This article is correct as of 12th November 2019
THE CONCEPT OF THE RIGHT TO BE FORGOTTEN and THE ANALYSIS OF THE RESULTS OF DECISION NO. ECJ-131/12 RENDERED BY THE EUROPEAN COURT OF JUSTICE
The European Court of Justice (ECJ), by accepting the concept of the “Right to Be Forgotten” on May 23, 2014 by means of decision numbered ECJ C-131/12, has made a tremendous impact on the Internet ecosystem. ECJ adjudged by means of the aforementioned decision that results of the searches for private names which are inadequate, irrelevant or which become excessive in relation to the purposes for which they are collected in the course of time shall be removed upon request of the related individuals.
This decision, the content of which is positioned at the intersection of personal data protection and human rights law, has been subject to many misinterpretations and criticism as it involves many constituents to be considered both technically and psychologically.
In the first part of this study, the concept of the “Right to Be Forgotten” as well as other aspects thereof will be discussed in a doctrinal context; the decision of the ECJ will be analyzed in the second part, whereas the implementations and explanations following the decision will be handled in the third part, and finally, an overall assessment will be carried out.
A. THE RIGHT TO BE FORGOTTEN, THE RIGHT TO FORGET, THE RIGHT OF OBLIVION
Even though the concept of the Right to Be Forgotten has been discussed on various platforms in the member states of the European Union as well as the United States of America, it attracted the attention of the public to the fullest in November 2010 through a communication from the European Commission.
The EU Commission announced by means of a communication that the right to be forgotten was regulated directly as a digital right within the scope of the European Union Data Protection Regulation that was planned to be accepted in mid-2015. Even though Directive 95/46 currently in force produces the result of benefiting from the right to be forgotten for the individuals, the matter is not specifically included as a separate topic in the current legislation. However, the Draft Regulation covers the right to be forgotten as an individual title under Article 17 (Right to be Forgotten and to Erasure). In this respect, these two concepts are used together, and in fact the right to be forgotten is used as a subcategory of the right to erasure.
The EU, whose data protection policies may be considered to be individual-oriented compared to those of the U.S., introduced the right to be forgotten as a digital right the origins and implications of which have already been brought before the judicial authorities many times in France, Germany, Spain and the U.S. under different implications. One of these implications and the earliest legal institution which unfortunately is often confused with the right to be forgotten today is “The Right of Oblivion”.
The Right of Oblivion is defined as a right that allows a convicted criminal who has served his/her time to request the removal of the facts of this crime in order to be a part of society again. The right is based on “the right of privacy” which is intended to avoid any possible damages that may be imposed on the reputation, personality, identity and recognition of the individual.
The right to erasure is the main title of the right to be forgotten, and it provides the data subject with the right to request personal data processed by third parties related with him/her to be erased. Therefore, the intended purpose of this right is to establish a balance between the data subject and the data processor by providing the data subject with the right to be involved in the processing operations during data processing related to him/her.
In this respect, the right of oblivion exists independently from the digital world in the sense that it is aimed at establishing the balance between the right of the public to demand information and the personal rights as well as the right of privacy, while the right to erasure is about requesting personal data to be erased in case it does not have a legitimate processing foundation in terms of the principles of the data processing law. Since analog data processing methods are barely used at the present time and data processing operations are mainly carried out digitally, the right to erasure is also recognized as a digital right.
Another distinction concerning the right to be forgotten is between the right to be forgotten and the right to forget. Rouvroy makes a distinction between these two rights with respect to the perspectives of the actors involved in the action of being forgotten. Accordingly, the right to be forgotten is associated with third parties and about their obligation of forgetting, while the right to forget refers to the right of directly the individual to forget his/her past.
In this respect, it must be stressed that the decision to be analyzed below is directly associated with “the right to be forgotten” and the interpretations and assessments about the decision must be established in line with the legal institutions related to the aforementioned right to be forgotten.
B. ANALYSIS OF THE SCOPE AND THE EFFECTS OF THE DECISION ON THE RIGHT TO BE FORGOTTEN
B.1. Google Spain, Spain Data Protection Agency Case No ECJC-131/12 before the European Court of Justice
The history of the dispute in decision no ECJ C-131/12 rendered on May 23, 2014 by the European Court of Justice (ECJ) is based on an internet announcement with regard to the auction for the real estate of Mario-Costeja Gonzales, a Spanish lawyer, organized following attachment proceedings against him due to his social insurance debts.
Upon the announcement being published in 1998 in Lan Vanguardia, a Spanish newspaper, it came up constantly as a result of the searches made in his name. Gonzales filed a complaint in 2009 at the Spanish Data Protection Agency (Agencia Española de Protección de Datos – AEPD) against Lan Vanguardia, Google and Google Spain and requested the removal of the aforesaid announcement.
The Spanish Data Protection Agency, with a decision rendered in 2010, denied the request for such removal from the newspaper on the grounds that the subject news was published lawfully with the intention of meeting a legal obligation, however, it also decided for the removal of the link which brought up the aforesaid news as a result of the Google searches made in the name of the plaintiff.
In another sense, the Agency accepted that the announcement published in the newspaper was a data processing operation conducted lawfully since the announcement was published by the Ministry of Labor and Social Security. However, as is known, the lawfulness of each data processing action must be assessed individually.
In this respect, since the data processing actions of the newspaper and Google should be assessed individually, and since the ground of lawfulness that applies to the news to be published in the newspaper may not establish the grounds for Google’s indexing operation, the Agency concluded that the ground of lawfulness was not available in Google’s action.
Google and Google Spain declared that they did not agree with this decision and filed an action against the decision before the Supreme Court of Spain. The Supreme Court of Spain, during the proceeding carried out, requested an opinion on three matters from the ECJ acting as an advisory board for the local courts in the member states of the EU.
The questions extended to the ECJ by the Court were as follows:
- Can EU Directive 95/46/EC titled “The protection of individuals with regard to the processing of personal data and on the free movement of such data” be applied to search engines (Google, Yahoo, etc.)?
- When it is considered that the data processing server of Google Spain is physically in the U.S., can the European Union legislation be applicable to this company?
- Does an individual have the right to block access through the search engine to personal data related to him/her even if it is published lawfully?
Briefly, the ECJ accepted the following in its decision dated May 13, 2014:
- With regard to the EU Directive 95/46/EC being applicable to search engines (Google, Yahoo, etc.); search engines are regarded as data controllers, therefore they have legal responsibility within the scope of EU Directive 95/46/EC (para 41) and such responsibility cannot be denied by depending on the search engine status,
- With regard to physical servers being located in a geography other than that of an EU member; even if the data processing server of a company is located in a country that is not a member of the European Union, in case the concerning company –even if its field of activity is related to advertisement services intended for the search engine– has a branch in an EU member state, the EU legislation may be applicable (para 60),
- With regard to the right to be forgotten; in case the data of the individual appears to be inadequate, irrelevant or no longer relevant, or have become excessive over time in relation to the purposes of the processing, the individual has the right to request that the links providing access to such data are erased from the list of results of the searches made in his/her name (para 94).
When rendering the decision with regard to the right to be forgotten, the court expressly underlined the necessity of assessing the right to be forgotten in each event according to the event’s particular conditions.
Again, it is emphasized in the decision that in case an individual requests that a search result is erased within the scope of the right to be forgotten, there must be a careful balance between the individual’s right of privacy and the freedom of the public to access information as well as freedom of expression.
When we analyze the decision in the widest sense in the light of the aforesaid, we conclude that the ECJ adjudged that the individuals have rights on the data created by themselves or by third parties on the Internet and that in the context of EU Directive 96/46/EC, regardless of where the physical servers are located at, upon the request of individuals, the search engines providing service to consumers in Europe must erase the data, namely the links, that appear to be inadequate, irrelevant or no longer relevant, or excessive in relation to the purposes of the processing from the list of results of name based searches.
B.2. Search Engines will hereupon be regarded as “Data Controllers”
The decision rendered by the ECJ on May 13, 2014 contains a significant implementation change in terms of the legal status of search engines which has been a controversial point throughout the world for a while.
As is known, the legal status of search engines has been discussed in every jurisdiction, yet no clear conclusion has been reached. Moreover, the companies carrying out search engine activities have been subject to a sui generis legal protection due to the unique structure of the service they offer to their customers.
Accordingly, since the indexing operation performed by search engines such as Google, Yahoo, etc. had not been deemed as a data processing operation according to EU Directive 95/46/EC in the previous EU applications, the search engines were not considered as data controllers and they did not have any liabilities pursuant to EU Directive 95/46/EC.
Google, by acting from this point of view in its petition, claimed that it could not be considered a data controller and made statements regarding such liability. Google stated that;
- It collects, processes and indexes data indiscriminately and during such operation no controls are made in order to check whether the related links contain personal data, therefore it cannot be qualified as a data processor or a data controller
- The party required to take action in terms of erasure of the contents is not itself but the party that has directly provided the contents, because it does not intend to control the data that is subject to indexing, whereas the party obliged to take such action in the present case is the newspaper that has provided the related contents
- Even if it is accepted that Google carries out a data processing operation, it can never be considered as a data controller based on the facts that a) it does not intend to process the data, b) the data subject to indexing are not verified by Google as to whether they are personal data or not, c) the party publishing the content holds the final authority regarding the destiny of the subject data d) it will not be able to index a data if such data is erased from the database of the content provider, e) it cannot verify the legitimacy of the personal data processing operation, f) it plays a secondary role in the publication of data, g) The Article 29 Working Party, in the Opinion 1/2008, expressed that search engines bear the liability of intermediary service providers pursuant to the Articles 12-15 of eCommerce Directive, h) even though Google performs the data processing operation, it must be considered in the status of a Telecommunication operator that bears no liability within the context of the current Data Protection Directive.
However, despite all these claims, the ECJ emphasized through the rendered decision that Google's data operator status must be interpreted in a wider context. The ECJ, in its decision, reached the conclusion that, since Google performs the indexing operation on the data available on the Internet in a certain context of purpose and meaning, Google’s subject action was, as distinct from the previous implementation, indeed a data processing operation and in this regard, it was liable as a data controller within the scope of EU Directive 96/46.
It must be expressed at this point that even though the current case has been intensively discussed with regard to the balance between privacy and the right of the public to access information, the core matter of the case is whether Google should be considered as a data controller or not.
Considering the matter in a chain of reasoning, it is concluded that if it was not possible to qualify Google as a data controller, the discussion of balance between privacy and public interest would be beside the point, since the necessity of establishing such balance arises on the grounds that personal data is not an absolute right but a right that competes with other human rights.
In other words, by accepting Google as the data controller in the subject case, the related directive found an area of application in that personal data was deemed to exist and the right to protect personal data being a non-absolute right, competed with other human rights. Through this methodology, it can clearly be seen that the individual vs. public interest discussion is indeed a sub-discussion.
B.3. The decision will be implemented in a way limited to the erasure of the related links from the search results regarding the individual
It is explicitly expressed in the decision of the ECJ that the subject link erasure would be limited to the erasure from the search results with regard to the individual. Accordingly, the content related to the link that is decided to be erased within the scope of the right to be forgotten will continue to be displayed in the results of other search operations and the related content will continue to be available in the source web page.
The ECJ was heavily criticized for allegedly legalizing censorship when the decision on the right to be forgotten was first rendered. The ECJ defended itself by claiming that the subject decision was not censorship in any manner, because the parties benefiting from such right were not the governments but directly the individuals, furthermore the related source would continue to exist on the Internet ecosystem and therefore it was not a matter which damaged the right of the public to access information.
It must be expressed at this point that it is emphasized in the Guidelines published on November 26, 2014 by the Article 29 Working Party that nicknames and pseudonyms must also be included in the scope of the right to be forgotten.
B.4. Companies with Headquarters in the U.S. will also be affected by the “Right to Be Forgotten”
Another notable point of the decision is the fact that it is applicable with regard to the companies located both in and outside of the EU.
The Court adjudged that the fact that the servers with which Google performs the data processing operations physically are located in a country other than an EU member state does not release it from the liability arising from EU Directive 95/46/EC.
Accordingly, even though Google Spain does not carry out indexing operations but only runs advertising activities, since the company is a corporation established in accordance with the laws of Spain and the operations it carries out are related to indexing at some point, it is concluded that the activities of the company must comply with EU Directive 95/46/EC.
When the number of internet users throughout the EU member states is taken into account and when it is considered that almost all big search engines in the World with a few exceptions carry out their activities in this geography, the magnitude of the impact of the decision becomes remarkable.
The companies which were not subject to EU Directive 95/46/EC in their actions and operations regarding data protection in the past as they were based in a country other than the EU member states will here upon have to carry out their activities within the scope of such Directive when providing the EU citizens with their services, including giant names such as Yahoo and Bing. The effect created by the decision is revealed more clearly, when it is considered that these companies must carry out their activities in compliance with not only the provisions establishing the grounds for the right to be forgotten but also all other provisions of EU Directive 95/46/EC.
Obviously, Google will feel the utmost impact as it possesses the biggest share in the related market. Google is now faced with very serious liabilities in the EU where it was previously free from many of them, due to the resolutions reached by the judicial and administrative authorities of the EU in the past year. One example is the voting resolution rendered by the European Parliament on November 27, 2014 which gives the green light to the EU competition authorities to issue warnings against Google in their investigations, albeit with no executive power.
B.5. The right to be forgotten will bring forth not global but local results
Another point which should be indicated is that only the individuals living in the EU member states (Iceland, Lichtenstein, Norway and Switzerland are also included in these countries by Google) will be able to benefit from the right to be forgotten. Turkey is not listed among these countries even though it is a candidate country for EU membership. Therefore, for the time being, it does not seem possible for Turkish citizens to benefit from the right to be forgotten.
At this point, a clarification is provided in the Guidelines published by the Article 29 Working Party on November 26, 2014 regarding the implementation of this procedure in that in the implementation of the right to be forgotten, Data Protection Authorities must focus on cases where there is a clear link between the data subject and the EU, such as citizenship or residency (para 19).
On the other hand, according to statements by Google and the comments of other authorities made in the first days after the decision was rendered, in case Google recognizes as fair a request that is received within the scope of the right to be forgotten, it will not erase this result from the entire Google database, but will apply this to the domain names active in the EU member states, namely websites google.es andgoogle.fr. Hence, although the subject link is erased from the list of results within the scope of the right to be forgotten, it can still be displayed easily as a result of a search conducted on google.com.
However, upon the Guidelines published by the Article 29 Working Party on November 26, 2014, it is presumed that this application producing local results will most likely not be applicable anymore and the action will have to be implemented on the worldwide Google database in a manner to produce the same results.
This is because the Article 29 Working Party indicated in the aforementioned Guidelines that limiting the erasure operation to EU domain names on the grounds that users tend to access search engines via their national domains cannot be considered a sufficient means for satisfactorily guaranteeing the rights of data subjects. (para 20)
Personal data of individuals enter into an unlimited circulation as a consequence of the removal of borders by means of information and communication technologies. Therefore, the effects of personal data can easily be perceived in the other countries of the world as well. In this respect, the implementation of such action to a wider extent as suggested by the Article 29 Working Party is necessary from the point of view of the individual. Particularly, when it is considered that there are no obstacles against accessing the subject domain names, namely Google.com in the EU states, the necessity of such application as well as the benefits thereof are clear.
B.6. Google cannot benefit from the exception of “Freedom of the Press”
In the decision rendered, the ECJ adjudged that the data processed within the framework of freedom of the press will be assessed within the scope of the conditions of lawfulness set out in EU Directive 95/46/EC and that in this respect, the data in this nature will not be assessed within the scope of the right to be forgotten.
However, companies carrying out search engine activities cannot benefit from such exception. The reason for this is that Google is not a media entity, a status which is known to be embraced by Google in order to abstain from the legislative regulations that apply to EU media corporations.
Therefore, even though the news published on the website of the newspaper can be considered within the scope of exception in the context of “freedom of the press,” the display by Google of such news amongst the search results is not considered to be within the scope of “freedom of the press.”
This exception, undoubtedly, attracted the attention of some institutions. For instance, the BBC, with the statement made on October 17, 2014, announced that it had so far been notified of 46 links that had been removed and that it would be publishing such links on its website in the following days. Apparently, the BBC carefully studied the details of the decision and successfully read between the lines, and hence reacted against it in the most legitimate manner by publishing the related links.
At this point, even though the scope of the right to be forgotten involves only the removal of the link related to a person from the search results but not the erasure of the content from the linked source, it is expected to constitute another problem whether the website on which the BBC will publish the related links will be included in the search results or not.
The decision rendered by the ECJ with regard to the right to be forgotten that constitutes the subject of this article is expected to give rise to many discussions in terms of both data protection law and human rights law. The reason for this is that the subject matter is directly related to the privacy of individuals whereas the institutions to be effected from the implementation thereof are the backbone of the internet ecosystem as well as the key actors that enable individuals to access information on the Internet.
Therefore, it must be underlined that there are issues to pay attention to during the interpretation of the ECJ’s decision, and the misinterpretation of the decision may give rise to serious violation of freedom of expression and the right of the public to access information.
Besides, it must also be noted that the decision has so far been discussed in the public only in certain aspects. Even though the decision initially points at the liability of certain institutions and organizations with respect to personal data law for the first time, the human rights aspect has been more dominantly discussed by the public. The reason for this, in my opinion, is that whether the search engines are data controllers in the context of data protection law is a matter that can only by handled by experts.
In other words, Google and other search engines place the technical side of the matter on one side and focus on the “human rights and freedom of expression” side which may attract the attention of the public at higher levels and thus criticize the legitimacy of the decision.
However, as we have expressed above, in case the legal status of Google and other search engines is not recognized as data controllers, the liability of institutions will not arise within the scope of EU Directive 95/46/EC. In such a case, the discussion on freedom of expression and privacy as the controversial aspects of this issue will be beside the point, since personal data is not an absolute right but competes with other human rights.
On the other hand, there is also a point to be discussed in the assessment of the decision from the perspective of the Turkish Law. The decision rendered by the ECJ is about the illegal processing of the subject data within the context of personal data law. In this respect, even lawfully published content, as in the subject matter, can be considered as processed unlawfully pursuant to the related articles of EU Directive 95/46/EC and can be included in the scope of the right to be forgotten on the grounds of failure to meet the conditions prescribed by the Directive. As a matter of fact, that is why only the link is erased while the content remains on the source website.
From this point of view, the discussion as to whether “Regulating Broadcasting in the Internet and Fighting Against Crimes Committed through Internet Broadcasting” numbered 5651 in the Turkish Law provides the right to be forgotten, which has been continuing since the issuance of the decision on the right to be forgotten, is groundless. This law involves regulations directly related to illegal content as a consequence of which it regulates the obstruction of access to such sources. In this context, it can be accepted at the utmost that this law is an illusion of the right to be forgotten in the Turkish law.
In conclusion, it will be accurate to state that such a decision, in the core meaning, has brought into question once again the recent differences in the policies of the U.S. and the EU regarding data protection matters. It is well known that the U.S. has a more liberal perspective in terms of data protection policy when compared to that of the EU and the data in this nature will most probably be assessed by the U.S. within the scope of “freedom of expression” whereas the EU has recently come into the fore with individual-oriented decisions and regulations proposed in a “personal rights” based approach.
The court, in parallel with this approach, proposed also in the Google Spain case that the right of “privacy” of the individuals prevails over “freedom of expression” and the “right to access information” of the public. Therefore, this gap between the two legal orders has become more visible. However, despite this gap, Google has adopted a surprisingly moderate policy instead of taking a tough line against the ECJ decision and put the right to be forgotten into effect even before the local court rendered the decision.
The best manner of putting into practice the requests received by Google within the scope of the right to be forgotten will undoubtedly be formed as a result of the experiences gained over time and of the public discussions with regard to the implementation of the matter.
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 Communication from The Commission to The European Parliament, The Council, The Economic and Social Committee and The Committee of the Regions http://ec.europa.eu/justice/news/consulting_public/0006/com_2010_609_en.pdf
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 Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the protection of individuals with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation), http://ec.europa.eu/justice/data-protection/document/review2012/com_2012_11_en.pdf
 Rolf H. Weber, The Right To Be Forgotten: More Than a Pandora’s Box?, 2 (2011) JIPITEC 120, para 5-11
 Paul BErnal, A Right to Delete, European Journal of Law and Technology (EIJLT) 2011 (2) No.2, para 2
 Meg Leta Ambrose / Jef Ausloos, The Right to Be Forgotten Across the Pond, Journal of Information Policy, Vol.3, 2013, pp-1-23
 Aurelia Tamo and Damian George, Oblivion, Erasure and Forgetting in the Digital Age, 6(2014) JIPITEC 71 para 13 Antoinette Rouvroy/Yves Poullet, The Right to Informational Self-Determination and the Value of Sel-Development; Reassessing the Importance of Privacy for Democracy, in; Serge Gutwirth et Reinventing Data Protection?, Springer 2009, pp.45
 EU Directive 95/46/EC on the protection of individuals with regard to the processing of personal data and on the free movement of such data http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:31995L0046:en:HTML
 Okan Çan, Google Bizi de unutur mu?, http://www.fikrinizinde.com/google-bizi-de-unutur-mu/ Date of Access: 22.12.2014
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 EU ECJ, Myth-Busting
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 European Parliament Backs Investigation to Split Google Search from Its Other Businesses http://techcrunch.com/2014/11/27/google-unbundle-eu/ Date of European Parliament Backs Investigation to Split Google Search from Its Other Businesses http://techcrunch.com/2014/11/27/google-unbundle-eu/ Date of Access:22.12.2014
- Decision of the European Court of Justice no.ECJ C-131/12
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- Rolf H. Weber, The Right To Be Forgotten: More Than a Pandora’s Box?, 2 (2011) JIPITEC 120, para 5-11
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- Aurelia Tamo and Damian George, Obilivion, Erasure and Forgetting in the Digital Age, 6(2014) JIPITEC71 para 13 Antoinette Rouvroy/Yves Poullet, The Right to Informational Self-Determination and the Valueof Sel-Development; Reassessing the Importance of Privacy for Democracy, in; Serge Gutwirth etReinventing Data Protection?, Springer 2009, pp.45
- The Directive 95/46/EC of the European Union on the protection of individuals with regard to the processing of personal data and on the free movement of such data
- Article 29 Working Party, Press Release dated 19.02.2008
- EU ECJ, Myth-Busting
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- European Parliament Backs Investigation To Split Google Search From Its Other Businesses
http://techcrunch.com/2014/11/27/google-unbundle-eu/ Date of Access:22.12.2014
- BBC to publish 'right to be forgotten' removals list, http://www.bbc.com/news/technology-29658085,
Date of Access:22.12.2014
- Okan Çan, Google Bizi de unutur mu?, http://www.fikrinizinde.com/google-bizi-de-unutur-mu/ Date of Access:22.12.2014