Legal Research Working Group - GDPR Special Project Announcement

Hi everyone. The Legal Research Working Group is pleased to announce our plans for addressing GDPR compliance for the Factom (R) Protocol. unsurprisingly, blockchain technology and GDPR make for strange bedfellows. We obviously need to make sure that the Factom (R) Protocol (and its resources such as, are in full GDPR compliance.

As you may recall, @Matthias Fortin did an excellent job during the non-profit discussion of asking well-thought out, detail-oriented questions. After communicating with Matthias more, it is clearly evident to the Legal Research Working Group that he has the same sort of focus and attention to detail in regards to GDPR compliance. Additionally, because HashnStore is located in the EU (France), they are more affected by GDPR than ANOs in other jurisdictions.

For these reasons, the Legal Research Working Group thought it prudent to ask Matthias if he would serve as "Special Project Lead - GDPR" for the Legal Research Working Group. Fortunately for the Factom (R) Protocol community, he has accepted!

1. Matthias and the Legal Research Working Group will work to outline the scope of the project as well as compile pertinent info
2. Matthias will then contact attorneys that are experienced in GDPR compliance.
3. Matthias will operate as point-of-contact and project lead. The Legal Research Working Group will provide full assistance to Matthias.

We will update the community with more details as we progress. In the meantime, a huge thank you to @Matthias Fortin on behalf of @HashnStore for spearheading the Factom (R) Protocol GDPR Compliance Special Project!
Update: Due to previous GDPR conversations with @Alex , @Matthias Fortin recommended that the GDPR Special Project ask Alex to join the team, as Alex brings a unique perspective and relevant experience to the project. In addition to working with the law firm Hogan Lovells on this topic, Alex can provide technical insight such as the following (a brief sample from Alex):

I was prototyping an application that needed to handle data of private individuals. Two challenges I faced:
1. If hashes can be considered personal data, how can I ensure that my application retains the advantages of blockchain whilst remaining GDPR compliant.

2. How should I leverage entry chains, which are an attack vector for user privacy. If you were to associate an entry chain with a user, then that entry chain becomes a pseudonym for the user. Revealing the connection between the pseudonym and the user would reveal metadata about the user's interaction with the application.
The Legal Research Working Group agreed with Matthias' assessment of Alex's potential contributions and asked Alex to join the project. Alex has accepted. Huge thanks to @Alex for joining the team!

Moving forward, since Matthias is the GDPR Special Project Lead, he will take the reins in regards to providing the community updates about GDPR progress.

Thank You,

Due to previous research on ZkPs, the LRWG has decided to ask @Valentin Ganev to join the project. His technical knowledge in this field could be valuable to assess the GDPR compliance of certain processes.

The LRWG will meet in the next days in order to define clearly its expectations. We will then give a rough timeline of the project to the community.

Thank you,
LRWG - GDPR Project
Last edited:
Hi everyone,

The LRWG is happy to announce it has realised some progress this last month. We have progressed on 2 fronts.

First, we have defined the overall scope of the study. It will mainly focus on the compliance of the infrastructure operators and of the participants to the governance processes. Compliance of the solutions developed on top of Factom will be discussed in the proposed study but it could not be an exhaustive study as the situations can differ from one solution to another.

Second, we have found a lawyer to realise such a study which fits into our available budget (which is a challenge by itself!). But even more important the lawyer is a specialist of the GDPR questions and is participating to several research projects including new tech such as AI and Blockchain. She is a French Professor and is part of a famous French Institute (“Institut Universitaire de France”)

The next steps are to sign this contract with the lawyer (at that point we will announce her name - we only have a quote for now) and to start collecting more specific information from different actors of the protocol. We may need to contact some of you !

Thank you,
LRWG - GDPR Project
Hi everyone,

It has been a long time since our last update. @Matt Osborne has already done one within the LRWG Grant thread. A lot of progress has been done. Here is a complete summary of our work these last months:

- We have been able to produce a report on the way the consensus is achieved within the Factom Protocol and the role of each actor. It is quite a valuable document. If you want to have a look, it is here :

I would like to thank all the members of the GDPR WG for their help to write this doc and @Steven Masley who dedicated a lot of time to answer our numerous questions on the mechanics of the consensus algorithm. This document would not have been as useful as it is without him.

- In parallel to this work, we have been searching for different law firms and lawyers able to perform a large study covering the different aspects of our protocol : Infrastructure, Governance and Development. We have been in a position to discuss with a very qualified lawyer member of the "Institut Universitaire de France" and a specialist of GDPR and AI topics.

- We got a quote from this lawyer for quite a competitive price considering the average cost of the law firms. This is due to the fact this lawyer is an academic and not part of a law firm.

- As already explained by @Matt Osborne within the LRWG Grant thread we have not been in a position to launch the study unfortunately. The funding issue has to be solved before re-starting this work.

- Last but not least, we have briefly discussed within the GDPR WG the opportunity to apply for a grant. We all agree that this next round will be very competitive. But due to the work already provided and because we do not know yet what will be the other grant proposals, the consensus is to apply and let the community decide relatively to the other grants. Therefore, HashnStore will be submitting this grant in the coming days.

The GDPR work is therefore still ongoing. I take this opportunity to thank again all the members of this WG: @Shuang Leng @Matt Osborne @Alex @Nikola Nikolov @Valentin Ganev @Julian Fletcher-Taylor and again thank you very much to @Steven Masley for answering all our technical questions about the code.

Thank you for reading,
LRWG - GDPR Project