Data Capital: 'Twas the byte before Christmas

Visiting the North Pole to interview Santa Claus about data is everything I’d hoped it would be – and more. The smell of the fresh wood shavings as one of the elves leads me through the workshop to Santa’s office, the sound of the reindeer gently grunting out in the stables, the snatched glimpses of sacks of toys being loaded onto a sleigh.

As I’m ushered into Father Christmas’s office, I have a brief flashback to the first time I was summoned to the editor’s lair – that same mixture of fear and excitement, wondering whether it was that naughty spelling mistake or that nice bump in online subscribers that had attracted the boss’s attention.

Naughty and nice were clearly on Old Saint Nick’s mind too. “I’ll be with you in a minute,” he mouths, as he wraps up a call with someone named Geoff in accounting. While he’s distracted, I glance around the room and scribble down some quick notes in my best shorthand.

On the wall behind Santa’s massive oak desk, three giant computer screens display the infamous “naughty” and “nice” lists. Maya and Seth are safely ensconced in the “nice” column, while Imogen is languishing firmly on the “naughty” side, and Olivia is teetering on the central “To be decided…” screen.

“Sorry about that,” mutters Santa as he tosses his Bluetooth headset onto his desk and waddles around to shake my hand. As he lowers himself into an armchair by a crackling fire, he strikes me as a quaint mix of Lloyd Bridges’ president in Hot Shots: Part Deux and every character ever played by Brian Blessed.

“Using data has transformed the run-up to Christmas Eve for me,” admits the white-bearded hero in between bites of a mince pie and long slugs of eggnog. “Now I can spend Advent watching reruns of Hallmark movies and pinching the pink strawberry chocolates from the tub of Cadbury Roses when Mrs Claus isn’t looking.

“I got the idea to start using data after Norad began tracking my sleigh back in the 1950s,” he adds, referring to the reports issued on Christmas Eve by the North America Air Defense Command and its predecessor, Continental Air Defense Command (Conad).

Santa is quick to deny internet rumours that the tracking may soon be outsourced through a digital transformation programme to the private sector’s Global Air Defense Command Services.

“When the global positioning system (GPS) came along in the 1990s, it made it so much easier to navigate,” Santa remembers. “Before that, I always had to take one of the elves with me to read the map and call out directions.

“I had to start lashing the elves to the handlebars of the sleigh after we lost Snowflake somewhere over Ayrshire back in ’75. Terrible business – you wouldn’t believe the paperwork you have to fill-in when a magical creature gets blown away.”

Santa points to advances in information science in recent years and the wider availability of high-quality data. “Getting accurate climate change predictions from the Met Office has been a game changer,” he admits.

“Now I know where it’s safe to park the sleigh and where there’s a risk of excessive snowfall. I’ve got it all on an app on my phone,” he adds, whipping out a sleek Apple iPhone 24 Pro from within the folds of his red-and-white suit and showing me a series of interactive maps.

As well as navigation and route planning, data is also being used behind the scenes to increase efficiency in St Nicholas’s North Pole workshop. Another phone app presents Father Christmas with a data dashboard to monitor consignments, while algorithms powered by machine learning analyse the information to optimise the system.

“A good compliance framework is essential to help Santa sleep at night – that means having appropriate policies and procedures and training in place to ensure that all the elves know how they should be handling personal data, how to keep it secure, and what to do if there is a personal data breach,” points out Martin Sloan, a partner who specialises in intellectual property, technology, and data at law firm Brodies.

“Given the scale of his operations, Santa will also likely need a data protection officer. Santa will also need to ensure that he has carried out appropriate diligence on any service providers that he uses – for example, IT systems, and cloud-based software used for route planning.”

The need for good data management extends beyond Santa’s supply chain. While Christmas Eve might be his busiest night of the year, data gathering begins on Boxing Day, with a vast array of screen-scraping bots and application programming interfaces allowing him to track trends long before the DMs start sliding into his inbox.

However, his careful, data-driven planning can be knocked sideways by unexpected political developments. “Brexit was a pain in the bowlful-of-jelly,” Father Christmas admits with a sad nod. “Boris was definitely on my naughty list that year.”

Even after the UK left the European Union, a domestic version of its general data protection regulations (GDPR) remains in place. And being located in the frozen north is no excuse for not complying.

“Even though Santa is based at the North Pole, he’s still subject to UK GDPR if his subjects are here and if he’s processing their data here,” explains Adam McGlynn, an associate in the employment team at Acuity Law.

“Now that the Retained EU Law (Revocation & Reform) Act has received royal assent, government ministers have the powers to change or revoke laws – we’re expecting some statutory changes at the end of the year, so it’s worth keeping an eye on what might change.”

If Santa is using social media to assemble his naughty and nice lists, or to look at people’s preferences for presents, then the big man needs to make sure he’s minimising the amount of data that he collects and processes.

“Does he need every single post and every single picture, or does he just need a select few details from social media to understand present preferences?” asks McGlynn.

There’s a knock at the door, and one of the elves scurries back into the office, before intimating in a loud stage whisper that Santa’s three o’clock is waiting in reception. With a supreme effort, Father Christmas hoists himself out of his comfy chair and shakes my hand.

As I’m ushered from his inner sanctum, Santa returns to his desk, but not before asking Alexa to play Sheena Easton’s 1985 classic It’s Christmas All Over the World.

As the seasonal sound of Bellshill’s finest fills the office, I catch a glimpse of Father Christmas tapping his toes before the elf closes the door behind us, and the spell is finally broken.