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CS Professional · Artificial Intelligence, Data Analytics and Cyber Security - Laws and Practice · Internet and Other Technologies

A company wishes to record shareholder register entries on a blockchain. Considering the immutability feature and the right of a data principal to seek erasure of personal data under data protection law, what is the main compliance concern?

The main concern is that immutability makes correcting or erasing personal data stored directly on-chain very difficult, conflicting with data principals' rights. A typical solution is keeping personal data off-chain in erasable storage and recording only hashes or references on the blockchain.

  1. ABlockchains cannot store text data at all
  2. BImmutable on-chain personal data may be difficult to erase or correct, so personal data is better kept off-chain with only hashes recorded on-chainCorrect
  3. CImmutability automatically satisfies every erasure request
  4. DErasure rights apply only to paper registers

Explanation

Immutability conflicts with correction and erasure obligations when personal data sits directly on the chain. A common design keeps personal data off-chain and stores only a hash or reference on-chain. Blockchains can store text, and erasure rights are not limited to paper.

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