Cybersecurity Policy Report, Questionnaire on Data Erasure Compliance Published by German Regulator, (Apr 15, 2025)
By Tony Foley
The data protection authority for the German federal state of Baden-Württemberg (LfDI Baden-Württemberg) published a self-check questionnaire yesterday aimed at parties responsible for implementing the right to erasure (or “right to be forgotten”) under article 17 of the European Union’s General Data Protection Regulation (GDPR).
In March, the European Data Protection Board (EDPB) launched its bloc-wide coordinated enforcement action (CEF) on how the right to erasure was being implemented in the EU. LfDI Baden-Württemberg is one of 32 data protection authorities (DPAs) participating in the CEF (CPR, March 5).
The questionnaire, launched as part of the CEF, is designed to serve as a means of self-monitoring for people responsible for implementing the erasure right. LfDI Baden-Württemberg noted that deficiencies in the handling of article 17 erasure requests may become apparent when data subjects assert their rights or in the context of data protection authority proceedings. The agency added that the questionnaire provided examples of questions DPAs could ask about article 17 in such proceedings. Responsible parties are invited to participate in the survey on a voluntary basis.
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