Google and the Right to Be Forgotten

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Google and the Right to Be Forgotten

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Google and the Right to Be Forgotten

Google and the Right to Be Forgotten1
In 2009, Mario Costeja Gonzalez, a self-employed attorney living in a small town outside
Madrid, Spain, casually “googled” himself and was startled by what came up on his computer
screen. Prominently displayed in the search results was a brief legal notice that had appeared
more than a decade earlier in a local newspaper, La Vanguardia, which listed property seized
and being auctioned by a government agency for nonpayments of debts. Among the properties
was a home jointly owned by Costeja and his wife.
Costeja immediately realized that this information could damage his reputation as an
attorney. Equally troubling, the information was no longer factual. He had paid his debt nearly a
decade earlier. Abanlex, Costeja’s small law firm, depended on the Internet to gain much of its
new business, which was often generated by a Google search. Potential clients might choose not
to hire him, based on the old auction notice, he reflected. His mind then turned to the possible
effects of this kind of information on other people’s livelihoods. “There are people who cannot
get a job because of content that is irrelevant,” he thought.2 “I support freedom of expression and
I do not defend censorship. [However, I decided] to fight for the right to request the deletion of
data that violates the honor, dignity and reputation of individuals.”3
The next week, Costeja wrote to La Vanguardia and requested that it remove the article
about his debt notice, because it had had been fully resolved a number of years earlier and
1 By Cynthia E. Clark, Bentley University. Copyright © 2015 by the author. Used by permission.
2 “Google Privacy Campaigner Praises Search Engine for Bowing to EU,” Financial Times, May 30, 2014.
3 “The Man Who Sued Google to be Forgotten,” Newsweek, May 30, 2014.
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reference to it now was therefore entirely irrelevant.4 In doing so, he was making use of his
rights under Spain’s strong data protection policies, which recognized the protection and
integrity of personal data as a constitutional right under Section 18 of the nation’s Data
Protection Act.5 In response, the newspaper informed him that it had recently uploaded to the
Internet all its past archives, dating back to 1881, to allow them to be searched by the public. It
also noted that the auction notice had originally been publicly posted in order to secure as many
bidders as possible. The newspaper refused Costeja’s request, stating that the information was
obtained from public records and had thus been published lawfully.6
To be sure, the real problem for Costeja was not that the notice had appeared in La
Vanguardia’s digital library, but that it had shown up in the results of the most widely used
search engine in the world, Google, where potential clients might use it to judge his character.7
Following this reasoning, Costeja then wrote to Google Spain, the firm’s Spanish affiliate, only
to be told that the parent company, Google Inc., was the entity responsible for the development
of search results.8 Costeja was taken aback by this development. “The resources Google has at
4 European Parliament. Judgment of the Court, May 13, 2014, at
5 “The Unforgettable Story of the Seizure to the Defaulter Mario Costeja González that Happened in 1998,”
Derechoaleer, May 30, 2014, at
6 “Will Europe Censor this Article?” The Atlantic, May 13, 2014,
7 “The Unforgettable Story of the Seizure to the Defaulter Mario Costeja González that Happened in 1998,”
Derechoaleer, May 30, 2014,
8 V. Alsenoy, A. Kuczerawy, and J. Ausloos, “Search Engines after Google Spain: internet@liberty or
privacy@peril?” ICRI Working Paper Series, September 6, 2013, at
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their disposal aren’t like those of any other citizens,” he reflected.9 Costeja felt he would be at a
disadvantage in a lawsuit against an industry giant like Google.
In March 2010, after his unsuccessful attempts with the newspaper and Google Spain,
Costeja turned to Spain’s Data Protection Agency (SDPA), the government agency responsible
for enforcing the Data Protection Act. “Google in Spain asked me to address myself to its
headquarters in the U.S., but I found it too far and difficult to launch a complaint in the U.S., so I
went to the agency in Spain to ask for their assistance. They said I was right, and the case went to
court,” he explained.10 In a legal filing, Costeja requested, first, that the agency issue an
administrative order requiring La Vanguardia either to remove or alter the pages in question (so
that his personal data no longer appeared) or to use certain tools made available by search
engines in order to shield the data from view. Second, he requested that the agency require that
Google Spain or Google Inc. remove or conceal his personal data so that it no longer appeared in
the search results and in the links to La Vanguardia. Costeja stated that his debt had been fully
With these steps, a small-town Spanish lawyer had drawn one of the world’s richest and
best-known companies, Google, into a debate over the right to be forgotten.
Google, Inc.
Google Inc. was a technology company that built products and provides services to organize
information. Founded in 1998 and headquartered in Mountain View, CA, Google’s mission was
9 “Spain’s Everyday Internet Warrior Who Cut Free from Google’s Tentacles,” The Guardian, May 13, 2014,
10 “The Man Who Sued Google to Be Forgotten,” op. cit.
11 Court of Justice, Judgment in Case C-131/12 Google Spain SL, Google Inc. v. Agencia Española de Protección de
Datos, Mario Costeja González.
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to organize the world’s information and make it universally accessible and useful. It employed
more than 55,000 people and had revenues of $45 billion. The company also had 70 offices in
more than 40 countries.
The company’s main product, Google Search, provided information online in response to
a user’s search. Google’s other well-known products provided additional services. For example,
Google Now provided information to users when they needed it, and its Product Listing Ads
offered product image, price, and merchant information. The company also provided AdWords,
an auction-based advertising program and AdSense, which enabled websites that were part of the
Google network to deliver ads. Google Display was a display advertising network; DoubleClick
Ad Exchange was a marketplace for the trading display ad space; and YouTube offered video,
interactive, and other ad formats.
Search Technology
In its core business, Google conducted searches in three stages: crawling and indexing, applying
algorithms, and fighting spam.
Crawlers, programs that browsed the web to create an index of data, looked at web pages
and followed links on those pages. They then moved from link to link and brought data about
those web pages back to Google’s servers. Google would then use this information to create an
index to know exactly how to retrieve information for its users. Algorithms were the computer
processes and formulas that took users’ questions and turned them into answers. At the most
basic level, Google’s algorithms looked up the user’s search terms in the index to find the most
appropriate pages. For a typical query, thousands, if not millions, of web pages might have
helpful information. Google’s algorithms relied on more than 200 unique signals or “clues” that
made it possible to guess what an individual was really looking for. These signals included the
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terms on websites, the freshness of content, the region, and the page rank of the web page.12
Lastly, the company fought spam through a combination of computer algorithms and manual
review. Spam sites attempted to game their way to the top of search results by repeating
keywords, buying links that passed Google’s PageRank process, or putting invisible text on the
screen. Google scouted out and removed spam because it could make legitimate websites harder
to find. While much of this process was automated, Google did maintain teams whose job was to
review sites manually.13
Policy on Information Removal
Google’s policy on the general removal of information was the following:
Upon request, we’ll remove personal information from search results if we
believe it could make you susceptible to specific harm, such as identity theft
or financial fraud. This includes sensitive government ID numbers like U.S.
Social Security numbers, bank account numbers, credit card numbers and
images of signatures. We generally don’t process removals of national ID
numbers from official government websites because in those cases we
consider the information to be public. We sometimes refuse requests if we
believe someone is attempting to abuse these policies to remove other
information from our results.14
Apart from this general policy, Google Inc. also removed content or features from its search
results for legal reasons. For example, in the United States, the company would remove content
with valid notification from the copyright holder under the Digital Millennium Copyright Act
12 Information on PageRank is available online at
13 Information about Google search is available online at
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(DMCA), which was administered by the U.S. Copyright Office. The DCMA provided recourse
for owners of copyrighted materials who believed that their rights under copyright law had been
infringed upon on the Internet.15 Under the notice and takedown procedure of the law, a
copyright owner could notify the service provider, such as Google, requesting that a website or
portion of a website be removed or blocked. If, upon receiving proper notification, the service
provider promptly did so, it would be exempt from monetary liability.
Google regularly received such requests from copyright holders and those that
represented them, such as the Walt Disney Company and the Recording Industry Association of
America. Google produced and made public a list of the domain portions of URLs that had been
the subject of a request for removal, and noted which ones had been removed. As of July 2015, it
had removed more than 600,000 URLs out of more than 2.4 million requests.16
Likewise, content on local versions of Google was also removed when required by
national laws. For example, content that glorified the Nazi party was illegal in Germany, and
content that insulted religion was illegal in India.
17 The respective governments, via a court order
or a routine request as described above, typically made these requests. Google reviewed these
requests to determine if any content should be removed because it violated a specific country’s
When Google removed content from search results for legal reasons, it first displayed a
notification that the content had been removed and then reported the removal to, a website established by the Electronic Frontier Foundation and several
15 Information about Digital Millennium Copyright Act (“DMCA”) notice procedure is available at
16 Information about the removal process is available online at
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law schools. The Chilling Effects database collected and analyzed legal complaints and requests
for removal of a broad set of online materials. It was designed to help Internet users know their
rights and understand the law. Researchers could use the data to study the prevalence of legal
threats and the source of content removals. This database also allowed the public to search for
specific takedown notifications.
Google removed content quickly. Its average processing time across all copyright
infringement removal requests submitted via its website was approximately 6 hours. Different
factors influenced the processing time, including the method of delivery, language, and
completeness of the information submitted.
The Right to Be Forgotten
The right to be forgotten can be understood as peoples’ right to request that information be
removed from the Internet or other repositories because it violated their privacy or was no longer
relevant. This right assumed greater prominence in the digital era, when people began finding it
increasingly difficult to escape information that had accumulated over many years, resulting in
expressions such as “the net never forgets,” “everything is in the cloud,” “reputation
bankruptcy,” and “online reputation.”19 According to Jeffrey Rosen, professor of law at George
Washington University, the intellectual roots of the right to be forgotten could be found in
French law, which recognized le droit à l’oubli—or the “right of oblivion”—a right that allowed
a convicted criminal who had served his time and been rehabilitated to object to the publication
of the facts of his conviction and incarceration.”20
18 The Berkman Center for Internet & Society at
19 “The Unforgettable Story of the Seizure to the Defaulter Mario Costeja González that Happened in 1998,” op. cit.
20 “Will Europe Censor this Article?” op. cit.
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Although the right to be forgotten was rooted in expunging criminal records, the rise of
the Internet had given the concept a new, more complex meaning. Search engines enabled users
to access information on just about any topic with considerable ease. The ease with which
information could be shared, stored, and retrieved through online search raised issues of both
privacy and freedom of expression. On the one hand, when opening a bank account, joining a
social networking website or booking a flight online, a consumer would voluntarily disclose vital
personal information such as name, address, and credit card numbers. Consumers were often
unsure of what happened to their data and were concerned that it might fall into the wrong
hands—that is, that their privacy would be violated.
On the other hand, by facilitating the retrieval of information, search engines enhanced
individuals’ freedom to receive and impart information. Any interference with search engine
activities could therefore pose a threat to the effective enjoyment of these rights.21 As Van
Alsenoy, a researcher at the Interdisciplinary Center for Law and Information Communication
Technology, argued, “In a world where search engines are used as the main tool to find relevant
content online, any governmental interference in the provisioning of these services presents a
substantial risk that requires close scrutiny.”22
Since the 1990s, both the European Union and its member states (such as Spain) had enacted
laws that addressed the right to privacy and, by extension, the right to be forgotten.
A fundamental right of individuals to protect their data was introduced in the EU’s
original data protection law, passed in 1995. Specifically, the European Data Protection

21 Alsenoy et al., 2013.
22 Alsenoy et al., 2013.
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Directive 95/46 defined the appropriate scope of national laws relating to personal data and the
processing of those data. According to Article 3(1), Directive 95/46 applied “to the processing of
personal data wholly or partly by automatic means, and to the processing otherwise than by
automatic means of personal data which form part of a filing system or are intended to form part
of a filing system.”23 Article 2(b) of the EU Data Protection Directive 95/46 defined the
processing of personal data as:
“any operation or set of operations which is performed upon personal data,
whether or not by automatic means, such as collection, recording, organization,
storage, adaptation or alteration, retrieval, consultation, use, disclosure by
transmission, dissemination or otherwise making available, alignment or
combination, blocking, erasure or destruction.”
Individual countries within the European Union also enacted their own laws, which were
sometimes stronger than those of the EU. For example, in Spain, the protection of data was a
constitutional right. The Spanish Constitution recognized the right to personal privacy, secrecy of
communications, and the protection of personal data. These rights were protected through the
Data Protection Act (the “Act”), passed in 1999, which incorporated the 1995 European
Directive on data protection, and was enforced by the Spanish Data Protection Agency (SDPA).
Created in 1993, this agency was relatively inactive until the passing of the Act, which gave it
more powers and a mandate to enforce privacy rules in a wide range of situations.24
The Spanish agency exercised its powers broadly. For example, in 2013, it fined telecom
firm Telefonica SA €20,000 for twice listing an individual’s phone number in local phone books
without the individual’s prior consent. In 2008, the agency fined a marketing company €600 for
23 Alsenoy et al., 2013.
24 “Data Protection in Spain” June 24, 2010, at
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using “recommend this to a friend” icons on websites, saying that senders of recommendation emails had to first request the recipient’s permission. The agency had also successfully required
anyone using security cameras to clearly mark their presence with a recognizable icon.
Supporters of this move have highlighted the importance of transparency in protecting one’s
Over time, however, differences in the way that each EU country interpreted privacy
rights led to an uneven level of protection for personal data, depending on where an individual
lived or bought goods and services. This led the European high court to take a second look, in
2013, at the original law.26 A European Commission memo at that time noted that the right “is
about empowering individuals, not about erasing past events or restricting freedom of the
press.”27 The changes were intended to give citizens more control over their personal data,
making it easier to access and improve the quality of information they received about what
happened to their data once they decided to share it. An unanswered question, however, was the
latitude given to national courts and regulators across Europe to set the parameters by which
these requests could be made.28
The United States
U.S. courts had taken a very different approach to privacy and to the right to be forgotten. A few
U.S. laws recognized the right to be forgotten; the Fair Credit Reporting Act of 1970, for
example, gave individuals the right to delete certain negative information about their credit—
such as late payments, tax liens, or judgments—seven years from the date of the delinquency.
25 “Spanish Agency Behind the Google Ruling Lauded by Some, Hated by Others,” The Wall Street Journal, June
26, 2014.
26 “What is the ‘Right to Be Forgotten?’” The Wall Street Journal, May 13, 2014.
27 European Commission, “LIBE Committee Vote Backs New EU Data Protection Rules”, October 22, 2013, at
28 “What is the ‘Right to Be Forgotten?’” op. cit.
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But, for the most part, fundamental differences in legal philosophy made this right less likely to
become widely supported in the United States. In an article published in the Atlantic in May
2014, Matt Ford suggested that in the U.S. context, one person’s right to be forgotten logically
imposed a responsibility to forget upon someone else, a notion that was alien to American law.
The First Amendment to the Constitution barred the government from interfering with free
speech. Law professor Rosen argued that the First Amendment would make a right to be
forgotten virtually impossible, not only to create but to enforce. For example, the U.S. Supreme
Court ruled in 1989 that penalizing a newspaper for publishing truthful, lawfully obtained
information from the public record was unconstitutional.29
The Lawsuit and Court Decision
The main focus of Costeja’s complaint before Spanish Data Protection Agency (SDPA) was his
request that La Vanguardia remove the debt notice from its archives. In doing so, he was
claiming his constitutional right to protect the integrity of his personal data. Costeja’s request
had two parts: that (1) La Vanguardia be required either to remove or alter the pages in question
or to use certain tools made available by search engines in order to protect the data and (2) that
Google Spain or Google Inc. be required to remove or conceal the personal data relating to him
so that the data no longer appeared in search results.
In July 2010, two months after Costeja’s original request, the SDPA ordered Google
Spain and Google Inc. to take “all reasonable steps to remove the disputed personal data from its
index and preclude further access,” upholding that part of the complaint.30 However, the SDPA
29 “Will Europe Censor This Article?” op. cit.
30 Audiencia Nacional. Sala de lo Contencioso, Google Spain SL y Google Inc., S.L. c. Agencia de Protección de
Datos, paragraph 1.2, at
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rejected Costeja’s complaint as it related to La Vanguardia, because it considered that the
publication by it of the information in question was legally justified.31
A year later, Google filed an appeal against the decision by the SDPA before the
Audiencia Nacional in Madrid, Spain’s highest national court. In March 2012, this court referred
the case to the European Court of Justice, the EU’s high court, for a preliminary ruling.32
In their briefs, Google Spain and Google Inc.’s argument hinged on the meaning of
“personal data” and “crawling.” Crawling, as noted above, was the use of software programs to
find multiple websites that responded to requests for information online.
33 These programs were
configured to look for information on the Internet, according to a set of criteria that told them
where to go and when.
34 Once the relevant web pages had been copied and collected, their
content was analyzed and indexed.35 Google compared its search engine index to an index at the
back of a textbook, in that it included information about words and their locations.
Specifically, Google argued before the European Court of Justice that because it crawled
and indexed websites “indiscriminately” (that is, without a deliberate intent to process personal
data as such), no processing of personal data within the meaning of Article 2 (b) of the EU Data
Protection Directive 95/46 actually took place. This absence of intent, the company argued,
31 “Spanish Agency behind the Google Ruling Lauded by Some, Hated by Others,” Wall Street Journal, June 23,
2014 at
32 Alsenoy et al., 2013.
33 See
34 Matt Cutts (Google Quality Group Engineer), How Search Works, s30-s44, available at
35 Alsenoy et al., 2013.
36 More information about crawling is available online at
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clearly distinguished Google’s activities as a search engine provider from the processing of
personal data as interpreted by the Court.
Google’s other main argument was that the publisher of the information should be the
sole controller of data, not the search engine. After all, its attorneys argued, Google’s
intervention was purely accessory in nature; it was merely making information published by
others more readily accessible. If a publisher, for whatever reason, decided to remove certain
information from its website, this information would (eventually) be removed from Google’s
index and would no longer appear in its search results. As a result, Google’s counsel argued, the
role of a search engine should be thought of as an “intermediary.”
In May 2014, the European Court of Justice ruled against Google. The court found the
Internet search provider was responsible for the processing of personal data that appeared on web
pages published by third parties. It further required Google to remove links returned in search
results based on an individual’s name when those results were deemed to be “inadequate,
irrelevant or no longer relevant, or excessive.” At the heart of the court’s logic was the process
that Google used to produce its search results. The official ruling explained the court’s rationale:
The Court points out in this context that processing of personal data carried out
by such an operator enables any Internet user, when he makes a search on the
basis of an individual’s name, to obtain, through the list of results, a structured
overview of the information relating to that individual on the internet. The Court
observes, furthermore, that this information potentially concerns a vast number
of aspects of his private life and that, without the search engine, the information
could not have been interconnected or could have been only with great
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In essence, the Court ruled that an activity, “whether or not by automatic means” could be
considered to be the “processing of personal data” within the meaning of Article 2(b), even if no
intention to process such data existed.
38 The court’s ruling applied to any search engine operators
that had a branch or a subsidiary in any of the 28 member states of the EU.39
Costeja’s lawyer, Joaquín Muñoz, was pleased with the ruling. “When you search for
something in Google, they don’t scour the entire Internet for you and then give you a result.
They’ve stored links, organized them, and they show them based on a criteria they’ve decided
upon.”40 As for Costeja, he expressed satisfaction with the result of his four-year legal crusade.
Speaking of the court’s decision, he said, “I think this is the correct move. You have to provide a
path for communication between the user and the search engine. Now that communication can
take place.”41
Google’s Application of the Ruling
For its part, Google—although disappointed with the ruling—set about complying with it. Soon
after the court decision, it removed Costeja’s disputed information from its search results. But,
the company also took more general action.
37 Court of Justice. Judgment in Case C-131/12 Google Spain SL, Google Inc. v Agencia Española de Protección de
Datos, Mario Costeja González.
38 European Parliament. Judgment of the Court. May 13, 2014, at
39 European Commission, “Fact sheet on the Right to be Forgotten,” at
40 “Spain’s Everyday Internet Warrior Who Cut Free from Google’s Tentacles,” op. cit.
41 “Google Privacy Campaigner Praises Search Engine for Following to EU,” Financial Times, May 30, 2014.
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The Court’s decision recognized Google as a data controller, or the operator of the search
engine and the party responsible for its data. As such, the court said, Google was required to
police its links and put into place a mechanism to address individual concerns. Accordingly,
shortly after the ruling was announced, Google set up an online form for users (from the
European Union only) to request the right to be forgotten. The company website stated that each
request would be evaluated individually and that Google would attempt to “balance the privacy
rights of the individual with the public’s interest to know and the right to distribute
information.”42 Once an individual had filled out the form, he or she received a confirmation.
Each request was assessed on a case-by-case basis. Occasionally, Google would ask for more
information from the individual. Once Google had made its decision, it notified the individual by
e-mail, providing a brief explanation if the decision was against removal. If so, the individual
could request that a local data protection authority review Google’s decision.
In evaluating a request, Google looked at whether the results included outdated or
inaccurate information about the individual. It also weighed whether or not the information was
of public interest. For example, Google generally retained the information if it related to
financial scams, professional malpractice, criminal convictions or a government official’s public
At the same time, Google invited eight independent experts to form an advisory council
expressly to “advise it on performing the balancing act between an individual’s right to privacy
42 “Search Removal Request under Data Protection Law in Europe,” at
43 Frequently Asked Questions, at
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and the public’s interest in access to information.”44 The committee included three professors
(two of law and one of ethics), a newspaper editorial director, a former government official, and
three privacy and freedom of speech experts (including one from the United Nations). Google’s
CEO and chief legal officer served as conveners. The committee’s job was to provide
recommendations to Google on how to best implement the EU court’s ruling.
The majority recommendation of the advisory council, published on February 6, 2015,
was that the right to be forgotten ruling should apply only within the 28 countries in the
European Union.
45 As a practical matter, this meant that Google was only required to apply
removals to European domains, such as or, but not, even
when accessed in Europe. Although over 95 percent of all queries originating in Europe used
European domains, users could still access information that had been removed via the site.
The report also explained that once the information was removed, it was still available at
the source site (e.g., the newspaper article about Costeja in La Vanguardia). Removal meant
merely that its accessibility to the general public was reduced because searches for that
information would not return a link to the source site. A person could still find the information,
since only the link to the information had been removed, not the information itself.
The advisory council also recommended a set of criteria Google should use in assessing
requests by individuals to “delist” their information (that is, to remove certain links in search
results based on queries for that individual’s name). How should the operator of the search
engine best balance the privacy and data protection rights of the subject with the interest of the
44 The Advisory Council to Google on the Right to be Forgotten, February 6, 2015, at
45 “Limit ‘Right to Be Forgotten’ to Europe, Panel Tells Google,” The New York Times, February 6, 2015.
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general public in having access to the information? The authors of the report felt that whether the
data subject experienced harm from such accessibility to the information was relevant to this
balancing test. Following this reasoning, they identified four primary criteria for evaluating
delisting requests:
• First, what was the data subject’s role in public life? Did the individuals have a clear
role in public life (CEOs, politicians, sports stars)? If so, this would weigh against
• Second, what type of information was involved? Information that would normally be
considered private (such as financial information, details of a person’s sex life, or
identification numbers) would weigh toward delisting. Information that would
normally be considered to be in the public interest (such as data relevant to political
discourse, citizen engagement, or governance) would normally weigh against
• Third, what was the source of the information? Here, the report suggested that
journalistic writing or government publications would normally not be delisted.
• Finally, the report considered the effect of time, given that as circumstances change,
the relevance of information might fade. Thus, the passage of time might favor
The advisory council also considered procedures and recommended that Google adopt an easily
accessible and easy-to-understand form for data subjects to use in submitting their requests.
The recommendations of the advisory council were not unanimous. Jimmy Wales, the
cofounder of Wikipedia and one of the eight group members, appended a dissenting comment to
the report. “I completely oppose the legal situation in which a commercial company is forced to
become the judge of our most fundamental rights of expression and privacy, without allowing
Google – 18
any appropriate procedure for appeal by publishers whose work in being suppressed,” Mr. Wales
wrote. “The recommendations to Google contained in this report are deeply flawed due to the
law itself being deeply flawed.”46
Discussion Questions
1. In what ways has technology made it more difficult for individuals to protect their
2. Do you believe an individual should have the right to be forgotten, that is, to remove
information about themselves from the Internet? If so, should this right be limited, and
if so, how?
3. How does public policy with respect to individual privacy differ in the United States
and Europe, and what explains these differences?
4. Do you think Google should be responsible for modifying its search results in response
to individual requests? If so, what criteria should it use in doing so? Are there limits to
the resources the company should be expected expend to comply with such requests?
5. If you were a Google executive, how would you balance the privacy rights of the
individual with the public’s interest to know and the right to distribute information?
46 Ibid.
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