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Outline of MTI's solution

The crux of MTI's solution is MTI's adapter, a middleware

application for interfacing with certain blockchain

networks. MTI's adapter is suited for use in a wide

variety of supply chains, including in international

freight and shipping. It enables systems currently in

use in the shipping industry to interface with one or

more blockchain networks. Each network can be run by

different industry players and can use different underlying

blockchain technologies (such as IBM's Hyperledger

Fabric, Activeledger, Corda, Quorum etc.). There is thus no

need for every player in the industry to use one particular

network, as multiple networks can operate in parallel.

Each shipping industry player can aggregate their multiple

networks and existing shipping industry systems in a

single place using MTI's adapter.

To drive commercial adoption of its adapter, MTI plans to

establish, together with a consortium of industry players,

one such blockchain network for use in international

shipping. This network will likely be built on Hyperledger

Fabric and will be a private, permissioned network.

In line with the GDPR principle of data minimisation,

the network will store on the blockchain (on-chain) only

information that everyone on the network has the right

to view. Where a transaction involves information that

only some participants have a right to see, that private

information will be hashed and the hash will be added

to the blockchain. The underlying private information

will then be sent, via a side channel peer-to-peer

network, to those participants with a right to see the

information. This focus on privacy by design means

that information that should not be visible to everyone

is kept off the blockchain (off-chain) and is only stored

locally by those participants with a right to access the

information. Any person who has a copy of the off-chain

private information can run the hashing algorithm over

it and compare the result to the hash stored on-chain to

verify that it has a true copy of the private information

associated with the transaction recorded on the ledger.

This also ensures all information associated with

transactions on the network are fully auditable.


What personal data may

be processed?

The personal data likely to be involved in MTI's solution

are not likely to be particularly sensitive. They would likely

be limited to:

• names of people signing certain shipping documents;

• business contact details of certain people involved in

the shipping process, such as phone numbers or email

addresses; and

• photos of shipping cargo that may incidentally include

recognisable individuals or other personal data.

MTI's solution intends to use the side-channel model

described above for all information that should not be

freely visible to every participant on the network, which

will include all personal data. This includes using the

side-channel model to restrict the visibility of free form

comments. There will, of course, always be the risk that

some personal data is not properly confined to the side

channels and finds its way on to the network, and we

therefore consider how MTI may ensure GDPR compliance

given this possibility.

40 I GDPR and the Blockchain


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