The roles of Data Controller and Processor as defined in the GDPR are quite easy to identify in most centralized businesses, however when it comes to identifying the roles in a blockchain/distributed ledger, the lines become blurred and the application of GDPR more complex.
Since GDPR is intended to be technology neutral, any entity established in the EU or processing the personal data of data subjects in the EU, regardless of the technology deployed, needs to identify who are the Data Controllers and who are the Processors in order for them to fulfil their respective obligations...
