Launch of Coordinated Enforcement Action on the Right to Erasure

11 March 2025

The Information and Data Protection Commissioner (IDPC) is pleased to announce its participation in the European Data Protection Board’s (EDPB) 2025 Coordinated Enforcement Framework (CEF).  

Following the CEF action on the right of access carried out in 2024, the CEF’s focus this year is once again on the implementation of a data protection right, namely the ‘Right to Erasure’ (or as is it commonly referred to the ‘Right to be Forgotten’) in terms of Article 17 of the GDPR. The main reason behind the selection of this topic by the EDPB is the fact that it is considered as one of the most frequently exercised GDPR rights and ultimately one about which Data Protection Authorities (DPAs) frequently receive queries or complaints from affected data subjects. The right to erasure enables individuals to have their data erased by a data controller. It is not an absolute right but only applies in certain circumstances. Furthermore, there are also exceptions to the application of this right. 

In total 32 Data Protection Authorities, including IDPC, across Europe will be taking part in the CEF throughout 2025. The IDPC will be taking part in this CEF by sending out questionnaires to data controllers across the private sector as a fact-finding exercise. In particular, it will analyse how data controllers handle and respond to requests for erasure they receive and how they apply the conditions and exceptions for the exercise of this right. As in previous CEF actions, the results will be then aggregated and analysed to generate a deeper insight from a local perspective into the topic.

Background

The CEF is aimed at streamlining enforcement and cooperation among DPAs. This current CEF exercise is the third initiative under this action in which the IDPC is taking part. Prior to this it contributed to:

The 2024 CEF action on the right of access - https://www.edpb.europa.eu/our-work-tools/our-documents/other/coordinated-enforcement-action-implementation-right-access_en

The 2023 CEF actions on the designation and position of Data Protection Officers - https://www.edpb.europa.eu/our-work-tools/our-documents/other/coordinated-enforcement-action-designation-and-position-data_en