Ethereum Foundation, in a proposal aimed at GDPR compliance, to define infrastructure boundaries, treats RPC nodes and mempool relays as processors that forward encrypted transactions without insight

Quotes that support claims

Actors: Wallets/dApp front-ends choose what data to submit (controllers). RPC nodes/mempool relays propagate transactions; under privacy enhancements they relay only encrypted or hashed data (processors). Block builders/sequencers assemble and order transactions; with PBS they handle blinded bundles (processors).

The execution layer would operate as processors relaying only encrypted or blinded data, while the consensus layer would solely validate commitments and zero-knowledge proofs. Lastly, the data availability layer, under PeerDAS, would store only anonymous shards for limited timeframes, bringing them in line with GDPR’s data minimization principle.