like it to be known where they have been and with whom they have been associating and who would probably not like it to be thought that the clergy of St Mary’s had an accurate database of who has been turning up.
It is complicated too.
Some asylum seekers would be very concerned at being tracked by cameras, whilst others would be delighted that their presence had been recorded, the better to prove that they were integrating into society. And what of that group of the most anxious visitors to St Mary’s – Church of Scotland Ministers Having a Day Off? They, generally speaking are happy to be with us but are sometimes less happy to be seen to be there. (And I did at one point suggest that we build little booths around the walls so that they could worship with us without being seen by Other Members Of Presbytery Also Having A Day Off).
I don’t think that facial recognition technology is going to be acceptable in church any time soon. However, it is worth remembering that we used to have the communion token system whereby communion tokens were distributed to members of the congregation who would bring them when they came to worship. It was partly a way of keeping tabs on who was there and partly a way of keeping people from receiving communion whom others thought should not be receiving.
It was simple technology and acceptable technology.
The current rise in the use of data is far from simple and not always acceptable.
Very recently the General Synod Office in Edinburgh issued some guidance for congregations in Scotland of how we might best keep the new GDPR – General Data Protection Regulations that are coming in next month.
These have been issued far too late and seem to have been devised from the point of view of trying to ensure that clergy and vestries don’t get sued for the way that data is used rather than trying to ensure that people’s data is protected and that the data that the churches keep can be used most effectively in mission.
Oh yes, data use can be mission. I mean it can really be employed for mission, not simply that it is mission in the banal way that everything in any church meeting has to be described as mission in order to get people’s attention). Data can be mission gold.
Just think – all those endless (and ridiculous) times we’ve been told that the best form of mission is to get people to invite their friends to church. Is all that “friendship evangelism” rhetoric not superfluous if we can invite friends of friends of facebook ourselves directly? (Though whether Facebook’s business model survives current scandals is anyone’s guess).
The GDPR materials that we’ve been sent don’t seem to me to be remotely adequate for what we are in the business of and it was very clear that when we discussed them at Vestry recently we would not be able to follow the guidelines from the province anyway. (And I found myself wondering which of our Boards had seen sight of these guidelines – Admin Board or Information and Communication should certainly have had a hand in them and the Mission Board too, I think).
But it is clear that they are difficult for us to implement.
For example, some time ago, the General Synod resolved that clergy should display the contact details for everyone in a congregation for a couple of weeks before the Annual General Meeting.
The new guidelines from the General Synod Office suggest that we now must all go and get everyone in the congregation’s permission to do this.
The truth is, the culture around data has changed completely.
If I made the public publication of everyone’s contact details a condition of being on the roll I’d have no roll left.
If I went round asking the congregation for permission to do so, I’d decimate the formal membership of the congregation instantly. Vestry were very clear that I shouldn’t do anything so stupid. We won’t be publishing everyone’s data and we won’t be asking everyone’s permission to do so. It would harm our mission even to try. And General Synod should revisit this resolution urgently.
Nor will we be asking people’s permission to pass their contact details onto the diocese or the province as we’ve also been recommended to do. We don’t share data in this way. The culture of our times suggests that people would turn away from us if we did do this kind of data sharing. It is against the spirit of the whole GDPR revolution. And so again, we find ourselves having to develop local policies which are legal and fit both with who we are and the culture in which we live.
I fear sudden drops in the recorded membership of the Scottish Episcopal Church if clergy and vestries implement what they have been told to do by the General Synod Office.
There’s also a lack of any kind of conversation about the retention of data.
I’d quite like to see an animation of where the congregation lives on a map of glasgow over a period of 50 years. It would help me know which parts of the city we are reaching and particularly whether we are reaching more affluent or less affluent places. That kind of use of data fits with out ethos. Our church is telling us that we should delete the data that would make it possible.
Data use is tricky. We need to talk about it far more. We need to use it legally with appropriate levels of permission and consent. And we need to use it well.
You raise questions that we have all been struggling with in Churches up and down the land for months now. Its difficult to interpret legislation that hasn’t yet been put on the Statute book, unless through the lens of the preceding legislation. With which we were completely compliant. An example being the Electoral Roll on display in the Church, only has names, and nothing else. We have a parish directory, which has always been completed with the written consent of those who are happy to appear on it and agree to share with other members on the electoral roll. Up to now, Children were not on the roll, unless their parents gave their consent. Under GPDR, children down to age 13 need to give their personal ‘informed consent’ which is not as easy as it sounds. Some, who were previously included with their parents, do not want to be on the next directory, apart from their name and a phone number (mobile) which given their propensity to change phones at the drop of a hat, or to lose them, makes them virtually incommunicado. This is difficult as the majority of our choir are children and contacting them for short notice commitments via their parents can be problematic, now, having to communicate direct might be a non-starter.
As people have become more aware of their rights and responsibilities, and our responsibility to them, the vision of a member of Clergy or a Church receiving the minimum £5K fine makes us all shiver for any breach of the new rules. And even being sued for damages. I hope that our insurance for such liabilities has been updated?
Mind you, the common sense things have apparently been sorted. For instance Registers of Hatch, Match and Despatch and Baptism and confirmation are compliant and as Public Records can be retained and archived safely, as they currently are with local Register Offices.
And apparently records of people that we minister too and have ministered too and use to offer ongoing care are ok for secure storage and use, provided that we review them and safely destroy them when they are no longer needed.
other financial records such as those of gift aid donors are exempt from the GPDR as long as they are required by HMRC, currently six years. And as most are now managed (by us) electronically, they are tightly controlled and kept secure, not on an odd computer left available for anyone to use.
I don’t anticipate any real issues in our parish, as a great deal of effort, time and resources have gone into ensuring that we’re compliant. But we just need to be careful not to get complacent.
I think that GDPR is 95% common sense and 5% utter madness.
Remember Gentle Reader that UKViewer seems to be based in Englandshire and their rules on registers differ markedly from those of blessed Caledonia.
A marriage register in the Scottish Episcopal Church has no legal purpose, to start with…