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PII not on blockchain? How to localize? How to access by authorized parties? Not only PII that is protected - transaction information, metadata.
Privacy - personal data - laws are in place - privacy protection and comply with GDPR. Conversation is separate - privacy or privacy on blockchain.
What about correlating with transactions? Then poor design. Scope of DLT - if audit transactions on the ledger - can't be pseudo anonymously identifiable.
The ledger becomes pure proofs? Yes. Hashes? Workgroup 29 EU GDPR - encrypted data should not be put on chain. Hashes or salted hashes, maybe? Privacy lawyers? Reverse engineer? Gray area - don't do it. Don't put hashes of PII on-chain.
Other systems will do PII storage and identity proofing? Identity management systems, covered ISO 307. Security and Identity management systems.
Safe? Not according to the news. Perhaps insider threats or poor implementation. Not a DLT thing unless you scope it into the conversation. DLT is a system of records somehow. CORDA is a bilateral system, visible to parties on transaction, not others.
Right of erasure? How do you remove? Direct impact on adoption of adoption of a particular ledger.
Focus - what is written to the ledger, including transaction audits. And, what should transaction audits be comprised of? Transaction audits to PII? In India or CORDA conversation - if implemented based on based practice - pairwise pseudo channels with service requestor and service provider. Only those two know - like FIDO - you can have a different DID - thousands of private DIDs for one service provider? How do we have privacy protection on the ledger?
Have to expose data to verifier? Verifier has the right to copy the data? As service provider. You can de-link Issuer from Verifier. On the ledger will be whatever available to make pairwise DID conversation more private. In the end, the Service Provider is capturing data and associating it with a person. The doctor knows who you are.
How do you protect on-chain in a DLT. As soon as I give a pairwise pseudo-anonymous channel - we're off-chain and in a different domain. That's any Identity management domain. Rife with leak problems.