Why was the right to be forgotten being extended to the United States in 2016, and what was Google doing about it? After Google had steered European users towards google.com rather than google.co.uk, google.fr and its other European domains, the French data protection regulator, CNIL, told Google in 2015 that when it delisted a search result under the right to be forgotten it must do so on every version of its search engine, wherever the person searching happened to be. The effect of that order was to extend the European right to the United States and, in practice, to the rest of the world. Google refused, was fined €100,000, and appealed. In the meantime it had begun to remove some results on the basis of defamation rather than data protection, which allowed it, for the time being, to avoid delisting outside the complainant’s own jurisdiction. I presented on the practicalities of the right at the Internet Law Leadership Summit in Miami, Florida, on 9 December 2016.
What was decided
Google won. In September 2019 the Court of Justice of the European Union held in Google v CNIL (C-507/17) that European law requires a search engine to delist across the European Union, using geo-blocking to stop a searcher in Europe reaching the result through google.com, but does not require it to delist worldwide, because the balance between privacy and freedom of information is struck differently around the world and the European legislature had not chosen to impose its own answer on everyone else. The French court then annulled CNIL’s fine. The position for a British applicant is the same in outline: a successful request removes the result from Google’s UK versions and from searches made from the United Kingdom, and no further. The American internet remains, on this question, out of reach. How to make a request that succeeds within those limits is in Making successful right to be forgotten requests to Google.
First published 5 December 2016. Reviewed and updated 28 September 2026.