Art.18 Right to restriction of processing
Restrict processing on request where the data subject contests the accuracy of the data, for a period enabling the controller to verify it; where the processing is unlawful and the data subject opposes erasure and asks for restriction instead; where the controller no longer needs the data but the data subject requires it for the establishment, exercise or defence of legal claims; and where the data subject has objected under Article 21(1), pending verification of whether the controller's legitimate grounds override theirs. Restricted data may be stored but otherwise processed only with the data subject's consent, for legal claims, for the protection of another person's rights, or for reasons of important public interest. Inform the data subject before a restriction is lifted.
Source: GDPR, Art.18. 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.
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
- Restriction records showing the ground, the date applied, and the date and reason for lifting · Data governance / DLP tooling
- Evidence the data subject was informed before each restriction was lifted · Data governance / DLP tooling
- Testing showing restricted records are excluded from downstream processing, marketing selections and analytics · Data governance / DLP tooling
- Evidence of the Article 19 notification to recipients following each restriction · Regulator portal / correspondence
governing documentDocuments that govern the control
- The technical mechanism that enforces restriction, such as a flag that blocks processing rather than one that is advisory only · Policy repository / GRC workspace
First move
Common gaps auditors find
- Restriction implemented as a note on the record that no system enforces, so processing continues unchanged
- Restriction lifted the moment the accuracy check completes, with no prior notice to the data subject
- Restricted records still flowing into exports, reports and model training because only the customer facing application reads the flag
- No distinction maintained between restriction and erasure, so the request is actioned as a deletion the data subject did not ask for
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.
Build my evidence sheetArt.17 Right to erasure (right to be forgotten) · Art.19 Notification obligation regarding rectification, erasure or restriction