ARTICLE
14 March 2025

Forget It!: EDPB Announces Focus On Right To Erasure In 2025

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Sheppard Mullin Richter & Hampton

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Sheppard Mullin is a full service Global 100 firm with over 1,000 attorneys in 16 offices located in the United States, Europe and Asia. Since 1927, companies have turned to Sheppard Mullin to handle corporate and technology matters, high stakes litigation and complex financial transactions. In the US, the firm’s clients include more than half of the Fortune 100.
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.
Germany Privacy

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.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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