Answer the data-protection review - #32
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A data-protection-officer review of the draft raised seven concerns about personal data in public, append-only transparency structures; all are answered, six normatively: - Log content minimization (new requirement with test): log leaves, proofs, and tree heads carry no directly identifying personal data; named-identity binding lives in access-controlled registers, with revocation and key rotation as the withdrawal mechanism. - Rectification: the log records issuance, not truth — corrections flow through superseding attestations and re-issuance, never edits (guidance on append-only structure and retention). - Data minimization: co-signature signer identity in public artifacts and passports is normatively a key fingerprint or pseudonym. - Linkability: schemes attesting individuals use rotating or purpose-bound keys or privacy-preserving credentials. - Storage limitation: retention bounded by purpose with scheme-defined deletion criteria for logs and ceremony transcripts. - Cross-border transfer: the deployment manifest documents mirror jurisdiction and transfer basis; schemes processing personal data define a privacy policy with lawful basis and information duties. The registry is now 118 requirements and 118 tests; the new audit gate passes.
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Answer the data-protection review
A data-protection-officer review of the draft raised seven concerns
about personal data in public, append-only transparency structures;
all are answered, six normatively:
proofs, and tree heads carry no directly identifying personal data;
named-identity binding lives in access-controlled registers, with
revocation and key rotation as the withdrawal mechanism.
flow through superseding attestations and re-issuance, never edits
(guidance on append-only structure and retention).
and passports is normatively a key fingerprint or pseudonym.
purpose-bound keys or privacy-preserving credentials.
deletion criteria for logs and ceremony transcripts.
jurisdiction and transfer basis; schemes processing personal data
define a privacy policy with lawful basis and information duties.
The registry is now 118 requirements and 118 tests; the new audit
gate passes.