How the 2025 EU Coordinated Enforcement on the Right to Erasure Will Impact Organizations: What Data Controllers Need to Know

How the 2025 EU Coordinated Enforcement on the Right to Erasure Will Impact Organizations: What Data Controllers Need to Know

As of March 2025, the European Data Protection Board (EDPB) has initiated a significant coordinated enforcement action focusing on the right to erasure, also known as the “right to be forgotten,” under Article 17 of the GDPR. This initiative involves thirty Data Protection Authorities (DPAs) across Europe, along with the European Data Protection Supervisor, aiming to scrutinize how organizations handle erasure requests and apply the relevant conditions and exceptions.

Overview of the 2025 CEF Initiative

The 2025 Coordinated Enforcement Framework (CEF) is a comprehensive effort to ensure that organizations comply with the GDPR’s right to erasure. The scope of this initiative includes investigations and fact-finding missions to assess compliance levels across various sectors. Participating authorities are set to evaluate how effectively organizations are managing erasure requests and adhering to the legal requirements.

Why the Right to Erasure is Under Scrutiny

The right to erasure is one of the most frequently exercised rights under the GDPR and a common source of complaints. This right allows individuals to request the deletion of their personal data under specific circumstances, making it a critical area for regulatory focus. The 2025 CEF aims to address these concerns by ensuring that organizations are not only aware of their obligations but are also implementing them effectively.

What Organizations Should Expect

Organizations should prepare for a range of investigations and fact-finding exercises conducted by DPAs. These may include audits, interviews, and reviews of documentation related to erasure requests. The potential for follow-up actions, such as enforcement measures or fines, underscores the importance of compliance.

Best Practices for Compliance

To navigate the complexities of the right to erasure, organizations should:

  • Develop clear policies and procedures for handling erasure requests.
  • Train staff on the importance of data protection and the specifics of the right to erasure.
  • Document decisions regarding erasure requests meticulously, including the rationale for any refusals.
  • Understand exceptions to the right to erasure, such as legal obligations or public interest considerations.

Potential Outcomes and Implications

The findings from the 2025 CEF are expected to influence future enforcement and guidance at both national and EU levels. Organizations that proactively address compliance may not only avoid penalties but also gain a competitive advantage by building trust with consumers and stakeholders.