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ARTICLE · 10 JUNE 2025

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EDPB Guidelines Raise Questions On How GDPR Interacts With Blockchain

William Fry LLP
William Fry LLP
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William Fry LLP

William Fry LLP

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On 14 April 2025, the European Data Protection Board (EDPB) opened its public consultation...

IrelandTechnology
John O'Connor
John O'Connor
Rachel Hayes
Rachel Hayes
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On 14 April 2025, the European Data Protection Board (EDPB) opened its public consultation on its guidelines for the processing of personal data through blockchain technologies (the Guidelines).

As we rapidly approach the end of the public consultation phase, on 9 June 2025, we take a quick look at what the Guidelines might mean for those using blockchain to process personal data.

GDPR & Blockchain

The EDPB flags from the outset that, for the application of GDPR, the metadata which blockchains store, while pseudonymised and offering a high level of security, may contain identifiers (such as a public key, and blockchain addresses) which could be used to indirectly identify a natural person when used with other, additional identifiers. The EDPB further stresses that blockchain is simply a technology like any other, such as cloud computing or peer-to-peer networks. As a result, there is no immediate exemption for blockchain from the rules on the processing of

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