Data Protection Laws GDPR CCPA vs Public Name Records

The growth of Web3 naming systems such as Ethereum Name Service (ENS), Unstoppable Domains, and other blockchain-based registries has introduced a novel tension in the world of data governance: the immutability and transparency of public name records versus the evolving landscape of global data protection laws. Jurisdictions like the European Union and the state of California have implemented sweeping regulatory frameworks in the form of the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), both designed to give individuals more control over their personal data. These frameworks emphasize rights such as data erasure, data minimization, and informed consent. However, blockchain-based public naming systems are fundamentally resistant to modification or deletion, presenting both legal and technical conflicts with these data protection regimes.

Web3 naming services allow users to register human-readable domain names that resolve to wallet addresses, smart contracts, IPFS content, and a variety of metadata fields. ENS, for instance, permits users to associate email addresses, Twitter handles, GitHub usernames, avatars, and descriptive text with a .eth domain. These records are stored on-chain or referenced via decentralized data structures that are publicly accessible and often permanent. While this transparency aligns with the ethos of decentralization and trustless systems, it directly contradicts GDPR principles such as the right to be forgotten and the right to restrict or rectify data.

The GDPR, enacted in 2018, imposes obligations on data controllers and processors to protect the privacy of EU citizens. It grants individuals the right to request that their personal data be deleted or corrected, a feature known as the “right to erasure.” In traditional web applications, this is implemented through centralized databases, where a data controller can remove or update information upon request. In the context of Web3, there is no central authority with the ability to alter or delete data once it has been written to a blockchain. Even if off-chain pointers like IPFS hashes are deleted from the registry, the underlying data may still be retrievable from the distributed file system if other nodes continue to host it. This permanence creates a significant legal grey area. If a user inputs personal information into a name record—knowingly or unknowingly—they may inadvertently violate their own data rights, or those of others, in a manner that cannot be undone.

California’s CCPA, while somewhat more lenient than the GDPR, also emphasizes the right of consumers to request disclosure, correction, and deletion of their personal information. Though initially framed around businesses collecting and monetizing user data, the law’s definitions are broad enough to encompass decentralized applications that gather and display user-submitted metadata. For example, a Web3 dApp that allows users to search ENS records and index public profiles could be seen as “collecting” personal information under CCPA if the data includes names, emails, or associated wallet activity. If that dApp enables or encourages users to link their real-world identity to a domain, the operator could be responsible for responding to deletion or correction requests—tasks that may be technically infeasible in decentralized systems.

A particularly problematic area arises in reverse resolution features. Services like ENS allow wallet addresses to be linked to .eth names, and vice versa, often displaying the name in wallet interfaces like MetaMask or transaction histories on block explorers. When these names include identifiable information or when associated records are scraped by search engines, individuals’ blockchain activity can become publicly traceable in ways that are hard to anonymize. This exposure could violate data minimization principles and create long-term privacy risks, especially in jurisdictions with strict data localization and consent laws. Once a name-to-address link is published on-chain, it is immutable, making retroactive privacy enforcement nearly impossible.

In response to these challenges, some Web3 projects have begun exploring privacy-preserving architectures. ZK (zero-knowledge) naming systems and encrypted metadata records are being developed to obscure user identities while still enabling name resolution. These solutions allow the verification of ownership or permissions without revealing the underlying data. However, they are not yet widely adopted and do not address legacy records already published under more transparent standards. Furthermore, they shift the complexity burden to the user, who must manage encryption keys and understand the implications of privacy trade-offs in a decentralized context.

From a legal standpoint, Web3 naming projects must carefully assess their compliance posture. While protocols themselves are often open-source and permissionless, front-end operators, registry managers, and marketplaces interacting with users may be viewed as data controllers under GDPR or service providers under CCPA. This distinction becomes critical when determining accountability for data exposure, correction requests, or data subject complaints. Some teams have attempted to mitigate liability by disavowing responsibility for on-chain data, publishing terms of service disclaimers, and advising users not to enter personal information. While helpful, such disclaimers may not absolve them of legal obligations if they facilitate or enable data collection through design.

Moreover, courts and regulators are still grappling with how to apply traditional data protection concepts to blockchain technology. The GDPR’s foundational assumption is that data controllers exist and can be identified, but in a DAO-run registry, governance decisions and data publishing may be diffused across thousands of token holders. This leads to difficult questions: Is the DAO collectively liable? Are individual token voters? What constitutes informed consent in a permissionless system? These are unresolved issues, but their implications are significant for anyone building or investing in Web3 naming infrastructure.

Ultimately, the friction between data protection laws and public name records highlights a deeper philosophical and architectural divide between centralized and decentralized paradigms. Regulators focus on user rights through reversibility and control, while blockchains emphasize transparency and immutability. Bridging this gap will require both legal innovation and technical experimentation. Solutions may include dynamic resolvers that allow private metadata overlays, opt-in registries that separate pseudonymous and verified profiles, or jurisdictional geofencing that restricts access to personal data from regulated regions.

Until such frameworks are developed and widely adopted, Web3 users and developers must navigate this environment with caution. Registering or exposing personal information through public name records creates permanent digital fingerprints that may violate not only the letter of data protection laws but also their underlying spirit. For regulators, the challenge lies in adapting enforcement tools to systems that defy conventional control. For builders, it is about balancing openness with privacy in a way that respects both technological innovation and fundamental rights. The future of digital identity will be shaped at this intersection—and the choices made today will have long-term consequences for compliance, privacy, and trust in the Web3 ecosystem.

The growth of Web3 naming systems such as Ethereum Name Service (ENS), Unstoppable Domains, and other blockchain-based registries has introduced a novel tension in the world of data governance: the immutability and transparency of public name records versus the evolving landscape of global data protection laws. Jurisdictions like the European Union and the state of…