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9 Reasons Why a ‘Right to be Forgotten’ is Really Wrong

Thursday, December 8th, 2011

The European Commission concept proposal for a data protection regulation contains the so-called right to be forgotten in Article 15. This is not a surprise but the way it has been drafted is quite terrible as I will try to explain below.

Commissioner Viviane Reding made a right to be forgotten into one of the central themes of the privacy directive‘s review of the last two years and her plans to modernize the existing legal framework for the processing of personal data in the EU. While there are some valuable improvements to the existing data protection rules in the EC’s concept proposal, this right to be forgotten is amongst the worst legal inventions I have ever encountered. Below I first shortly discuss the proposal and give 9 reasons why it is really wrong and why it should be abolished.

The basic principle of the ‘right to be forgotten’ is that data subjects can ask for deletion of personal data. This right to be forgotten is an extension of the existing right of erasure with regard to personal data processing in Article 12 of the Privacy Directive, and specifically targets personal data which have been made public, such as the name or picture of a natural person on a discussion forum. It also extends to links to publications containing personal data, for instance in search engines. The proposed right in Article 15 reads as follows:

Article 15  Right to be forgotten and to erasure

1. The data subject shall have the right to obtain from the controller the erasure of personal data relating to them and the abstention from further dissemination of such data where:

(a) the data are no longer necessary in relation to the purposes for which the data are collected or otherwise processed; or

(b) the data subject withdraws consent on which the processing is based according to Article 5(1)(a), or when the storage period consented to has expired; or

(c) the data subject objects to the processing of personal data pursuant to Article 17; or

(d) their processing otherwise does not comply with this Regulation.

This right shall apply especially in relation to personal data which are made available by the data subject while he or she was a child.

2. Where the controller referred to in paragraph 1 has made the data public, it shall in particular ensure the erasure of any public Internet link to, copy of, or replication of the personal data relating to the data subject contained in any publicly available communication service which allows or facilitates the search of or access to this personal data.

3. The controller shall carry out the erasure without delay, except to the extent that the retention of the personal data is necessary:

(a) for exercising the right of freedom of expression in accordance with Article 79; or

(b) for historical, statistical and scientific research purposes in accordance with Article 83; or

(c) for compliance with a legal obligation to retain the data by Union or Member State law to which the controller is subject; this law shall meet an objective of public interest, respect the essence of the right to the protection of personal data and be proportionate to the legitimate aim pursued; or

(d) in the cases referred to in paragraph 4.

4. Instead of erasure, the controller shall restrict processing of personal data where:

(a) their accuracy is contested by the data subject, for a period enabling the controller to verify the accuracy of the data

(b) the controller no longer needs them for the accomplishment of its task but they have to be maintained for purposes of proof;

(c) the processing is unlawful and the data subject opposes their erasure and requests the restriction of their use instead;

(d) the data subject requests to transmit the personal data into another automated processing system in accordance with Article 16(2).

5. Personal data referred to in paragraph 4 may, with the exception of storage, only be processed for purposes of proof, or with the data subject’s consent, or for the protection of the rights of another natural or legal person or for an objective of public interest.

6. Where processing of personal data is restricted pursuant to paragraph 4, the controller shall inform the data subject before lifting the restriction on processing.

7. The controller shall implement mechanisms to ensure that the time limits established for the erasure of personal data and for a periodic review of the need for the storage of the data are observed.

8. Where the erasure is carried out, the controller shall not otherwise process such personal data.

9. The Commission shall be empowered to adopt delegated acts in accordance with Article 86 for the purpose of further specifying:

(a) the criteria and requirements for the application of paragraph 1 for specific sectors and in specific data processing situations;

(b) the criteria for deleting public Internet links, copies or replications of personal data from publicly available communication service as referred to in paragraph 2;

(c) the criteria and conditions as regards personal data identified for the purpose of restricting its processing as referred to in paragraph 4.

In case that some party does not comply with the right to be forgotten, Article 79 provides for a possibly hefty fine by Data Protection Authorities:

Article 79 Administrative sanctions


3. The supervisory authority shall impose a fine between 500 EUR and 600 000 EUR, or in case of an enterprise up to 3 % of its annual worldwide turnover, to anyone who, intentionally or negligently


(c) does not comply with the right to be forgotten  or to erasure, or fails to put mechanisms in place to ensure that the time limits  are observed or does not erase any public Internet link to, copy of, or replication of the personal data relating to the data subject contained in a publicly available communication service pursuant Article 15.

So what is wrong about this right to be forgotten ( if that isn’t already clear from reading the text of the proposal)? Let me list 9 reasons why this proposal looks like a terrible idea:

1. A right to be forgotten with regard to public information is anti-historical. The idea is that the further dissemination of publications of personal data becomes problematic because they have merely historical value. In very specific cases this can arguably make sense. In some European jurisdictions, Germany for instance, there is what could be called a ‘interest to be forgotten’ for criminals that have had their share of punishment and need to reintegrate into society. But careful balancing needs to take place in such contexts as well. The regulation contains a reference to processing for historical purposes, for instance in recital 46, but this reference is way too vague.

2. A right to be forgotten actually doesn’t exist. The existing right to erasure was never absolute in the first place. It is merely the expression of the general principle of purpose limitation that underlies many of the data protection rules. If a company of government agency processes personal data about you, it needs a legitimate reason to do that. If they no longer have that reason it follows they need to stop processing the data and the ‘right to erasure’ gives you a specific legal provision to ask them to do so. To call this a right is an overstatement and gives the wrong impression to those that want information deleted as well as those that would like to keep it public. To improve data protection law through the addition of welcome overstatements is quite generally misguided. There are arange of other provisions in the proposal and exieting rules that suffer the same deficit, such as the prohibition of automated decision making.

3. A right to be forgotten wrongly treats freedom of expression as an exception in relation to the right to privacy. Article 15 states the right to be forgotten as the rule. The interest of communicating about others publicly, which notably includes public figures, celebrities, etc…, is tailored as an exception. Under the proposal, the burden of proof is placed on the one that publishes information and one needs to defend engaging in such communications on the basis that they are necessary to exercise one’s right to free speech, instead of justified. From a European perspective, this does not respect the need to provide for a balance between the competing interests that are typically at stake. (Notably, from a U.S. perspective and the First Amendment, the proposal is even more problematic.) Relatedly, it strengthens the idea that there is a right to control one’s image and reputation in public and the idea that conflicts over making information about others public should be legally resolved through a system of granting rights to control over information flows. This is clearly a short-cut that oversimplifies the values that are at stake in the context of publicity of and about natural persons.

4. A right to be be forgotten will be a tool for censorship. It will strengthen those that want to censor the Web instead of helping those with justified claims to have their personal information removed. The right that is being created is a stick to hit with, the strength of which will heavily depend on the financial means to enter into a legal fight about prolonged publicity of personal information on the Internet. It will be used most effectively by those that have the strongest interest in cleaning up their reputation online.

5. A right to be forgotten strengthens the questionable role of data protection law in the context of public information and networked media. Notably, what is new in the proposal, in comparison with the existing right of erasure of personal data, is that it specifically targets public information. While data protection law has developed in reaction to the use of automated personal data processing systems for government, administrative, and business decision making, it has slowly but steadily extended into the realm of public information and the media, due to the open ended nature of its definitions and the lack of a proper restriction for the public information environment. Unfortunately, the new proposal does nothing to stop this extension of a priori legal regulation of making information about others public. The exception for the media and freedom of expression in Article 81 remains narrow and many of the rules still apply. It also leaves a problematic amount of space to the Member States to interpret the scope of the exception. It is unclear to what extent search engines, social networks, internet archives and non-professional Web publishers such as bloggers or social network users fall under the exception. Data protection law includes a range of rules and principles that apply to any processing of personal data. To apply this legal framework to the media and other contributors to the public information environment is like making journalistic ethics into actual legal rules. This legal prescription of fair treatment of others in public communications violates the principle of free speech.

6. A right to be forgotten as proposed is a frontal attack on linking, search and archiving. Article 15, second paragraph contains the heart of the attack on publicity that is being proposed in the new regulation. The idea is that data subjects should have a right to claim the removal of all sorts of links to ‘their’ personal data on the Internet. It is no surprise that linking and search are being targeted specifically. These services are fundamental to establishing robust publicity in an information environment characterized by abundance. While the provision does not explicitly establish obligations for third parties (not the source of the publication) such as search engines to remove links to personal information, it is important to realize that the regulation does not resolve whether these third parties can be considered controllers themselves.

7. The proposal includes the threat of a fine, which can go up to millions and millions of Euros. While a right to be forgotten does not actually exist and would be legally problematic due to competing fundamental legal principles, the threat of a hefty fine may help to bring it into existence in practice. The chilling effects of fining those that do not comply with the ‘right to be forgotten’ or can be considered negligent in this respect are predictable. Imagine running a blog in a way that extends what is traditionally considered as journalism. Or consider running an association, which tends to publish its proceedings of the yearly general assembly online in view of the value it attributes to transparency. Or consider running a music fan-site with a forum with discussions about concerts and related matters. Clearly, such publications will sometimes contain information related to others. Now consider receiving a letter of an attorney of a now public figure that wants to see information removed and points out you can be fined between 500 and 600.000 EURO if you would fail to defend the prolonged publication of the now historical information in question.

8. A right to be forgotten will chill publishers into restricting access to potentially controversial material. The provision, and the threat of a fine, will incentivize web publishers to limit access to controversial information for search engines. Web publishers can prevent running into claims of a right to be forgotten by restricting access for search engines to publications containing personal data, for instance by using robots.txt. Can this sometimes be a good idea? Perhaps, but clearly the information remains accessible for Web users, even though they may not find it so easily. Can this be a bad idea? Of course, it will incentivize Web publishers that would like to open up their offering as widely as possible to restrict its findability elsewhere, thereby producing a bias towards uncontroversial information in search engines and related services.

9. It is reactionary and fashionable. A right to be forgotten alligns with reactionary sentiments about new forms of publicty made possible by the Internet. If there is any support to be found for this right to be forgotten, it must be amongst those who consider the relative uncontrolled nature of such communications as a threat perse. In addition, European politicians may be charmed by the idea of showing their teeth and passing a provision that they understand as actually protecting people’s privacy online. Finally, a right to be forgotten! Hopefully, they will in time start to understand the highly problematic nature of this proposal.

Panel on the Global Network Initiative

Thursday, June 4th, 2009

I ran into this video of a panel on the Global Network Initiative (The video at the source has some useful taps).

Although the positive tone is dominant, there seems to be a little discomfort discussing the initiative and the issues it is seeking to confront, for instance around the issue of working together with law enforcement and answering to subpoenas. Nicole Wong does answer the question about US law enforcement subpoenas, but to say that she is happy about it or deserves compliments for the information she gives would be an overstatement. Google and others should be much more transparent about their interaction with law enforcement in the US and abroad and hopefully GNI will provide the framework do do that. Now their log retention policy FAQ states:

Will governments be able to subpoena server log data after it is anonymized? Will anonymized data still be able to identify an individual user by cookie or IP address?
Google does comply with valid legal process, such as search warrants, court orders, or subpoenas seeking personal information. Logs anonymization does not guarantee that the government will not be able to identify a specific computer or user, but it does add another layer of privacy protection to our users’ data.

Will this policy change make it more difficult for law enforcement to prevent and detect
crime or child exploitation?

No, current laws allow the government to request that companies preserve user data. We regularly comply with such laws.


How many subpoenas for server log data does Google receive each year?
As a matter of policy, we don’t provide specifics on law enforcement requests to Google.

It’s not generally forbidden to provide these data, so let’s organize them and make them universally accessible and useful. UPDATE: Chris Soghoian issued a FOIA request relating to this kind of information.

The GNI was launched about half a year ago. It’s still looking for an executive director and the webiste does not give any information about the board of directors that is supposed to govern the GNI. In other words, formally, the GNI does not really exist yet. To stay positive, this means that once it really starts to function, much could come out of it.

‘Traveling to the US’ or ‘As if I had any…’

Thursday, February 26th, 2009

You are about to access a Department of Homeland Security computer system. This computer system and data therein are property of the U.S. Government and provided for official U.S. Government information and use.  There is no expectation of privacy when you use this computer system.

Opening lines of pop up from ESTA.

And yeah sure, it’s all great :)


DailyMotion Had to Pay Access Provider Not to be Blacklisted

Friday, February 13th, 2009

Interview in French here.

‘The extended term would also benefit the record producers’

Thursday, February 12th, 2009

Yes, the term extension is moving forward… The JURI Committee approved the term extension today (and extended its scope it seems). From its report:

“The extended term would also benefit the record producers.”

The Open Rights Group is trying to bring some sense into the discussion:


Privacy and Data Protection Day

Wednesday, January 28th, 2009

Today I wrote a contribution for the edri-gram. It’s a short overview of data protection issues in the Netherlands.

Keeping an Eye on Search Engine Diversity

Wednesday, December 24th, 2008

Last week, I came across two fascinating stories that show some of the problems relating to search engine diversity. Chris Soghoian writes how Google’s restrictive Adwords policy stands in the way of informing searchers about public data about political donations. Paul Alan Levy comments on a story about a company called Lifestyle Lift that tries to lead users away from a critical website by optimizing its presence on the Google search result page.

Research shows that the majority of search engine users stay on the first page of results and usually click on the first few results only. This increases the importance of being in the top of the organic results. In addition to offering a competitive way to be found in the organic results, search engines allow organizations to bid on search terms which result in sponsored results. This is the dominant search engine business model. Sponsored links typically show up in the right hand side of the search result page or on the top of the page if they perform above a certain threshold set by the search company. For practical purposes I will restrict my comments to Google.

What is clear is that the two sets of results represent two different information flows. The flow of organic results is the result of the crawling and ranking of sources on the Web. The sponsored results are the result of the Adwords auctioning system, or other forms of sponsoring, such as Google Grants or promotion by Google itself. Research shows that about half of the Internet users might be unaware of a difference between organic and sponsored results.

Although it seems to make sense to to require transparency between organic results and sponsored results, in reality the difference is complex and problematic. On a superficial level, the difference reflects ideas about transparency of advertising in the media. Listeners, viewers or internet users should be able to distinguish between editorial content and advertising (in the broad sense). But, in the context of search results, the difference between a sponsored or an organic result does not tell much about the amount of money that has been paid for the result to show up. It is also quite common for a website to show up both in the organic results and the sponsored results. The different processes that govern the ranking in the two sets of results are equally opaque for users. And finally, the sponsored results are the results that are in some waysmore editorial in nature. My tentative conclusion is that the difference is not well understood and of limited value. What is more important is that we evaluate diversity and quality of search results pages in their totality.

Difference does not reflect payments

Both information flows of results, i.e. organic and sponsored, involve the spending of money to show up in the results as prominently as possible. The difference is who receives the payments, but it is clear that the user is not in a position to evaluate them. Whereas an organic result might show up for certain search terms without someone having invested any money into that, many organizations and companies use search engine optimization services to optimize their organic ranking and presence in search results. The example of Lifestyle Lift shows that sometimes complete websites are being set up to enhance presence and ranking.

It would be interesting to see how much is typically paid for organic optimization in comparison to sponsored optimization. Organic results might be seen as more trustworthy by internet users that think that they understand the difference between the sets of results. This increases the incentives to invest in organic optimization. If the ability to place sponsored links on search engine property would be restricted, one can expect increased pressure on organic results. There are no editorial restrictions on advertising in organic results.

Duplication of results and sources is common

Especially for searches related to products, companies and services, it is common that some of the sponsored links are duplicates of the organic links. Duplication blurs the line between organic and sponsored results. An argument in favor of duplication is that it decreases noise for users that were looking for that source anyway. Duplication is problematic because it decreases the diversity of the results and the possibility that users are confronted with information that adds another perspective to a search. The fact that duplication is fairly common suggests that it is worth for advertisers to push organic results off the first page and out of the attention of most searchers. This is especially the case if the duplication involves a sponsored result in the top of the page on the left, and the same organic results right below it. Duplication might be costly so this is a typical case where the rich get richer because they manage to capture the attention of internet users.

Ranking mechanisms of both sets of results are equally opaque

The ranking of organic search results by Google is notoriously opaque. The Page Rank algorithm, that uses links to establish a global measure of relevance for websites is only one of the many different (200+) factors that is used by Google to establish the ranking of organic results. If one wants to know about ranking algorithms the place to look is the search engine optimization industry. These search engine experts have a pretty good idea how search engines work and walk the fine line between accepted optimization and being punished. Ironically, this industry is also seen as the major reason for search engines not to be more transparent about their ranking algorithms.

The ranking of sponsored results is equally opaque. I have heard some experts explain that the ranking of sponsored links reflects the bids the advertisers, but in reality it is more complex. Google places advertisements on the basis of its keyword auction, and a quality score. The quality score is determined by Google. It includes the historical click through rate and other partly-non-disclosed relevance factors. Thus, the highest placed sponsored link is not necessarily the one that involves the highest willingness to pay. In addition, some sponsored links are placed (and can be clicked on) without them having to make a payment. They are sponsored by Google.

Quality control on sponsored links is stronger than for organic results

Interestingly, the sponsored results are subject to detailed editorial policy that guarantees the quality of sponsored results. The policy of Google Adwords also includes the suppression of unauthorized usage of trademarks, as Chris Soghoian found out. There are several legal and non-legal reasons for this, e.g. the fact that search engines receive money for the placement of these results. Thus, sponsored links might end up being of higher (average) quality and more relevant for some keywords. The relative balance between the quality of organic and sponsored results is of major importance to search engines. If search engines can keep the overall quality of the results in their totality the same, while shifting the relevance of results towards the sponsored results, they make more money.

Keeping an eye on search engine diversity

My conclusion from these ideas and remarks is that we need to focus more on quality metrics of actual search result pages in their totality than on transparency between organic and sponsored results. This difference is of limited value to users. I have the impression that Google is committed to diversity of search results and have heard one Google engineer in Europe say this publicly, but more independent empirical research (Benkler 2008, p. 285) is needed in this direction. Search engines could also be more explicit about this commitment, for instance by being transparent about their commitments to diversity and implementing policies that prevent duplication of results.

Google Wins Market Share in the U.S.

Wednesday, November 26th, 2008

Google continues to increase its market share in the United States. This one Microsoft loses. (In Europe, Google’s market share is above 80 % and in many countries, e.g. Germany and Holland, well above 90 %.)

Competition Takedown – Due Process on the Internet

Monday, November 17th, 2008

The Guardian is reporting about a proposal to make Internet service providers compete against each other on the speed they take down material after receiving notice. There has been one consistent criticism of the current regime for ISPs, namely that due process is not guaranteed by the current notice and takedown in Europe. See for instance Bernt Hugenholtz recent editorial in IIC. There is hard evidence that ISPs will takedown material without thoroughly checking its asserted unlawfullness. The proposal would make sense if it would not ask ISPs to compete on speed but on adequacy and observance of due process. This call by UK officials is shortsighted.

Yahoo and Google Block Celebrity and Public Official Results in Argentina

Tuesday, November 11th, 2008

Chris Soghoian, student fellow at the Berkman Center, has a blog post at the Opennet Initiative about search engine filtering in Argentina. It appears that Argentinian law obliges search engines to take down defamatory results. Yahoo silently decided to completely block all results for Diego Maradonna in Yahoo Argentina. Google has removed some results it had to and has made it clear it will appeal some of the court orders.

There have been similar attempts to block results in Europe. In the Netherlands a TV hostess tried to get results removed from Google and did not succeed. In Germany, in 2005, the Berlin Trial Court ordered a search engine to block certain defamatory results and to install a filter that would prevent any future references with the combination of plaintiff’s name and the word nackt (naked). (LG Berlin, February 22, 2005 AZ: 27 O 45/05, MMR 2005, p. 324-326, CR 2005, p. 530-532). The ruling was later overruled.

Yahoo has been remarkably quiet about the filtering in Argentina and has gone further than needed. It seems that Yahoo is thereby not living up to its obligations under the freshly signed Global Network Initiative principles, which includes resistance to search engine censorship. Now it has added a notice on the SERP page, that some or all results are blocked in response to a court order.

Google had already raised awareness on its Google Latin America blog. There, Google states that in Europe the E-commerce directive (2000/31/EC) resolved the issue of search engine responsibility. Unfortunately, this is not the case. In particular, the claim that article 12 would protect search engines is misinformed, as everybody can read for themselves. None of the safe harbour provisions in the E-commerce directive are  applicable to search engines. A few EU countries have established safe harbour provisions for information location tools, in the absence of regulation at the EU level, but except for Austria they follow the hosting provider model, thereby establising a DMCA type of regime for defamatory search results. The result is opaque notice and takedown for search engine results that are defamatory or link to defamatory information.

I have followed search engine liability in Europe closely. To my knowledge, Google has never publicly took a stand on the absence of clear and transparent liability rules for search services, as it seems to be doing now in Argentina. From the perspective of transparency and freedom of expression, there is much room for improvement in the EU. Yahoo has argued for more legal certainty for search engine providers in response to a consultation in the UK that addressed search engine liability. Google did not respond to that consultation.

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