What GDPR requires you to do
• Data minimization (Art. 5(1)(c)) — Process only personal data that is adequate, relevant, and limited to what is necessary. Tokenization sends zero personal data to the model.
• Privacy by design (Art. 25) — Controllers must implement technical measures that integrate data protection from the design phase. A tokenization proxy is exactly that.
• Cross-border transfers (Chapter V) — Sending personal data to US-based AI vendors triggers SCCs or DPF requirements. Tokenized surrogates aren't personal data — the transfer obligation thresholds shift.
• Right to erasure (Art. 17) — Delete a project in Cypherz and the per-project vault key is destroyed; all tokenization mappings become unrecoverable.