# Delegation-Based Personal Data Processing Request
## 3 Delegation-Based Personal Data Processing Request Notarization Framework
### GDPR Compliance Audit Process
* Request and response anytime, anywhere (A1): The proposed framework was designed to delegate the DS's request and DC's response through the web service, notarize it in the BC network, and send it to the recipient through the e-mail service; thus, the DS and DC can make requests and responses anytime, anywhere. See Figure 6 in Section 3.4 and Figure 11 in Section 4.1. * Save the information provided by electronic means (A2): The proposed framework stores all transactions related to personal data processing requests from DS and DC as electronic ledgers in BC. See Section 3.5 and Figure 11 in Section 4.1. * Record of DS's request and of DC's response to DS's request (A3): The proposed framework stores all transactions related to personal data processing requests from DS and DC as electronic ledgers in BC. See Section 3.5 and Figure 11 in Section 4.1. * Non-repudiation of requests and responses (A4): The DS and DC transmit the transaction together with the private key signature to the proposed framework, and the notary node of the proposed framework notarizes with the private key signature and stores it in BC, so the creator and notary cannot deny the stored data. See 'Prevention of denial' in Section 5.1.1. * Sealing of data (B1): As the proposed framework is based on private BC, network participants can be managed. The proposed framework allows only the peers of the SA to participate in the network. Furthermore, the consensus procedure of HLF, which generates blocks after verification via multiple peers, has the function of notarization. Peers acting as notaries only include the signature generated by their private key in the transaction at the time of verification and do not cause any changes. Thus, the proposed framework using HLF's RAFT consensus algorithm meets the \"sealing of data\" requirement. See 'Data security' in Section 5.1.1. * Accessible to all (B2): The proposed framework was designed to delegate the request of the DS and response of the DC through a web service and e-mail service. Both the DS and DC can access and use the framework after being authenticated and authorized by the CA. See Figure 11 in Section 4.1. * Trusted or certifiable (B3): For the integrity and objective reliability of the ledger, the proposed framework restricts the nodes participating in notarization to authoritative organizations such as SAs. In the proposed framework, the algorithm that allows multiple notaries to participate and notarize inherits the RAFT algorithm of HLF, which has already been verified for stability. * Highly trusted communications (B4): As the proposed framework uses HLF, a private BC framework, it inherits the integrity and confidentiality of the HLF's system, network, and data. HLF supports secure communication between nodes by using transport layer security (TLS) protocol, which is applied in the proposed framework. * Authentication (B5): The proposed framework authenticates all entities using Fabric CA, which is a CA provided by HLF. See 'Authentication and Authorization' in Section 5.1.1. * Data minimization (C1): The proposed framework only stores information for auditing the processing request transaction of the DS and DC's response to the request in the BC for the GDPR compliance audit, and it does not store any other personal data that the SPs have. See Section 3.5. * Feasibility in real environment (D1): As the proposed framework was designed to delegate the DS's request and DC's response through a web service and an e-mail service, the SPs need not modify the legacy personal information processing system or install a separate third party module. Therefore, it can be applied as a GDPR compliance audit framework in a real environment. ### Performance Evaluation

To evaluate the performance of the proposed framework, we installed Docker on Intel Core i5-8265U CPU @ 1.60 GHz, with 16 GB RAM specification system, and applied the two-peer three-order, and Raft consensus algorithm to configure and simulate the HLFnetwork.