GBBC Submits Response to the EDPB’s Draft Guidelines 02/2025 on Processing of Personal Data through Blockchain Technologies

GBBC, with the support of its members, has submitted a response to the European Data Protection Board’s (EDPB) Draft "Guidelines 02/2025 on Processing of Personal Data through Blockchain Technologies."

We welcome the EDPB’s recognition of the unique challenges blockchain presents for data protection law. Our response encourages the Board to adopt a technology-neutral, risk-based approach that safeguards privacy while enabling innovation, transparency, and EU competitiveness.

Key themes in our submission include:

• Recognition of cryptographic erasure and unlinkability techniques

• A functional approach to defining controllers and processors

• Proportional treatment of public permissionless blockchains

• Clarification of when public keys qualify as personal data

• Practical, layered solutions for GDPR-compliant international data transfers

We support the EDPB’s goal of ensuring GDPR compliance and offer targeted adjustments to ensure the final guidelines are clear, proportionate, and innovation-friendly.

A sincere thank you to our members for their detailed insights and technical contributions to this important consultation.

Read the full response here.