Are You Inadvertently Processing European Criminal Conviction Data? The Overlooked Impact of GC v CNIL

Google continues to drive the development in case law of the Court of Justice of the European Union (CJEU) on the right to be forgotten in two recent cases.

A lot of the media attention in Europe has focused on Google's 'major victory' in Google v CNIL (Case C-507/17), according to which the EU General Data Protection Regulation (GDPR) did not require Google to de-list search engine results globally following a successful de-listing request in the EU. The CJEU noted, however, that while the GDPR did not require global de-listing, it did not prohibit it. Therefore, EU member states' courts and data protection authorities would have jurisdiction to determine whether, in light of national standards, a search engine operator would also need to de-list globally.