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Singapore Issues Guidelines for Blockchain Privacy

A guide on personal data protection considerations for blockchain design has been made available by Singapore’s Personal Data Protection Commission (PDPC). To ensure more responsible management of customers’ personal data, the guide intends to help organisations use blockchain technology by outlining how to adhere to the Personal Data Protection Act 2012 (No. 26 of 2012) when deploying blockchain applications.

Among the issues covered in the guide are blockchain networks and associated roles; data protection risks and considerations; recommendations for permissionless and permissioned networks; and steps to developing a data protection management programme.

Some of the takeaways from the guide are as follows:

  • Anticipate potential compliance issues when planning to store personal data on blockchains;
  • Do not store any personal data on-chain on a permissionless blockchain, whether in-clear, encrypted or anonymised;
  • Encrypt or anonymise all personal data written on-chain on a permissioned blockchain; and
  • Use off-chain approaches to further mitigate personal data protection risks on permissionless or permissioned blockchains.

The guide explains how to abide by the PDPA when installing blockchain applications that process personal data, with the goal of promoting blockchain adoption. For more responsible administration of clients’ personal data, it offers advice on data protection by design (“DPbD”) aspects.

This manual is intended for organisations that:

  • Govern, configure and operate blockchain networks and consortia (i.e. blockchain operators);
  • Design, deploy and maintain applications on blockchain networks (i.e. application service providers); and
  • Use blockchain applications (i.e. participating organisations).

The recently published guide discusses the risks and policy issues involved with writing personal data on permission and permissionless blockchains, as well as the pros and downsides of DPbD strategies for storing and transmitting personal data on blockchains.

The guide is not a comprehensive reference or recommends implementations for blockchain applications due to the range of blockchain types and methodologies. Instead, it offers organisations a wide range of guidelines and considerations for creating and setting up PDPA-compliant blockchain applications.

While this guide focuses on blockchain technology, due to its prevalence, some of the principles and recommendations discussed may be broadly applicable to Distributed Ledger Technologies (DLTs) as well, depending on the nature of the DLT implementation.

Meanwhile, the Personal Data Protection Commission of Singapore and the Office of the Privacy Commissioner for Personal Data of Hong Kong (PCPD) have renewed their Memorandum of Understanding (MOU) to maintain their existing ties, foster closer cooperation, and increase the scope of their collaboration in personal data protection.

The Memorandum of Understanding between the two data protection authorities outlines the scope of their collaboration, which includes, among other things, the coordination and provision of mutual assistance in joint investigations into cross-border personal data incidents, the exchange of information and sharing of best practices involving data protection policies and enforcement actions, and collaboration in education and training.

In May 2019, the two governments signed an agreement to create bilateral platforms to advance personal data protection. The MoU offers a strengthened framework for collaboration and workable cooperation and serves as a solid foundation for the working relationship between the two data protection bodies.

The recently signed agreement demonstrates both governments’ commitment to increasing collaboration and cooperation in the protection of personal data privacy in new and emerging areas such as artificial intelligence and cross-border data flows.

Both countries believe that an effective cooperation mechanism would benefit both authorities on a variety of fronts, including enforcement actions, promotion, and public education.

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