As Chief Elf Officer, it is my job to present the end-of-year report for the worldwide Santa organisation.
It has been a tough year, with regulatory changes and constantly shifting tariffs and borders. Somehow, we have made it through largely unscathed. Most of us are now longing to put our feet up with the mince pies Santa brings back for us, and hoping for a few glasses of brandy (alcohol-free for those who prefer it that way) to wash them down.
We are running a little late, but here is my end-of-year report.
Naughty and Nice List Update
We continue to process children’s data – names, addresses, gift preferences, and behavioural assessments under the Naughty/Nice framework – with appropriate adjustments for neuro-divergence, language, and cultural context.
This has required the addition of health-related data and corresponding system upgrades. It is also far from the only information we process.
In practice, Santa processes personal data relating to:
- children
- parents and guardians
- helper elves (permanent, seasonal, and “helping out for a friend”)
- suppliers and logistics partners
- reindeer
- veterinary teams
- and several third parties who insist they are “just providing a platform”
Our previous data privacy policy still implied that Christmas was a much simpler operation than it has been for some time. To be honest, it had been a while since we reviewed it, and we were quietly hoping it would magically update itself. It did not.
For those interested, Santa’s earlier approach to data protection is set out in our previous Data Privacy Policy, which reflected a much simpler time.
The scale of our processing has increased. There have never been more children in the world than there are today, and many now live in places without chimneys, fixed addresses, or the infrastructure Santa’s original delivery assumptions were built around. As a result, some data was no longer accurate, and some “children” in our systems had, in fact, grown up.
The routes have multiplied.
The data has become more complex.
We rely on the Santa Nav system to find everyone, and that has created challenges of its own.
Christmas did not get bigger all at once.
It simply kept growing.
Two-Fairy Authentication System
To improve security, we introduced a Two-Fairy Authentication system (2FA).
This worked well over the summer while the flower fairies were active. Once winter arrived and they entered hibernation, responsibility passed to the Tooth Fairy and the Sugar Plum Fairy. They were quickly overwhelmed and, under pressure, some elves simply turned the system off
Abracadabra Incantation (AI)
We also explored the use of an Abracadabra Incantation (AI) system to help manage the growing volume of emails, letters sent up chimneys, and social media messages. Santa has been overloaded for some time, and there was concern that some children’s messages might be missed during the Christmas rush.
The newly appointed Data Prudence Oracle (DPO) immediately prepared a Consequences Assessment.
This identified, among other things:
- uncertainty over where letters would be stored
- whether content might be retained, reused, or incorporated into enchantment training
- the distinction between acknowledgement and response
- and the risk that parents might reasonably assume that Santa, rather than a spell, was replying
The Consequences Assessment was thorough, sensible, and circulated promptly.
Unfortunately, it coincided with final toy production sign-off, three separate reindeer-related incidents (the Santa Nav screen glow closely resembles Rudolph’s nose, leading to widespread confusion), and a prolonged discussion about whether glitter is environmentally friendly.
As a result, the Consequences Assessment was not read.
During an unprecedented surge in letters, a well-meaning individual decided to activate the system anyway.
No one paused to ask three very ordinary questions:
- whether parental consent covered automated replies
- whether families were aware an enchanted system was responding
- or what would happen to the information afterwards
Cross-Border Implementation
Christmas is, by its nature, a global operation — covering not only the mortal world, but several other realms besides.
Letters arrive from multiple jurisdictions.
Elves work remotely.
Suppliers are internationally distributed.
Several systems operate in the “silver cloud”, which appears to exist everywhere and nowhere simultaneously.
The Abracadabra Incantation did not respect borders. No limits had been placed on the spells it used.
No one could say, with confidence, which workshop, elf, or enchanted forest held which information at any given point. While we know the trees talk to each other, we have no idea what they say or share. Even the Data Prudence Oracle required additional time to investigate and expressed concern about which Wizards were responsible for what.
Complaints from Parents
Unsurprisingly, some parents complained.
We were required to respond within a fixed timeframe, which meant pulling several senior elves away from operational duties at a busy time of year.
Parents threatened a mince-pie boycott if matters were not resolved.
Santa took this extremely seriously.
The reindeer were dispatched on a consent-clarification and fact-finding exercise across multiple regions and reported back to the senior team, Santa, and me.
Findings and Actions
Because the Two-Fairy Authentication system had been disabled, we cannot determine who activated the Abracadabra Incantation. Access credentials had been shared to save time, meaning there is no reliable record of who invoked which incantations.
We are addressing this by strengthening access controls and ensuring sufficient fairy support so elves can work efficiently without bypassing security.
The Abracadabra Incantation now sits behind a clear consent notice explaining what it does and linking to a revised Data Privacy Policy. Its settings have been adjusted to restrict cross-border transfers and limit the categories of data it can collect and share.
Missing data was retrieved from the Silent Forest, which, fortunately, was not communicating with anyone else at the time.
Data now remains where Santa expects it to be.
Cross-border routes have been mapped.
The original Consequences Assessment has been re-circulated and read.
The Data Privacy Policy has been updated to reflect reality rather than tradition.
Complaints procedures now exist in a form that can be located without guesswork (previously, complaints relied on a mixture of hope, magic, and the occasional obliging reindeer, which was not a robust system).
A new AI policy now sets out what may be incanted, by whom, and with whose knowledge and agreement.
We have self-reported to Krampus and the ICO — the respective Naughty Step enforcers for magical beings handling data. We are hopeful that, having identified and addressed the issues promptly, they will be merciful.
Parents have been updated, and mince pies have been reinstated.
The Incantation & Technology (IT) department has agreed to restrict system access by role and not to activate new magical devices until a Consequences Assessment has been signed off by the Chief Elf Officer and the Data Prudence Oracle (sometimes, unkindly, referred to as the Data Potions Oracle).
Magic remains a core part of Christmas.
Magical thinking, however, is not a lawful basis for introducing AI or collecting and sharing data.
Season’s Greetings
Christmas is not cancelled.
The sleighs are almost ready.
The reindeer are fit for work (subject to final adjustments to the Santa Nav system).
The elves are back at their benches, catching up.
If, as the year draws to a close, you suspect that:
- your own festive bots have become a little over-enthusiastic
- your helpers or platforms are doing more with data than you realised
- or your paperwork still assumes a simpler, more innocent time
you are not alone.
Simply let us know.
The Chief Elf Officer is very tired, but still available to take a look — calmly, pragmatically, and without putting anyone on the Naughty Step unless absolutely necessary (regardless of beard length).
Or if you’d like to get going in the New Year when all those minced pies have been digested – we’d be happy to magic up some support for you when you’re ready.
