27 April 2019

Exercising my Right to be Forgotten Again

For a second time, I exercised my Right to Erasure (GDPR Article 17). This one took some time, but after escalating it to the correct offices, my request has been addressed.

See, I have been curating my online presence. If you search for my name online, then you'll find plenty of things about me. Most of the results point to my blog, so that is expected. But some results are outdated information, and these are the ones that I am targeting. Last time, I had an outdated CV that was somehow floating around. So I reached out and asked that it be deleted. This time, I wanted an entry of mine in an online public community directory be deleted.

See, many years ago, before GDPR was even a thing, I registered in this directory. It's a directory that was intended to the academic community, and since I was a member of this community, at that time I figured it wasn't a bad idea. However, years passed by and now I am not a member of this community. So I wanted my entry deleted.

I emailed the webmaster back in February. But a month passed and I didn't receive any response. So I emailed them again, and this time, I involved some relevant authorities. The directory was hosted by an academic department in a university in the United States, so I involved the department. I also involved the Privacy Officer of the university, who immediately replied and provided a tracking number. The reply was firm and mentioned that if I didn't receive any response, then I should involve them again, as they definitely support my request.

Of course, after this escalation, the webmaster responded. At first the webmaster claimed that they are not in scope of the GDPR. But I pointed out to them that in fact they are, even though they are a controller based outside the EU. As long as they are processing personal data of data subjects that are resident in the EU, then the long arm of the GDPR applies to them. And so I made them aware that they are in fact processing data of EU residents and are therefore under scope.

I haven't heard from them afterwards, but yes, they did delete my entry.

I have a few other places where I want to exercise my right to be forgotten, but we'll tackle them one at a time.

2 comments:

  1. I'm glad that most results (if not all) point to my blog or my pictures, especially considering I have a fairly rare last name.

    ReplyDelete
    Replies
    1. Zhu,

      Funny, twenty years ago this wouldn't even be an issue at all. Sometimes I wonder given the technological advances what problems we'd be facing in the next couple decades.

      Delete