In order to comply with specific regulations (eIDAS, Payment Services Directive, Anti-Money Laundering Directive) and reduce risk profiles, financial service providers increasingly collect large amounts of information from their customers. The increasing opportunities and technical means for data collection afforded from digitalisation raise legal concerns related to proportionality, necessity, and data minimization.
This paper will address the issue by examining aspects of digital identity, especially those that have proposed the use of a permissioned distributed ledger or blockchain as architecture for know your customer and onboarding evidential frameworks. After elaborating on the notion of identity in the digital sphere and the applicability of the GDPR to a blockchain based data structure, the discussion will be developed to critically assess the current trend towards using the financial institutions’ customers’ mobile devices as interfaces, and the legal and sociological implications of this technological development.
