Right to erasure under GDPR: why applying it is more complex than it seems - Agenda Digitale
Summary
This article explains why GDPR erasure requests require careful case-by-case analysis rather than automatic deletion. It outlines the legal conditions under Article 17, including when a controller may refuse deletion because of legal obligations, public interest, or legal defense needs. It also highlights findings from the EDPB’s coordinated enforcement work, which found weaknesses in procedures, training, retention management, backups, and anonymization. The article closes with practical steps for controllers, including mapping data, updating processing records, improving deletion workflows, and training staff.
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