Right of erasure

The exercise of this right, described in article 20 of the LQPD, means that you can request the person responsible to delete your personal data when any of the following circumstances occur:

        Your personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed.

        The processing of your personal data has been based on the consent that you gave to the controller, and you withdraw the same, provided that the aforementioned processing is not based on another cause that legitimizes it.

        You have opposed the processing of your personal data by exercising the right of opposition in the following circumstances:

·       The processing of the controller was based on the legitimate interest or in the fulfillment of a mission of public interest, and no other reasons have prevailed to legitimize the processing of your data.

·       Your personal data is subject to direct marketing, including the preparation of profiles related to said marketing.

·       Your personal data has been illegally processed.

        Your personal data must be deleted to comply with a legal obligation.

        The data is from minors and the processing is related to information society services.

In addition, both the GDPR and the LQPD, by regulating this right, connect it in a certain way with the so-called "right to be forgotten", so that this right of deletion is extended in such a way that the controller that has made public personal data is obliged to instruct any other data controllers that are processing them to delete any link to them, or copies or replicas of the relative data.

However, this right is not unlimited, in such a way that it may be feasible not to proceed with the deletion when the processing is necessary for the exercise of freedom of expression and information, for the fulfillment of a legal obligation, for the fulfillment of a mission carried out in the public interest or in the exercise of public powers vested in the controller, for reasons of public interest, in the field of public health, for purposes of archiving in the public interest, for scientific or historical research or for statistical purposes, or for the formulation, exercise or defense of claims.

You can download the form to exercise it here.

Commentary

The right to erasure, also known as the "right to be forgotten", is considered one of the particular innovations introduced by the EU General Data Protection Regulation (GDPR) in May 2018, and by the LQPD in May 2022. More specifically, it is a further elaboration of the right to erasure contained in articles 12, letters b) and c) and 14, letter a) of the Data Protection Directive 95/46/CE[1] to which the previous LQPD of Andorra was adapted. Its development is a clear example of the modernization of European data protection standards to be up to date. Its added role in our Law recognizes its growing importance in today's society, in which personal data is generated, made public and shared on a large scale, as an instrument for the data subject to maintain some control over personal data.

Although the right to erasure is a well-established data protection right, the "right to request Internet browser removal" (typically referred to as the "right to be forgotten") has proven more controversial in recent years, because of freedom of expression and general human rights concerns among many civil society groups.

 

Last updated: May 17, 2022