Your personal data among Jehovah’s Witnesses

Recognizable questions

- I was never asked whether Jehovah’s Witnesses could keep data about me. Are they actually allowed to do that?

- What do elders know about me?

- Are conversations about my personal life recorded somewhere?

- What information is passed on when I move to another congregation?

- Can information about something that happened years ago still play a role later on?

- Can I see what is being kept about me?

- And if I’ve become inactive or left Jehovah’s Witnesses: can I ask for my data to be deleted?

Many people may hardly give it a thought as long as they actively participate in the congregation. You become a publisher, a Publisher Record is kept, elders provide pastoral care, and when you move, certain information goes with you to your new congregation.

But what data is this actually about?

And perhaps even more fundamentally:

Did you ever give your permission for this?

I was never asked whether I agreed to this. Is that allowed?

Perhaps you can’t remember anyone ever asking you:

“Do you consent to personal data about your faith, spiritual status, field service and congregation-related situation being recorded and processed?”

Yet the absence of such explicit consent does not automatically mean that processing your personal data is unlawful.

Under the GDPR, consent is not the only possible legal basis for processing personal data.

That is especially important in a religious organization. Information that reveals your religious beliefs falls under the GDPR’s special categories of personal data. Stricter rules apply to that. At the same time, the GDPR contains a specific possibility for non-profit organizations with a religious purpose to process such data under conditions in the context of their legitimate activities. Among other things, this must involve members, former members, or people who have regular contact with the organization, and appropriate safeguards must be in place.

Jehovah’s Witnesses explain in their own Dutch privacy statement which legal basis they use.

It states that they generally do not process personal data on the basis of consent, because they are usually able to rely on another legal basis.

For publishers, they cite as a basis, among other things, their legitimate interest in maintaining and managing the religion and religious activities of Jehovah’s Witnesses.

So the absence of a signature does not automatically mean that data processing is prohibited.

But the opposite is also important:

The fact that you are a Jehovah’s Witness or a publisher does not automatically mean that every possible record, every retention period, or every transfer of personal information is thereby justified.

The rules of the GDPR must be followed when processing data.

So the relevant question is not only:

“Did I ever give consent for this?”

but also:

“What data about me is being processed, why is it needed, on what legal basis does this happen, how long is it kept, and who gets to see it?”

Jehovah’s Witnesses: by becoming a Witness, you agreed

There is an interesting formulation in Jehovah’s Witnesses’ worldwide data protection policy.

It says that the exchange of personal data between branch offices only takes place when this is necessary for religious and charitable purposes. The organization then states that all Jehovah’s Witnesses have agreed to this by their voluntary decision to become Jehovah’s Witnesses and identify themselves as such.

That may raise an interesting question:

Is choosing to become a Jehovah’s Witness the same as separately consenting to every processing operation involving your personal data?

Legally, those are not necessarily the same thing.

This is actually clear from Jehovah’s Witnesses’ own Dutch privacy statement. It explains that the organization generally processes personal data not on the basis of consent, but usually relies on another legal basis.

It is therefore important to distinguish between what an organization itself describes as agreement to its way of working and “consent” as a specific legal basis under the GDPR.

What data do Jehovah’s Witnesses keep about you?

Jehovah’s Witnesses’ Dutch privacy statement mentions several types of data.

Basic data

For example:

• name, date of birth, gender.

Contact details

For example:

• address, email address, phone number, emergency contact details.

Spiritual information

Jehovah’s Witnesses include, among other things:

• baptism date, “anointed” or “other sheep,” roles and assignments within the congregation or organization, field ministry activity, spiritual status, dates associated with that status, similar information about someone’s spiritual well-being.

The organization also states that personal data may come directly from you, but also from publicly available sources or from others.

That last point is interesting.

So information about you may be processed that you did not provide directly yourself.

Pastoral care and introduction letters

For pastoral care by elders, the Dutch privacy notice mentions basic details, contact details, spiritual information, and religious beliefs.

When it comes to retention periods, introduction letters are also explicitly mentioned.

According to the Dutch notice, these are kept according to local retention policy. Other data for pastoral care is kept as long as necessary for the purposes.

The public privacy notice does not specify exactly what personal information is included in each individual introduction letter.

So we cannot say that every past wrongdoing, every family problem, or every conversation with elders automatically ends up in such a letter.

But you can ask what has been recorded about you personally.

What happens when you move to another congregation?

When you move, you do not necessarily start completely from scratch administratively.

Jehovah’s Witnesses themselves state that when a publisher chooses to move to another congregation, their basic details, contact details, and spiritual information are passed on to the new congregation.

In some cases, the branch office also processes personal data to continue participation in religious activities and the congregation’s administration. The notice also explains that under certain circumstances data may be transferred outside the EU/EEA, with the safeguards mentioned there.

That raises an interesting question:

What does a new congregation already know about you before it has truly gotten to know you?

Why is information shared?

There are understandable reasons why a religious organization keeps and transfers information.

When someone moves to another congregation, for example, it can be useful to know that the person is baptized, what responsibilities they have, and what their current congregation situation is.

Continuity of pastoral care can also be a reason.

From the organization’s perspective, administration can therefore help to continue responsibilities and support.

But the same transfer of data can also have another side.

How long does your past travel with you?

For someone, there can be a big difference between administratively recording a current status and keeping or passing on very personal events from the past for a long time.

Think, for example, of possible information about:

• a past pastoral or disciplinary matter;

• relationship or marital problems;

• family conflicts;

• past limitations or responsibilities within the congregation;

• previous conversations with elders;

• someone’s spiritual situation.

That does not mean that all of this information is routinely stored about every publisher or included in every introduction letter. The public privacy notice is not specific enough for that.

But when such information is processed about you, you may wonder:

Why is this still being kept?

Is it still necessary for the original purpose?

Who can read it?

Has it been passed to another congregation?

How long is it kept?

And where did information come from that I never provided myself?

You do not have to guess.

You can ask to inspect it.

A practical example: personal information moves with you

An experience within a family shows why these questions can matter.

A sister who had not had contact with her mother for years moved to another congregation. In her new congregation, it was known that she had broken off contact with her Witness mother. According to her family, this information had been passed on from the previous congregation.

Later, she and her husband were confronted about this by elders. According to those involved, the situation also played a role in the question of what privileges her husband could receive within the congregation, including giving talks. The lack of contact with her mother was seen as unchristian.

Ultimately, she resumed contact with her mother. According to her family, part of the reason was also that she wanted her husband to become eligible for privileges again.

This is a personal experience. It does not mean that every congregation acts the same way or that every introductory letter contains such information.

But the example does raise an important privacy question:

What personal information is necessary for pastoral care, and when does information from someone’s past become more than is needed for that purpose?

How long are data retained?

There is no single retention period for all data.

For the Publisher Record, the Dutch privacy notice states, for example:

• active publishers: current and previous service year;

• inactive publishers: last active service year;

• people who are no longer Jehovah’s Witnesses: these specific data are not retained.

Different retention periods apply to other personal data.

For pastoral care, for example, it states that introductory letters are kept in accordance with local retention policy, and other related data for as long as necessary for the purposes.

You therefore cannot simply say:

“As soon as you leave Jehovah’s Witnesses, your entire file is destroyed.”

That does not follow from the public privacy notice.

If you want to know what still exists in your specific situation, you can request it.

What rights do you have under the GDPR?

You have various rights regarding your personal data.

Right of access
You can ask which personal data about you are being processed and request information about, among other things, the purpose, recipients, and retention periods.

Right to rectification
If personal data are incorrect, you can request correction under certain conditions.

Right to erasure
Under certain circumstances, you can request that personal data be deleted. This right is not absolute.

Right to restriction of processing
In certain situations, you can request that processing be temporarily or partially restricted.

Right to object
Jehovah’s Witnesses themselves state that when they process personal data on the basis of legitimate interests, you have the right, under certain circumstances, to object to that processing.

First request access, or have it deleted right away?

If you do not know what is being kept about you, first requesting access can be a logical step.

Then you may discover, for example:

• which personal data actually exist;

• which data your congregation keeps;

• whether personal data from an introductory or transfer letter are being processed;

• which data were passed on to another congregation;

• where data came from that you did not provide yourself;

• which retention period is applied.

You can then decide more specifically whether you want something corrected, want to object, or want to request deletion.

And if you are inactive or have left Jehovah’s Witnesses?

Being inactive and no longer being a Jehovah’s Witness are not the same thing in data administration.

This is shown, for example, by the different retention periods mentioned in the Dutch privacy notice for the Publisher Record.

Even if you are no longer a Jehovah’s Witness, you can still make use of the privacy rights that apply to your situation.

But do not automatically assume that everything has been deleted, or that everything is still being kept.

Ask.

A simple but important question is:

What personal data are you still currently processing about me, for what purpose, on what legal basis, and how long will this data be retained?

Template letter - access to and deletion of personal data

You can adapt this letter to your own situation.

Subject: GDPR request concerning my personal data

Dear Sir/Madam,

Under the General Data Protection Regulation, I request access to the personal data you process about me.

My details

Name: .............................................................................
Date of birth: .................................................................
Current or former congregation: .........................................
Previous congregation(s): ........................................................
Address: ..............................................................................
Email address: .....................................................................
Phone number: ................................................................

I request that you provide me with as complete an overview as possible of the personal data processed about me.

I would also like to receive information about:

• the personal data you currently process about me;

• the purposes for which this data are processed;

In particular, I request access to personal data which, if present, relate to:

• my baptism and congregation status;

• my current or former assignments or privileges;

• my field service activity;

• my spiritual status;

• pastoral conversations or pastoral care;

• personal or family circumstances;

• previous measures or restrictions within the congregation;

• any disciplinary matters;

• correspondence or notes containing personal data about me;

• introductory, recommendation, or transfer letters prepared about me or received concerning me.

Transfer to other congregations

If I changed congregations during my time as a publisher, I also request information about:

• which personal data about me were passed on to another congregation;

• to which congregation or other entity these were disclosed;

• for what purpose;

• if available, when this disclosure took place.

If an introductory letter, transfer letter, or similar document about me exists or has existed, I request access to the personal data about me contained in it, insofar as Article 15 GDPR entitles me to it.

Data I did not provide myself

To the extent that personal data about me were not collected directly from me, I would like to receive the information about their source to which I am entitled under the GDPR.

Erasure

For personal data that meet the conditions for erasure under Article 17 GDPR, I request deletion.

If you believe that certain personal data must or may be retained despite my request, I would like to receive, per category, information about:

• which data are being retained;

• why they are still necessary;

• on what legal basis the further processing rests;

• how long these data will be retained.

Objection

To the extent that Article 21 GDPR applies to a processing activity, I object on grounds relating to my personal situation to the further processing of my personal data.

I ask you to assess this objection and inform me of the outcome.

Further disclosure

I request that you do not further disclose my personal data to another congregation or other entity where there is no valid legal basis for doing so.

If you believe that further disclosure is lawful and necessary, I would like information about the personal data concerned, the purpose, the recipient or categories of recipients, and the legal basis.

I would appreciate a response to my request within the statutory period.

If my request is wholly or partially denied, I would like to receive a written explanation and information about my options to lodge a complaint with the Dutch Data Protection Authority or to use other legal remedies.

Yours sincerely,

Name: .............................................................................
Place: ............................................................................
Date: .............................................................................
Signature: ...................................................................

Tip: keep your submitted request and the response you receive. If you later want legal advice or wish to contact the Dutch Data Protection Authority, this will give you an overview of what you asked for and how it was responded to.

In closing

The fact that personal data are kept within a religious organization without you having separately signed a consent form does not automatically mean that the processing is unlawful.

But it also does not mean that you are not allowed to ask what is being kept about you.

Perhaps the question is therefore not only:

“Did I ever give permission for this?”

but above all:

“What do they know about me, why is it being kept, who has received it, and how long will it remain?”

The GDPR gives you rights that allow you to obtain more clarity about that.

You do not have to guess what has been recorded about you. You can ask.

Sources

JW.org - Use of Personal Data - Netherlands - updated March 21, 2025
JW.org - Jehovah’s Witnesses’ Global Data Protection Policy
European Union - General Data Protection Regulation - specifically Articles 6, 9, 15, 16, 17, 18 and 21
Data Protection Authority - Privacy rights under the GDPR