@phizzy this is interesting.
Could it be the congregation is under the Act? Since such information is stored in the congregation confidential file.
I have raised the issue of how data is stored in congregation and what measures are taken to protect my data. Still waiting for answers.
As for US HQ, i think they will be in big trouble if they do not get their GDPR (General Data Protection Regulation) for every EU national done properly.
link to information if interested related to charities: https://www.theguardian.com/voluntary-sector-network/2017/may/05/gdpr-charities-prepare-eu-data-protection-changes-consent-fundraising