The right to be forgotten is the right to have a search engine stop returning particular results when someone searches for your name. It does not remove the page from the internet and it does not rewrite history; it removes the signpost. For most people who are troubled by an old news report, a spent conviction, a court listing or a page that is simply out of date, that is enough, because the search for their name is where the damage is done. This is how to make a request that succeeds.
Where the right comes from
The right was created by the Court of Justice of the European Union in Google Spain v Costeja (C-131/12) in May 2014, which held that a search engine processes personal data and that a person may require it to delist results that are inadequate, irrelevant, no longer relevant or excessive. Since the United Kingdom left the European Union the right rests on Article 17 of the UK GDPR, the right to erasure, read with the Data Protection Act 2018, and it is enforced by the Information Commissioner and the courts here. The leading English case is NT1 and NT2 v Google [2018] EWHC 799 (QB), in which two businessmen with old convictions asked Google to delist reports of them: one succeeded and one failed, and the judgment sets out the factors that decide such cases.
What Google weighs
A request is a balance between your privacy and the public’s interest in finding the information. The factors that matter most are these.
- Your role in public life. A private individual has a strong claim; a politician, a senior executive, a professional in a regulated field or anyone whose conduct the public has a legitimate interest in has a weaker one, at least for information about that role.
- The nature of the information. Health, sexuality, family matters and financial detail weigh in your favour. Information about your professional conduct, especially where you still do the same work, weighs against you.
- Time. The older the information and the less it says about who you are now, the stronger the request. A spent conviction under the Rehabilitation of Offenders Act 1974 is a strong card, though not a trump: in NT1 and NT2 the businessman who had shown remorse and moved on won, and the one who had not, and still traded on the same reputation, lost.
- Accuracy. Inaccurate, misleading or incomplete information is easier to delist, and a page that has been corrected or has had a judgment in your favour added to the record supports the request.
- The source. Journalism, court records and official registers carry more public-interest weight than a forum post, a review or a page written by someone with a grudge, which are usually the easiest results to remove.
Making the request
Requests go through Google’s removal form. The form asks for the URLs, the search terms that return them, usually your name, and an explanation. The explanation is where requests are won and lost. Address the factors above one by one, in plain terms, with dates; say what the page contains, why it is no longer relevant to your life, what has changed since, and why no one now has a legitimate interest in finding it under your name. Attach evidence: proof of identity, a certificate of a spent conviction, a correction, an apology, a court order. Do not argue that the page is defamatory or should never have been written, which is a different claim and one Google will not decide. Each URL is assessed separately, so a request that lists twenty results with one paragraph of reasons will usually fail on most of them, while a request that deals with each in turn tends to succeed.
What delisting covers
A successful request removes the results from Google’s UK versions and from searches made from the United Kingdom, whichever domain is used. It does not remove them worldwide: the European court held in Google v CNIL (C-507/17) in 2019 that global delisting is not required, and Google applies the same approach here. The results are removed only for searches of your name, so a search for the event itself may still find the page. The page itself stays online, and the same request has to be made, separately, to Bing and to any other search engine.
If Google says no
Google refuses a large share of requests, often with a standard reason. A refusal is not the end. You can reply with further evidence, and it is worth doing, because the first decision is frequently made on the form alone. You can complain to the Information Commissioner, who can order delisting, or apply to the court, which is what NT1 and NT2 did. And you can go to the source: the website that published the page owes you the same right to erasure, and a page that has been taken down disappears from every search engine without a request. Where the source will not act and the author can be identified, the remedies against the author, in defamation, privacy or harassment, remain available; the delisting request is usually the first step, not the only one. Cohen Davis prepares and pursues these requests, including the appeals.
First published 10 January 2015. Reviewed and updated 28 September 2026.