EvidenceSheet

Art.17 Right to erasure (right to be forgotten)

Erase personal data without undue delay where the data is no longer necessary for the purposes it was collected or processed for, where consent is withdrawn and no other legal ground applies, where the data subject objects under Article 21(1) and there are no overriding legitimate grounds or objects to direct marketing under Article 21(2), where the data has been unlawfully processed, where erasure is required by Union or Member State law, or where the data was collected in relation to information society services offered to a child. Where the data has been made public, take reasonable steps including technical measures, allowing for available technology and the cost of implementation, to inform other controllers processing it that erasure of any links to, or copies or replications of, the data has been requested. The obligation does not apply to the extent processing is necessary for freedom of expression and information, for compliance with a legal obligation or a public interest task, for public health reasons, for archiving, research or statistics under Article 89(1) where erasure would seriously impair those objectives, or for the establishment, exercise or defence of legal claims.

Source: GDPR, Art.17. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open GDPR in the compliance library.

Many articles apply only where their condition is met (a data protection officer under Article 37, an impact assessment under Article 35, a representative under Article 27); the condition is in each statement.

5
artefacts
0
held by a system
2
at each review
hard
to go live
Data governance / DLP tooling
where the evidence lives
teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

none for this control

periodic reviewEvidence produced at each review

  • Erasure records showing the ground relied on, the decision, and the date the data actually left each system · Data governance / DLP tooling
  • Evidence of the reasonable steps taken to inform other controllers where the data had been made public · Data governance / DLP tooling

governing documentDocuments that govern the control

  • A deletion capability map covering production, replicas, warehouses, logs, search indexes, backups and processors, with method and lag for each · Policy repository / GRC workspace
  • Where an exemption is applied, the specific Article 17(3) ground and the necessity reasoning for the data actually retained · Policy repository / GRC workspace
  • Processor deletion confirmations obtained under the Article 28(3)(g) contract term · Vendor register / contract repository

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

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Art.16 Right to rectification · Art.18 Right to restriction of processing