EU Blockchain Forum publish “Blockchain and the GDPR” paper

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The EU Blockchain Forum, an EU forum set up to ” accelerate blockchain innovation and the development of the blockchain ecosystem within the EU, and so help cement Europe’s position as a global leader in this transformative new technology”, has just published a “thematic report” on how blockchain technology fits with the principles and laws of the General Data Protection Regulation (GDPR).

If you’re wondering what blockchain is then the report provides a helpful summary (in its appendices) but essentially it’s a peer-to-peer distributed database system, where multiple devices can be used to store the database without centralised control.

The report highlights a number of tensions between GDPR and blockchain:

  • Identification of, and therefore responsibilities of data controllers and processors
  • The anonymisation of data within the blockchain environment
  • The exercise of some individuals’ rights

And whilst the Forum doesn’t pretend to know the answers, indeed suggesting only the EDPB, courts or governments/regulators are in a position to resolve these issues, it does suggest four “rule-of-thumb principles”:

  1. Start with the big picture: how is user value created, how is data used and do you really need blockchain?
  2. Avoid storing personal data on a blockchain. make full use of data obfuscation, encryption and aggregation techniques in order to anonymise data
  3. Collect personal data off-chain or, if the blockchain can’t be avoided, on private, permissioned blockchain networks. consider personal data carefully when connecting private blockchains with public ones
  4. Continue to innovate, and be as clear and transparent as possible with users.

Maybe this is something we’re going to see addressed in future work the ICO do around various technological advances, along with big data, AI and data ethics.

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