블록체인 기반 REC 거래 시스템 효율화를 위한 개인정보보호법제 연구

The block-chain technology-based information sharing system was introduced to optimize the efficiency of current renewable energy certificates(RECs) transactions. A stable settlement of the introduction of new technologies should be based on an interpretation of the constraints of the relevant legal regulations. For this purpose, Related to REC transactions, the issues under the Personal Information Protection Act that may arise from the introduction of block-chain were reviewed in turn based on analysis of the ‘General Data Protection Regulations’ and ‘domestic law’ analysis, and the results are as follows. First, because the personal information related to REC transactions stored on block-chain includes ‘personal identification information’, hash values converted into hash functions are also included in the personal information. Second, it is possible to recognize the status of a ‘personal information controller’ under the Privacy Act to block-chain nodes. However, since it is technically impossible to destroy, isolate, store, and manage personal information, technical alternatives such as ‘off-chain storage’ and flexible interpretation of laws should be considered to minimize differences from current laws. Third, legislative improvements to ‘post-consent’ and ‘agreement to general information provision’ and ‘extend the application of Legitimate interests as exceptional reasons for consent’ are needed in connection with ‘third party information provision’ made without ‘prior consent’ within block-chain.