Sep 25, 2025
Article by
Introduction
Every click, every purchase, and every interaction leaves behind a trail of personal information that businesses collect, store, and often struggle to manage. While this data is precious, it also comes with responsibility. The General Data Protection Regulation (GDPR), which came into force in 2018, set a clear standard that individuals have the right to ask for their personal data to be erased. This is popularly known as the “Right to be Forgotten.”
Even though the GDPR has been implemented for a long while, but data deletion still causes a lot of confusion. Companies often don’t know where all the data is stored, how to delete it properly, or what the law actually expects. Let’s understand why deletion is so difficult in practice, what the law states about the same, and how to build a process that’s both compliant and manageable.
What GDPR Says About Data Deletion
Article 17 of GDPR outlines the “Right to Erasure,” often referred to as the “Right to be Forgotten.” This Article gives individuals the right to request deletion of their personal data when:
The data is no longer necessary for the purpose it was collected.
Consent is withdrawn.
The data has been unlawfully processed.
The individual objects to processing, and there’s no overriding legitimate reason to keep it.
Deletion is required by law.
Importantly, this isn’t an absolute right. There are exceptions, such as when data is needed for legal claims, public interest, or compliance with other laws. But when the right applies, businesses are expected to act “without undue delay.”
Why Businesses Struggle with Data Deletion
When companies receive a deletion request, the first instinct might be to look at the customer-facing system and clear the data. But personal data rarely exists in a single place. It often exists in:
CRM platforms
Cloud storage services
Employee inboxes
Third-party vendor databases
Historical backups
The scattered nature of data is a major challenge. Add to this the fact that different teams (legal, IT, operations, marketing) may all touch the same data at different points. Without a clear roadmap, deletion requests can feel like searching for needles in multiple haystacks. Also, deletion isn’t always technically feasible. Legacy systems may not support granular deletion. Backups might be immutable. And some data may be in logs or analytics tools in ways that make removal difficult without disrupting operations
Another challenge is the tension between deletion rights and retention obligations. For example, an e-commerce company may be legally required to hold onto transaction records for a specific number of years for tax compliance. In such cases, GDPR allows retention, but the organisation must make sure that the data is not used for any other purpose.
Steps to Ensure GDPR-Compliant Data Deletion
This is a step-by-step guide to ensure GDPR compliance:
1.Data Discovery & Lineage
Identify and trace data across all systems. Without knowing exactly where personal data resides, deletion will always be incomplete.
2.Validate Requests
Before acting, verify the identity of the data subject and make sure the request is legitimate. This protects against unauthorised deletions and strengthens trust in the process.
3.Review Retention Schedule
Not all data can or should be deleted immediately. Review your organisation’s retention policies to confirm whether the requested data is eligible for erasure. For instance, financial records may require mandatory retention periods.
4.Check Overriding Clauses
GDPR allows certain exceptions where deletion may not be possible, such as compliance with legal obligations or safeguarding public interests. Always assess whether any of these apply before proceeding.
5.Timely Processing
GDPR requires that erasure requests be processed without undue delay and within a 30-day SLA. This is very crucial for the companies as it shows respect for the individual’s rights.
6.Choose Anonymisation or Deletion
In some cases, anonymising data (so it can no longer be linked to an individual) may be a better option than outright deletion. The choice should align with your business needs while respecting GDPR principles.
7.Document Everything
Maintain detailed records of each step taken. These event logs are vital for demonstrating accountability during audits or regulatory reviews.
8.Send Confirmation
Once the deletion (or anonymisation) is complete, notify the data subject. This closes the loop and reassures individuals that their request has been honoured.
Smart Strategies to Make Deletion Effortless
While compliance may sound tedious, there are ways to simplify the process, so it becomes part of everyday operations rather than an extraordinary task.
Automate Where Possible: Implement tools that automatically flag data for deletion once it reaches the end of its retention period. This prevents unnecessary accumulation.
Design Systems with Privacy in Mind: Adopt the principle of “privacy by design.” Build your databases and workflows in a way that makes it easy to isolate and remove personal data when needed.
Create Centralised Dashboards: Instead of hunting through multiple systems, a centralised interface that tracks and manages deletion requests can save hours of effort.
Segment Data Access: Limit who can access certain categories of data. The fewer places' data is duplicated, the easier it becomes to delete it effectively.
Audit Regularly: Periodic audits make sure that your processes are working as intended and help identify hidden data stores that might otherwise be overlooked.
These strategies reduce compliance risks and also build trust with customers. When people see that an organisation respects their privacy and acts promptly on their requests, it strengthens the relationship.
Why This Matters Beyond Compliance
Data privacy is a matter of trust as we are living in an era where consumers are increasingly conscious of how their information is used. They want to know it’s being handled with care and that they have control over it. Companies that handle data deletion efficiently stand out as transparent and responsible. This not only keeps regulators at bay but also enhances brand reputation. After all, a customer is far more likely to stay loyal to a company that values their privacy than one that treats it as an afterthought
Common Mistakes to Avoid
Even well-intentioned companies make errors when handling deletion requests. Some of the most common pitfalls include:
Partial Deletion: Removing data from one system but leaving it intact in others, such as backups or email chains.
Over-Deletion: Erasing information that must legally be retained, creating regulatory problems later.
Ignoring Third Parties: Failing to ensure that vendors also delete the relevant data.
Poor Documentation: Not keeping evidence of compliance, which can hurt during audits or investigations.
Delays in Response: GDPR requires that deletion requests be addressed “without undue delay.” Taking weeks to respond can expose a company to complaints and fines.
By avoiding these mistakes, businesses can make their compliance efforts more reliable and less stressful.
Conclusion
GDPR’s data deletion requirement is a necessity for building trust in the digital world. The “Right to be Forgotten” makes sure that individuals have control over their personal information, and organisations that respect this right show responsibility and integrity.
While deletion may seem complicated due to scattered data, legal retention requirements, and involvement of third parties but a structured approach makes it manageable. Mapping data, setting retention schedules, documenting processes, and training staff are simple yet effective steps that help organisations stay compliant.
More importantly, handling deletion requests efficiently shows a commitment to transparency and customer respect. Compliance should not be seen as a burden but instead as an opportunity to strengthen relationships, protect reputation, and reduce risks. strengthen relationships, protect reputation, and reduce risks.