The recent approval of the General Data Protection Regulation (GDPR) imposes new data protection requirements on data controllers and processors with respect to the processing of European Union (EU) residents' data. This requirements consist of a single set of rules that have binding legal status and should be enforced in all EU member states. In light of these requirements, we propose in this paper the use of a blockchain-based approach to support data accountability and provenance tracking. Our approach relies on the use of publicly auditable contracts deployed in a blockchain that increase the transparency with respect to the access and usage of data. We identify and discuss three different models for our approach with different granularity and scalability requirements where contracts can be used to encode data usage policies and provenance tracking information in a privacy-friendly way. From these three models we designed, implemented, and evaluated a model where contracts are deployed by data subjects for each data controller, and a model where subjects join contracts deployed by data controllers in case they accept the data handling conditions. Our implementations show in practice the feasibility and limitations of contracts for the purposes identified in this paper.
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