Lee Gatiss has borne false witness throughout his document about me and my family. That much has been demonstrated repeatedly on this blog. For him to continue as a senior leader in ministry without repentance is a disgrace. But the same applies to the other senior leaders who are complicit with him – starting with the members of the Church Society Council who took the decision to publish and widely circulate lies about me and my family.
As an example, one such Church Society Council member and a Trustee of Church Society is Rebecca Hunt, a trained barrister. I recently discovered that Rebecca works for Christian Concern / the Christian Legal Centre and was made one of its company directors in 2021. This was after Rebecca Hunt had unlawfully withheld and unlawfully shared my personal data, and after she had been part of the behind the scenes dishonest and derogatory discussions about me at Church Society. It was also before the Church Society senior leaders said that there would be an independent investigation into the matters that I had raised, but then instead published their slanderous report.
This shocked and saddened me because I had long considered Christian Concern to be different from some of the other evangelical organisations in the UK – in other words, I have viewed Christian Concern as wanting to operate with integrity. My husband and I currently support the organisation. However, a Christian organisation should not be working with those who take part in bullying and slander, disregard the law, withhold information that an individual is entitled to, share personal data with others, refuse to act transparently, or go back on their word.
Below is an item of my personal data, redacted and (eventually) sent to me by Church Society. The red annotations are mine. It is an email dated 1 August 2019 to other Church Society senior leaders from Rebecca Hunt that shows she was directly involved in the Church Society conversations about me.
In the first paragraph, Rebecca mischaracterised the problem as being the situation in a parish, rather than the behaviour – bullying, threatening, dishonest, unkind – of the Church Society senior leaders towards me. In her second paragraph, Rebecca speaks of “wanting to be seen to be doing anything but covering anything up”, even though cover up is exactly what the senior leaders were trying to do.
In her third paragraph, Rebecca suggested using her “Christian friend” to help with “an independent investigation”. As a trained lawyer, Rebecca Hunt should certainly know that for an investigation to be independent, any investigator would have to have no prior association with any of the parties involved, and should certainly not be a friend of any of them. The woman that Church Society put me in touch with was indeed the “friend” that Rebecca had recommended. Rebecca suggested that the important point of the investigation should be to find out what I was “trying to achieve” (surely irrelevant?), rather than to investigate the behaviour of Church Society’s people towards me and my family. Rebecca Hunt then minimised the issues I was raising and mischaracterised my reasonable comments as “lashing out”, before questioning my mental stability. At the end of her email, Rebecca again wrongly suggests presenting the use of her friend’s services as an “independent investigation”; this lacks integrity.
In my dealings with Church Society, which began in 2018, I had gradually become aware that the senior leaders were not acting in a straightforward manner towards me and my husband. Eventually in 2020, my husband and I put in a Subject Access Request to Church Society in order to receive a copy of the personal data that they held on us. All organisations/data controllers have to comply with the Data Protection Act 2018, so a Subject Access Request to an organisation from a person wishing to be provided with that person’s own personal data is a perfectly legal and reasonable action, not as the Director of Church Society would have it in his document about me, a “very unfamiliar and unusual process”. As the Information Commissioner’s Office says on its website: “Your data is your data. It belongs to you so it’s important your data is used only in ways you would reasonably expect, and that it stays safe. Data protection law makes sure everyone’s data is used properly and legally.” https://ico.org.uk/for-the-public/ . Organisations are by law supposed to comply with a Subject Access Request within 30 days, but it took over six months for Church Society to send my personal data.
It was not until much later that I discovered that Rebecca Hunt was the Church Society Council member who was handling the SAR. At first Church Society responded to the SAR sending only our membership forms. I wrote back (as the ICO suggests) to complain that Church Society had not fulfilled their legal obligations in responding to the SAR and I then received the following email. The “appropriate advice” mentioned came from a trained lawyer, Rebecca Hunt.
Rebecca Hunt was clearly aware of the Information Commissioner’s Office website because the email from Church Society directed me there. In fact the ICO website contains very clear and simple guides for organisations about their obligations under the DPA 2018 and the UK GDPR including how to respond to Subject Access Requests. https://ico.org.uk/for-organisations/ A trained lawyer should really not have any problem understanding how to deal correctly with a SAR. As Church Society was clearly withholding my personal data, I complained to the ICO and although they had a backlog to deal with, they eventually looked into the issue, agreed that Church Society had not complied with the Subject Access Request and required Church Society to comply properly. The ICO wrote to Church Society on 15th September 2020.
As I had not heard from them, I wrote to Church Society to again ask them to supply my personal data. Church Society agreed to do this and I then pointed out that our personal data would include email conversations about us or minutes of meetings where we had been discussed. The following day I then received an email with a message from Rebecca Hunt asking me to have a conversation with me. This was the first time I had been made aware that it was Rebecca handling the SAR and I did not have any means of contacting her, except through Church Society. As other senior leaders at Church Society had used telephone calls to intimidate me and my husband or to say things that were later denied, I did not think that this was a good idea. I also wondered why Church Society did not simply comply with the SAR as the law required.
I therefore wrote back to say that my husband and I would prefer to keep things in writing.
Church Society sent some of our personal data to us, attached to the email below from Rebecca Hunt, which showed that she had been responsible for withholding my personal data for so many months. I was not clear why she signed herself off as “Barrister”, unless she felt that it had particular relevance to the situation, but I did feel intimidated and I did wonder how a trained lawyer could so mishandle something as straightforward as a Subject Access Request.
Rebecca’s sentence “You will understand that I had to be very mindful of our obligations to protect the data of third parties in this” is very misleading given that names could easily be redacted. There was no apology from Rebecca for withholding our personal data for so long.
The sentence in Rebecca’s email “I trust that you will respect the confidentiality of this material” is also bewildering. Given that the data that she was attaching had already been redacted by Rebecca and was my personal data to do with as I wished, why would she ask me to keep it confidential? A lawyer would understand that she had no right to do this. The only reason could be that Church Society would not want the information to be made public. It lacked integrity on Rebecca Hunt’s part for her to try to tell me that the material was confidential.
Church Society wrote again on 28th September 2020 and sent some more of our personal data that they held – emails that we had sent to them in 2018. As the personal data that had been sent to me thus far was both inaccurate and incomplete, I wrote back to Rebecca via the Church Society admin email address to explain and ask that they comply properly with my Subject Access Request, as the law requires. I wrote on 28th September 2020 and was again told that Rebecca wanted to speak with me, although I had already asked for communication to be in writing.
I wrote again on 9th October 2020 and was told that my email was forwarded to Rebecca. I heard nothing from her so wrote again a week later on 16th October 2020 to ask for an update and was again told that my email would be forwarded to Rebecca. Still I heard nothing and asked again for an update on 30th October 2020 and then 5th November 2020. It had been well over six months since I had first asked for my personal data and yet organisations are supposed to comply within 30 days.
Finally I went back to the Information Commissioner’s Office to ask them for advice, as Church Society had still not provided me with my own data. The ICO were helpful and asked me to write what had happened in an email so that they could take action. They again wrote to Church Society to require them to comply with the law, as the email below shows.
Church Society finally sent most of my personal data on 20 November 2020, although some followed even later. Some of the emails sent were illegible, which the law does not allow. There were redactions that are not allowed by law either, e.g. the redaction of an adjective describing one of my emails. The ICO has been very clear that organisations are not permitted to redact just because what has been written about a person might embarrass the writer or the organisation.
Church Society sent me and my husband our personal data via a Dropbox link, which I had agreed to as long as it was secure. The reason for providing our data in this way was because there was so much of it, i.e. a vast amount of discussion about me and my husband and what to do about us, most of it in the form of emails sent between various senior leaders of Church Society, including Rebecca Hunt. It was also clear from why Rebecca Hunt had withheld our personal data for so long. Contrary to her justifications to the Information Commissioner’s Office, there was nothing “sensitive” or “highly confidential”, at least not as far as my husband and I were concerned, because we have a legal right to see what is being written about us and held as data by organisations. What Rebecca deemed “sensitive” and “highly confidential” was merely emails between senior Church Society leaders that cast them in a bad light and were embarrassing to them. The data revealed derogatory, inaccurate and slanderous comments about us by these senior Christian leaders, and a complete lack of integrity in their dealings with us. That is what Rebecca Hunt had withheld from us. I raised all this with Rebecca Hunt and Church Society for their attention, but they did not address the issues. By law, the data that organisations hold about individuals has to be accurate and truthful, but Church Society had failed to do this also.
I then noticed that others had been given access to my personal data in the Dropbox. This included Lee Gatiss, Ros Clarke, Andrew Towner and Rod Thomas. Andrew Towner and Rod Thomas did not even have Church Society email addresses. Given that they had engaged in bullying me, this was intrusive and intimidating. It also falls foul of Data Protection law. Why had Rebecca Hunt allowed my personal data to be unlawfully shared with others, especially when she had withheld my personal data for so long?
I asked Rebecca Hunt to confirm all those who had been given access to my personal data. She never did respond to that, but I did finally receive an email from her on 4th December 2020 via the Church Society admin email address and was stunned by the lack of integrity in what she had written.
In her email, Rebecca described complying with the Subject Access Request as “an enormous amount of work”, although she herself had chosen to take on the responsibility of overseeing the SAR. Moreover, the reasons for the SAR being “an enormous amount of work” are Church Society’s own fault: the Council members and trustees used non-Church Society email addresses (in itself a data protection risk!) so Church Society had to ask them to supply their data; the vast amount of discussion about me and my husband by Church Society senior leaders over a long period, including many unnecessary derogatory and defamatory comments and the inappropriate sharing of information – this created a huge amount of data; a lot of email communication about us generated by the lack of policies and procedures that one would expect a registered charity to have; the fact that if Church Society had treated me decently in the first place, I would not have felt the need to put in the Subject Access Request.
In her email, Rebecca also untruthfully described “the efficient administration of the task as swiftly as possible”, when in fact her response had been neither efficient nor swift, and had taken over six months instead of the one month allowed.
Rebecca’s explanation for the unlawful sharing of my personal data is also disingenuous. The Dropbox provided to me did not contain others’ personal data as it had already been suitably redacted before it was provided to me. What it did do was to share my and my husband’s personal data (with our names) with the other people who accessed the Dropbox. If the others had wanted to see their personal data held by Church Society, the correct procedure for them would have been to put in their own Subject Access Request – not to be given access to my personal information. Rebecca speaks of being “obliged to take the privacy of all concerned into account”, although she and the other Church Society leaders had shown a complete lack of concern for my and my husband’s privacy, both in terms of the Dropbox and in terms of the many email conversations about us where untrue things were said and inappropriate comments made. Nor is it plausible that she would not have realised that the others given access to the Dropbox would be able to access all the data – this is immediately obvious from looking at Dropbox, but in any case, it was Rebecca Hunt’s responsibility to make sure that my personal data was provided securely and only to me.
Unbelievably, Rebecca Hunt again finished her email reminding me to “respect the confidentiality of third parties”, although the data provided had already been redacted by Rebecca herself and was my own personal data to do with as I wished. I understood why she wanted me to keep the information confidential, given that it showed many of the senior leaders of the Church Society/ReNew constituency in a poor light. However, it lacked integrity for her to try to impose confidentiality on me. I had never undertaken to keep the information confidential and in fact it is important for Christians in this constituency (and elsewhere) to know if the senior leaders of it are behaving without integrity.
When I subsequently raised the issue of the Dropbox with the Information Commissioner’s Office, the ICO agreed with me that Church Society had unlawfully shared my personal data with others. They wrote to Church Society requiring the organisation to comply with the law and to devise an action plan to convince the ICO that they, Church Society, were going to respect the data rights of individuals in the future and to take their data protection responsibilities more seriously.
An organisation withholding information that an individual is entitled to, or inappropriately sharing information about an individual, is a well-documented method of bullying by organisations towards less powerful individuals. This is exactly how Church Society as an organisation treated me and my husband, under the direction of Rebecca Hunt.
However, Rebecca Hunt’s direct involvement in Church Society’s dishonest behaviour and power abuse towards me was not just limited to her part in the publication of a slanderous document that made me ill. Nor was it limited to her part in the dishonest and unkind discussions about us. Nor was it limited to her unlawfully withholding and then unlawfully sharing my personal data. In early 2021, Church Society suddenly announced that they were going to have “an independent review” into my “allegations”. The Chair of Church Society Council Rev Andrew Towner wrote to me to tell me and invited me to ask any questions that I may have. This seemed strange coming from him given that he was one of the people who had been engaged in bullying me, and that so much of Church Society’s behaviour was a matter of written record. I emailed back on several occasions with a number of reasonable questions and comments, but could not get answers to them. Eventually I received the email below from Rebecca Hunt, telling me that it would not be appropriate for them to answer any of my questions.
Given Rebecca’s previous description of having her friend involved as an “independent investigation”, and indeed the other leaders’ attempts to present people they could influence as independent, I wondered what they meant by “independent” this time round. It also struck me as unacceptable that the very senior leaders who had abused their power against me, were now setting the terms of reference for a review without any transparency towards me.
In hindsight, given their behaviour towards me from the start, it is not surprising that the Church Society/ReNew senior leaders did not submit themselves to a genuinely independent investigation, but instead marked their own homework and published a defamatory and harmful document about me and my family.
After I had raised the issue of Rebecca Hunt’s behaviour on Twitter, she began to follow my account. Next, a mutual acquaintance got in touch to say that Rebecca was asking for my contact details. Rebecca told our acquaintance that there had been some recent social media mentions and “thought it would be a good idea to speak about it.” This is strange because I have already communicated to her twice that I would prefer to keep things in writing, and she has failed to answer my reasonable questions. As I have explained above, spoken conversations are often not used with integrity by the senior Church Society/ReNew leaders. Frankly I find them triggering. In addition, Rebecca is well aware of how she has behaved. It is a matter of written record, as I have shown in this blog post. Rebecca knows that she unlawfully withheld and then unlawfully shared my personal information. She knows that she has been dishonest. She knows that she has spoken about me in a way that a Christian should not. She knows that she was part of the bullying towards me. She knows that she and others published a slanderous and harmful document. Rebecca does not suddenly now need a telephone conversation with me. She needs to address her behaviour. For a Christian in a senior position, this would surely mean a public acknowledgment of her wrong behaviour and her resignation from her various posts for Church Society and Christian Concern. If Rebecca genuinely needed to communicate with me, she could write to me, although I should make clear that I would not undertake to treat her communication as private and confidential.
For some of the other senior leaders of Church Society also – there is a choice. Will they admit their behaviour without fudging or minimising it and repent? Given the public nature of their actions and their seniority, this repentance would need to be public. For them to truly repent would also require a lot of work to put things right, given the harm they have caused.
For Christian Concern/The Christian Legal Centre, there is a choice too. Will they have those who have behaved dishonestly and abused power working for them and so compromise their witness as an organisation? Or will they as Christians choose integrity?