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Erasure Request on a Blockchain: Immutability, Blocking and Proof

Erasure requests for blockchain data: personal-data links, technical limits, off-chain erasure, access blocking and evidence under the GDPR.

BRANDAUER Rechtsanwälte
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Mag. Bernhard Brandauer, Austrian attorney-at-law

BRANDAUER Rechtsanwälte

Mag. Bernhard Brandauer advises businesses on the legal classification and practical implementation of data protection requirements.

9 September 2026 · Mag. Bernhard Brandauer, Austrian attorney-at-law

An erasure request creates a particular technical problem where personal data are stored on a blockchain. Depending on the architecture, a confirmed block cannot simply be overwritten. The first questions are therefore which information is actually on chain, whether it can be linked to an individual and which connected data are stored outside the blockchain.

This article addresses erasure requests involving immutable blockchain structures. It explains how to assess the personal-data link, separate on-chain and off-chain data, limit access and record the response. General backups, anonymisation, data portability and data breaches are separate subjects.

Initial assessment

How should your blockchain erasure request be assessed?

Answer the questions about personal data, architecture and access. The result shows which technical and organisational records should be gathered first.

01 Question 1

Are personal or linkable data stored on the blockchain?

Review the content, hash values, identifiers and additional information that may permit an allocation to a person.

Result

Your orientation

01

The personal-data link has not yet been assessed reliably.

Describe the stored values, hashes, identifiers and available additional information. Assess whether a person can be identified directly or through other data. That assessment is the basis for the next response to the request.
02

The data architecture is not yet mapped sufficiently for the erasure assessment.

Prepare an overview of on-chain and off-chain storage, keys, interfaces, applications and providers. Mark where data are copied and who can access a mapping to an individual.
03

Access blocking is not yet adequately prepared.

Limit the affected applications, permissions and key access. Blocking can reduce further use, but it does not replace the separate assessment of erasure, lasting inaccessibility or a possible exception to erasure.
04

The technical response is not yet sufficiently evidenced.

Record receipt, affected data, the architecture reviewed, the decision and the measure taken. Keep only the evidence needed for accountability and control.
05

The essential checks and measures are prepared.

Complete the request by considering the architecture, personal-data link and available access controls. Record separately which data were erased, which access was blocked and which information remains under a reviewed exception.

Assess on-chain and off-chain data separately

The technical architecture determines which response is possible. Record every type of information created by the blockchain process: transaction data, hash values, keys, wallet mappings, user profiles, documents, logs, backups and data in connected applications. Mark which values are immutable on chain and which are held elsewhere.

Off-chain data can usually be handled in their own systems. This may concern a customer profile, a mapping table or a document referenced by a blockchain entry. Erasing data outside the chain answers the request only to the extent that it changes the personal-data link and further use in practice. The connection with the blockchain needs its own assessment.

Article 5 GDPR includes purpose limitation, data minimisation and storage limitation. These principles matter when the architecture is planned. Store as little personal information as possible directly on a structure that cannot later be adjusted. Future erasure requests will then be easier to assess and control.

Keep erasure and access blocking distinct

Blocking prevents or limits the use of data. It may concern applications, permissions, interfaces or access to mapping keys. This can stop further processing in practice. Whether it also amounts to erasure under Article 17 GDPR depends on the technical and actual access position.

An immutable record remains present where it is merely removed from a user interface or hidden in an application. The same applies where one application is blocked but other systems can still reach the value, a copy or the mapping to a person. Explain precisely which use has ended and which access options remain.

Article 25 GDPR requires data protection by design and by default. Access blocking can form part of that safeguard. It must be connected to the individual request and should not be used as a blanket answer for every blockchain arrangement.

Handle keys and access controls carefully

In blockchain applications, key material may determine whether data can be read, linked or processed further. Review who manages the keys, which applications use them, whether copies exist and whether providers have their own access. A key must not automatically be treated as identical to the personal data.

Destroying or blocking a key can be a technical measure that makes access more difficult. It does not by itself prove that every personal-data link has disappeared. The assessment must cover copies, alternative keys, exported data and other routes to an allocation. Record the specific technical effect of the measure.

Article 32 GDPR requires a level of security appropriate to the risk. In the individual system, this can include access controls, separated roles, protected interfaces and reviewable management of privileged access. The measure must match the architecture and sensitivity of the affected data.

Record exceptions and the decision clearly

Article 17 GDPR also covers situations where continued processing must be assessed. These include legal obligations, tasks in the public interest and the establishment, exercise or defence of legal claims. An exception cannot be justified merely by the technical immutability of a blockchain. Record the concrete condition and the scope of continued storage.

Record receipt, the requester’s identity, the affected transactions or data sets, identified storage locations and available allocation routes. Then decide on each relevant data set. An on-chain value, an off-chain profile and an access key may require different measures.

The evidence must explain the decision without collecting unnecessary new personal data. Article 5 GDPR requires responsible and traceable processing. Record responsibility, checks, technical implementation, control and result in a form that remains understandable later.

Follow the request from receipt to evidence

Start with a complete record of the request. Secure the time of receipt and allocate the requested data to blockchain and off-chain systems. Then review personal-data links, purposes, storage locations, recipients, access and possible exceptions. A technical description should remain understandable for the legal assessment.

Set the measure for each data set. This may be erasure of an off-chain record, removal of a mapping, blocking of an application or another technical change. Where an on-chain entry cannot be altered, describe and assess the remaining access options openly.

Control implementation against the systems and copies identified at the start. Review applications, interfaces, key management and provider access. Record what was checked, who performed the control and the result. Evidence should support the decision rather than simply assert it.

Avoid common blockchain erasure errors

The blockchain is treated as an automatic exception: Technical immutability alone does not answer whether Article 17 GDPR applies or an exception is available.

A hash is automatically called anonymous: The link to an individual depends on additional information, the architecture and available knowledge.

The interface is cleaned while the entry remains reachable: Hiding a value in one application does not end other access, copies or allocation routes.

Key destruction is equated with erasure: Its technical effect and remaining identifiability require a separate assessment.

Off-chain systems are ignored: Profiles, documents, mapping tables, exports and provider copies may be decisive for the response.

The evidence records only the result: Without architecture, checks, responsibility and control, the decision is difficult to explain later.

FAQ

Questions about erasure requests on a blockchain

Must a blockchain entry be deleted for every erasure request? +
That depends on whether the entry contains personal data or can be linked to an individual with reasonable means, and whether the conditions or exceptions in Article 17 GDPR apply. The architecture and available additional information require an individual assessment.
Is blocking access to the blockchain entry enough? +
Blocking can limit further use, but it is not automatically erasure. The remaining applications, copies, keys and allocation routes matter. The technical effect must be recorded and assessed.
Are hash values always anonymous? +
No. A hash value may be linked to an individual depending on additional knowledge, connections and the technical environment. The personal-data link must be assessed in the specific architecture.
What must a business prove about a blockchain erasure request? +
The record should explain receipt, affected data, storage locations reviewed, the personal-data link, the decision, technical measure, responsibility and control result. It should itself remain limited to the information required.
What about data stored outside the blockchain? +
Off-chain profiles, documents, mapping tables and other copies must be recorded separately and assessed under the applicable conditions. Handling the blockchain entry does not automatically resolve those data.

Prepare the blockchain erasure request

We review the technical architecture, personal-data link, on-chain and off-chain data, keys, access and possible exceptions with you. The request, a data-flow description, affected transactions or hash values, system and provider records and the previous response help with an initial assessment. This shows which data can be erased, which access can be limited and which steps must be evidenced. If a security incident is involved, the process for a data breach at a processor must be assessed separately.

Discuss your data protection matter

Tell us briefly what is happening. We will help classify the situation and discuss which documents and next step are useful for your business.

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