Framework Utilizing Ethereum Architecture Suggested for GDPR Compliance

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Recommendations have been put forward for adhering to the European General Data Protection Regulation (GDPR) within public blockchains. The technological basis is rooted in developments from Ethereum.

Framework Utilizing Ethereum Architecture Suggested for GDPR Compliance0

The European Blockchain Association (EBA) has presented a consultative document to the European Data Protection Board (EDPB) detailing how Ethereum’s modular architecture and related technologies can facilitate compliance with the General Data Protection Regulation (GDPR).

GDPR mandates that personal data be stored with the ability to delete it, managed by specific data subjects, and adequately anonymized. This requirement poses challenges to the inherent characteristics of public blockchains, such as immutability, transparency, and decentralization.

The suggested framework distinctly outlines the responsibilities of data controllers and processors across various transaction processing layers, specifically:

  • Execution Layer, where transactions are initiated from dApps and wallets;
  • Consensus Layer, which is accountable for block finalization;
  • Data Availability Layer, offering scalable data storage solutions.

In this framework, dApp providers act as data controllers, while block builders and validators work with encrypted or abstracted data, ensuring they do not access personally identifiable information (PII). Storage nodes implement a model of temporary retention of anonymous data segments.

The document also emphasizes the significant application of privacy-enhancing technologies (PET):

  • zk-SNARKs and Fully Homomorphic Encryption (FHE) facilitate transaction verification without revealing data;
  • Proto-Danksharding and PeerDAS enable short-term, fragmented, and anonymous data storage;
  • Proposer-Builder Separation (PBS) distinguishes access to transaction details from block finalization activities.

This proposal illustrates how existing architectural solutions and PET tools can provide a basis for GDPR compliance in open decentralized settings. Consequently, the framework does not necessitate compromising the fundamental principles of public blockchains but indicates that Ethereum and similar distributed ledger technologies (DLT) can potentially conform to GDPR, provided suitable technical adjustments are made. This strategy may be particularly pertinent as Ethereum establishes itself as a foundational infrastructure for online initiatives and the global economy.

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