If by ‘data’ you mean any symbolic representation, then yes — we can use data to refer to anything in memory/on tape. But programs are ‘operational data’ — clearly there is a difference between the passive raw data ‘3’ and the active data ‘count 3 [2, 4, 8, 3, 2, 3, 1, 0]’. The evaluation of ‘3’ is ‘3’ — but the evaluation of ‘count 3 [2, 4, 8, 3, 2, 3, 1, 0]’ is 3 — new data, and a new position on the tape, a new state, etc. So passive raw data and active programs are ontologically/metaphysically different type of data… Active data needs an “interpreter” (mind) to evaluate it— otherwise, it is again just passive raw data. My reference to data in the post is to passive raw data.