Rights to Erasure and Restriction of Processing
The right to erasure (right to be forgotten) applies in defined situations and requires deletion even from backups unless an exemption applies. As an alternative, the right to restriction marks stored data to limit future processing.
The Right to erasure (right to be forgotten) applies where data is no longer necessary, consent is withdrawn with no other legal ground, the subject objects with no overriding legitimate grounds, data was unlawfully processed, erasure is legally required, or data was collected to offer information society services to children.
A valid erasure request requires deleting the data including from backup systems, unless an exemption applies (e.g., legal obligation or legal claims). Where the controller made the data publicly available online, it must take reasonable measures to inform other controllers to erase links or copies.
As an alternative, Restriction of processing means marking stored data to limit future processing - by moving it to another system, making it unavailable to users, or removing it from a website. It applies while accuracy is contested, where processing is unlawful but the subject prefers restriction over erasure, where the controller no longer needs the data but the subject needs it for legal claims, or while a legitimate-interest objection is being verified.
Controllers must communicate any rectification, erasure, or restriction to each recipient to whom they disclosed the data, unless impossible or disproportionate. The recipients must be documented in the record of processing activities.