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Asked: February 2, 20222022-02-02T14:51:55+01:00 2022-02-02T14:51:55+01:00In: GDPR

Who is the data controller when storing data in a blockchain? (immutable distributed data store)

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Who is considered the data controller when storing pseudo-anonymized personal data in a blockchain? I.e. an immutable distributed data store. Related question: https://watercooler.community/question/storing-pseudo-anonymized-personal-data-on-a-blockchain

Is it the application that collects the data and writes the transaction to the blockchain?

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    1. DP-Pro

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      2022-02-09T10:40:09+01:00Added an answer on February 9, 2022 at 10:40 am

      There is a lack of consensus as to who is a controller / joint controller, further confounded by what processing is being undertaken on a given dataset at any one time. Blockchains, involve many different players and is unlikely to be an entity (and ergo a controller), in and of itself. You will need to apply the GDPR (and EDPB) definitions of controller to each blockchain you encounter, on a case-by-case basis. You know the familiar phrase – ‘There is no one-size fits all’! As an entity placing said data onto a distributed ledger, you are a (de facto) controller, but do you remain so, given the dilution of your powers?

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