EvidenceSheet

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.

5
artefacts
0
held by a system
4
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

  • 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

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.17 Right to erasure (right to be forgotten) · Art.19 Notification obligation regarding rectification, erasure or restriction