General Data Protection Regulation

General Data Protection Regulation

On May 13, 2019, the Jehovah’s Witness leaders released a letter addressed to all congregations in countries that comply with the General Data Protection Regulation (GDPR). They are directing those members not to collect personal data in connection with their field ministry.

This change in policy is massive as it affects some 1.3 million members. There are around 8.4 million members worldwide. Most of Jehovah’s Witnesses’ proselytizing required the mass collection of personal data so that they could return on members of the public who may have shown a passing interest in their publications, including The Watchtower and Awake! magazines.

In 2013 Finland banned Jehovah’s Witnesses from collecting personal data during their door-to-door visits. The religious group challenged the decision saying that their preaching work was a personal religious activity and claimed that data collection was merely personal notes. However, in 2018, the Luxembourg-based Court of Justice of the European Union sided with Finland saying that such religious activity is not covered by exemptions granted to personal activity.

The content of the letter to congregations is as follows:

Sharing in the field ministry has always been a personal expression of each Christian’s faith and desire to preach the good news of God’s Kingdom. (Matt. 28:19, 20) Over the years, you may have become accustomed to collecting personal data in connection with your ministry. However, recent court decisions and the enactment of the General Data Protection Regulation (GDPR) affect the collection and use of personal data in our branch territory. Thus, any suggestions we previously made on note-taking as related to the field ministry are no longer applicable.—Rom. 13:1.

Accordingly, publishers should not collect personal data in connection with the field ministry. This means not maintaining records that include a person’s name, address, language, ethnicity, and so forth. It also includes not recording addresses where no one is at home.

Though no personal data is recorded, publishers are encouraged to cultivate the interest they find. A publisher could do so by (1) providing his contact information to the interested person and arranging a return visit, (2) directing the interested person to the address of the nearest congregation meetings, or (3) directing the person to jw.org.

As an exception, if a householder requests that no further visits be made to his home, the publisher should make a note of the date and address only and place it in the territory record so that publishers working the territory in the future will not call at that address.

– Christian Congregation of Jehovah’s Witnesses

A postscript strictly provided to elders (leaders of the congregations) provided the following additional information:

The coordinator of the body of elders should arrange for this letter to be read to the congregation at the first midweek meeting after its receipt. Thereafter, it should be posted on the information board for one month. This postscript should neither be read to the congregation nor be posted on the information board.

Territory Map Cards (S-12) used for group and personal territory should show only geographic boundaries, such as street names. (od p. 91 par. 31) These cards should not include personal data such as a list of addresses of householders who speak a particular language.

When two or more congregations preach in the same neighborhoods, the service overseers in these congregations should communicate to work out a mutually acceptable system of covering the territory that does not involve maintaining records that contain the personal data of householders.—sfl chap. 23 par. 5; chap. 24 par. 1.

Please review the size of the individual territories used for house-to-house work. (sfl chap. 23 par. 2) In line with local circumstances, there may be advantages to preparing territories with fewer homes. For example, publishers may be motivated to request a territory close to their home or workplace. (od p. 91 pars. 31-32) In addition, since publishers do not collect personal data, territories with fewer homes may assist publishers to thoroughly search out “deserving ones” in the territory and cultivate interest.—Matt. 10:11.

– Christian Congregation of Jehovah’s Witnesses

What is worth noting is how this affects their targeted foreign language field. Jehovah’s Witnesses usually find foreign language speaking individuals by asking native speakers if such ones are living in their neighborhoods. Surely such targeted preaching will be affected by this policy change.

What we do know is that there will be no more surprises for householders as they will not be getting a return visit when they accepted a piece of literature just to get them off their door.

Spanish

Reglamento General de Protección de Datos (Bi)

Reglamento General de Protección de Datos (Es)

English

General Data Protection Regulation (Bi)

General Data Protection Regulation (Es)

Irish

An Rialachán Ginearálta um Chosaint Sonraí (Bi)

Zimbabwe

The letter was inadvertently released in Zimbabwe, a country not governed by GDPR. The error was quickly noted and a follow-up letter to elders in Zimbabwe was sent out. These are the two letters

General Data Protection Regulation (Zw)

General Data Protection Regulation letter (Zw)

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