GDPR Compliance¶
Citizen is designed with GDPR compliance as a first-class concern. The project maintains a comprehensive compliance framework covering data protection, privacy by design, and data subject rights.
Compliance Framework¶
The project uses the GESF (Governance Evidence & Security Framework) for automated compliance monitoring. Configuration and evidence are tracked in the .ges/ directory.
Data Protection Documents¶
| Document | Purpose |
|---|---|
| Data Inventory | Categories of personal data processed |
| Processing Records (ROPA) | Article 30 records of processing activities |
| Privacy Impact Assessment | DPIA for data protection risk assessment |
| Risk Register | Identified risks and mitigation measures |
| Retention Policy | Data retention periods per category |
| Access Control Matrix | Role-based access controls |
Privacy by Design¶
Citizen implements privacy by design through:
On-Chain / Off-Chain Separation¶
- On-chain: Only commitments, proofs, and events (no personal data)
- Off-chain: Encrypted user-controlled data custody
Selective Field Privacy¶
- Individual fields within entries can be encrypted
- Users control decryption through hybrid ACL/DEK-based sharing
Consent Receipts¶
- Namespace policies can require consent receipts for entries
- Consent is recorded on-chain with audit trails
Encryption by Default¶
- Off-chain data is encrypted with ChaCha20-Poly1305 (via X25519 ECDH)
- Backup vaults use AES-256-GCM with PBKDF2 (210K iterations)
Data Subject Rights¶
The protocol's architecture supports GDPR data subject rights:
| Right | Implementation |
|---|---|
| Access | Users can decrypt and view their own data |
| Rectification | Users can submit corrected entries |
| Erasure | Off-chain data is user-controlled; on-chain commitments are immutable by design (ledger integrity) |
| Portability | Encrypted backup vaults enable data export |
| Objection | Consent policies allow users to withhold consent |
Control Packs¶
The project maintains control packs for multiple frameworks:
- GDPR - General Data Protection Regulation
- OWASP - Application security best practices
- CIS - Critical Security Controls
- NIST - Cybersecurity Framework
These are configured in the .ges/ directory and validated through the CI compliance workflow.
CI Compliance Checks¶
The .github/workflows/compliance.yml workflow runs GESF audits on every push, checking for:
- Secret exposure
- Weak cryptography
- Injection vulnerabilities
- Authentication issues
- Configuration problems
- Database anti-patterns
Findings are reported but do not block CI (configured with continue-on-error).