Right of erasure (or “right to be forgotten”) has been selected by the European Data Protection Board as its priority enforcement topic for 2025. This work is being done under the “Coordinated Enforcement Framework” or “CEF.” The EDPB created the CEF in 2022 as a way to streamline and coordinate enforcement across EU data protection authorities. Past topics have included the right of access, and the role of data protection officers in organizations.
Data Protection Authorities in the various member states (and seven state-level authorities in Germany) this year will examine how companies are complying with GDPR obligations around erasure requests. The topic was selected, the EDPB indicated, because it is the most common right requested by individuals . . . and also the one about which DPAs often receive complaints.
As they did with the actions for right of access, DPAs will take steps ranging from fact finding to formal investigations. The DPAs will also work together to analyze the results of the initiative, and the EDPB will publish a report at the conclusion of the initiative. This will be similar to the report issued on the 2024 right of access actions (adopted this January).
Putting It Into Practice: The announcement about the right of erasure priority, as well as the release of the right of access report, can serve as a reminder for companies to revisit their process for responding to rights requests.