Is Functions Data?

I think that functions are not data in the sense that they are opaque. I mean, you cannot know a priori what is going to be the output for an input. Now that's true in like a Turing complete language, but actually there are some languages I'm thinking immediately of DAL by Gabriela Gonzalez which is basicallylanguage designed for generating like configuration files and stuff like that. And it does not support general recursion or any other constructs that basically you can't write a dull program with.