Pseudonymity, Automation, and Responsibility on Public, Permissionless Blockchains under the GDPR

  • Panel
  • Café
  • Thursday 21.05 — 08:45 - 10:00

Organising Institution

European Ethereum Institute (EEI)

Europe

  • Academic 2
  • Business 2
  • Policy 2
Public, permissionless blockchains increasingly function as foundational digital infrastructure, yet they sit in tension with key interpretative assumptions in EU data protection law. Recent developments-particularly the EDPB’s draft Guidelines 02/2025 and the European Commission’s Digital Omnibus proposal-have exposed structural frictions around pseudonymity, automated processing, and the allocation of responsibility in decentralised systems. These tensions mirror broader doctrinal concerns already recognised by the Court of Justice, notably in the EDPS v SRB case. This panel interrogates whether current GDPR interpretations can be meaningfully extended to protocol-level blockchain activity. Using Ethereum as an example of widely deployed public infrastructure, the discussion brings together legal, policy, and infrastructure perspectives to examine the limits of existing interpretative approaches and to consider how EU data protection rules can remain enforceable while accounting for the realities of decentralised infrastructure.

Questions to be answered

  1. How should personal data be interpreted in the context of public, permissionless blockchains, where protocol design deliberately limits influence over data processing?
  2. What governance and enforcement risks arise if data protection interpretation extends responsibility beyond factual influence, obscuring distinctions between decentralised and centralised infrastructure?
  3. How do recent approaches to defining personal data align with the principles articulated in EDPS v SRB?
  4. Can protocol-level blockchain execution be understood as “automated processing” under the GDPR, given the absence of centralised setting and decision-making?

Speaker

Vyara Savova

European Ethereum Institute (EEI) - Europe