GDPR Right to Be Forgotten Request Template (2026)

Why the Grounds Statement Is Everything

Google processes hundreds of thousands of right to be forgotten requests each year. The review is not performed by a court or a regulator. It is performed by trained content reviewers working through a high volume of submissions, applying a structured framework derived from Article 17 of the GDPR and the guidelines issued by the European Data Protection Board (EDPB).

Those reviewers are looking for a specific legal argument, not a personal story. The moment a submission identifies a qualifying ground under Article 17(1), the reviewer's job shifts from gatekeeping to evaluation. Until that moment, the reviewer's job is simply to categorize the request as qualifying or non-qualifying. A request that does not state a ground is automatically non-qualifying.

Article 17(1) of the GDPR sets out the conditions under which a data subject has the right to obtain erasure of personal data. There are six subsections. The most commonly applicable in news article contexts are:

• a
  Article 17(1)(a): The personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed. This is the most frequently cited ground for old news articles about private individuals whose circumstances have changed since publication.
• c
  Article 17(1)(c): The data subject objects to processing under Article 21(1) and there are no overriding legitimate grounds for the processing. This ground requires a separate objection statement and is more complex to argue successfully.
• d
  Article 17(1)(d): The personal data has been unlawfully processed. This applies where the original publication of the data, or its continued indexing, lacks a lawful basis under Article 6. It is the most powerful ground when applicable but requires a clear showing of unlawfulness.
• e
  Article 17(1)(e): The personal data has to be erased for compliance with a legal obligation. This most commonly applies in the context of court-ordered suppression, spent convictions under national rehabilitation law, or specific regulatory directives requiring removal.

Identifying the correct subsection is not optional. It is the foundational element of the request. Every other component, the specific URLs, the proportionality argument, the supporting documentation, exists to support the grounds statement. Without the grounds statement, those components are irrelevant to the reviewer.

The Anatomy of a Successful RTBF Request

A well-structured GDPR erasure request directed at Google has five components. Each must be present. The absence of any one component weakens the request materially, and the absence of the grounds statement makes the request non-reviewable.

1. Identity of the Data Subject

You must identify yourself as the person whose data appears in the indexed content. This means your full legal name, your country of EU residence (establishing GDPR jurisdiction), and, if your name has changed since the article was published, your name at the time of publication. Google's form asks for this information directly. Do not conflate this with a general description of the content; state who you are and why the article pertains to you specifically.

2. Specific URLs

The request must list each URL you are seeking to have delisted, not the publication name, not a general description of the content. Each URL should be the exact address of the indexed page as it appears in Google search results for your name. Copy the URL directly from the address bar after clicking through from search results. Requests submitted with approximate or partial URLs cannot be acted upon.

If the same article appears on multiple domains or has been republished by aggregators, each URL must be listed separately. A single request can include multiple URLs, but each must be individually specified. Google delist decisions are URL-specific, not publication-wide.

3. The Legal Ground Under Article 17

Name the specific subsection. Write "Article 17(1)(a) of the GDPR" or the applicable variant. Then explain in two to three sentences why that ground applies to your circumstances. Do not list multiple grounds hoping one will stick; identify the strongest applicable ground and argue it specifically. Citing multiple subsections without explaining why each applies signals to reviewers that you do not have confident grounds for the request.

4. The Proportionality Argument

Even where a qualifying ground exists, Google must balance your privacy interest against the public's interest in accessing the information. The RTBF is not absolute; Article 17(3) carves out exceptions for freedom of expression, public interest, and journalism. Your proportionality argument is your rebuttal to those carve-outs. It should establish that you are a private individual rather than a public figure, that the information is no longer current or relevant, that the passage of time has reduced any legitimate public interest, and that the harm to you from continued indexing is concrete and ongoing.

5. Supporting Documentation

Documentation is not required by Google's form, but it substantially improves outcomes. The most effective supporting documents are those that corroborate the legal ground being cited: court orders, acquittal certificates, rehabilitation certificates, regulatory clearance letters, or official records showing that the underlying matter has been resolved. For identity verification, a government-issued ID is typically sufficient. Redact any information in supporting documents that is not directly relevant to the request before submission.

The Templates: Three Scenarios

The following templates are designed to be copied into Google's RTBF form or into a formal written request. Replace all [PLACEHOLDER] fields with your specific information. Do not leave placeholder text in the submission. Each template is calibrated to a specific scenario; use the one that most closely matches your circumstances.

Template 1: Old News Article About a Private Individual

Use this template when the article was published about you as a private person, the events described are no longer current, and you have not voluntarily entered public life in the intervening period.

Template 2: Resolved Criminal Matter (Spent Conviction or Acquittal)

Use this template when you were charged with or convicted of a criminal offence that has since been resolved through acquittal, dismissal, or by reaching spent status under your national rehabilitation law. The grounds shift to Article 17(1)(a) for acquittals and Article 17(1)(e) where national law creates a specific legal obligation of erasure for spent convictions.

Template 3: Outdated Business or Professional Coverage

Use this template when the article concerns your professional conduct or a business matter, the underlying issue has been resolved, and you are not a current public figure whose conduct in a professional role is a matter of ongoing legitimate public concern. This is a harder case than the private individual template because public interest arguments are stronger for professional conduct, so the proportionality argument must be correspondingly more detailed.

What NOT to Write

Certain types of content in a GDPR erasure request do not merely fail to help; they actively harm the submission by signaling to reviewers that no qualifying legal ground underlies the request. The following categories appear frequently in rejected submissions and should be avoided entirely.

Emotional Appeals and Personal Narratives

An emotional appeal communicates to a reviewer that you are aware of no legal argument for removal. The reviewer's evaluation criteria are entirely legal. Personal suffering is not a ground under Article 17. Writing about emotional impact does not establish necessity, lawfulness, proportionality, or any other evaluative criterion the reviewer is applying. It also increases the risk that the reviewer categorizes the request as one where the requester "simply disagrees with the content," a category that is explicitly non-qualifying under RTBF guidelines.

Threats and Legal Ultimatums Directed at Google

Do not threaten Google with litigation, data protection complaints, or regulatory action in the body of the RTBF request. Threats do not accelerate review or improve outcomes. If you intend to file a DPA complaint, do so after receiving a rejection, as a separate formal step with the appropriate authority. A threat in a submission signals adversarial intent without providing any legal basis that the reviewer can act on.

Vague or Incorrect Legal Citations

Citing "GDPR" generally without identifying a specific article and subsection is insufficient. Citing Article 17 without the applicable subsection is insufficient. Citing ECHR Article 8 (right to private life) without connecting it to a GDPR ground is legally irrelevant to the form submission, which is not a court filing. Citing the US right to be forgotten (which does not exist as a legal doctrine) or California's CCPA in a request about EU search domains is a grounds mismatch that results in automatic rejection.

Requests Directed at Google.com

Google's RTBF mechanism operates on EU and EEA search domains: google.co.uk, google.fr, google.de, google.it, google.es, and equivalent country-specific domains. The GDPR applies to data subjects who are resident in the EU or UK. Requests submitted about google.com results fall outside the geographic and legal scope of the mechanism. If you are concerned about google.com results, the applicable pathway is a separate deindexing request or a suppression strategy. For more on the distinction, see our guide on how to file a Google right to be forgotten request.

Arguments That the Article Is Unfair Without Arguing It Is Inaccurate or Outdated

"Unfairness" is not a legal ground under Article 17. An article that you consider biased, one-sided, or contextually incomplete does not thereby become unlawfully processed data. If the article contains specific, documentable factual inaccuracies, that is a stronger argument under Article 17(1)(d), but it requires identifying the inaccuracy specifically and providing evidence of the correct facts. A general complaint about editorial framing does not establish any legal ground for erasure.

Key Phrases That Carry Weight in Google's Review

Google's RTBF reviewers work from guidelines published by the EDPB and informed by the Court of Justice of the European Union's decisions in cases including Google Spain (C-131/12) and GC and Others (C-136/17). Certain phrases appear in those guidelines as relevant factors in the balancing exercise. Using them deliberately and accurately in your proportionality argument signals to reviewers that you understand the legal framework and are engaging with it seriously.

These phrases should appear in your request in the context of facts that make them accurate, not as boilerplate without supporting substance. A reviewer who reads "I am a private individual" immediately after identifying you as a prominent politician will discount the submission. Use the language because it describes your situation, not because it sounds like it should work.

Google RTBF Form vs. DPA Complaint Letter

There are two distinct channels for pursuing the right to be forgotten against Google's EU search results, and they require different documents, different formats, and different audiences. Confusing them leads to submissions that are filed in the wrong place or that use the wrong register for their intended recipient.

The Google RTBF form submission is a request directed at Google LLC as a data controller, asking it to voluntarily delist URLs from EU search results. It is filed through Google's online form at myaccount.google.com/delete-services-or-account. The audience is Google's content review team. The tone should be factual and legal but not adversarial. The templates above are calibrated for this channel. Google is required to respond within one month under Article 12 GDPR.

The DPA complaint letter is a formal filing with your national data protection authority, alleging that Google has failed to comply with its obligations under the GDPR by rejecting a legitimate erasure request. It is filed with the ICO (UK), CNIL (France), DPC (Ireland), or the equivalent authority in your member state after receiving a rejection from Google. The audience is the regulator, not Google. The tone is formal and reads as a complaint, not a request. It references Google's rejection letter, explains why the rejection is incorrect in law, and asks the DPA to investigate and direct Google to comply.

Most data protection authorities will not accept an RTBF complaint unless the requester has first submitted to Google and received a rejection. The rejection letter from Google serves as a prerequisite for DPA filing. Keep a copy of every communication with Google, including the submission confirmation, the rejection letter, and the specific rejection language Google uses, because the DPA complaint must respond to that language specifically. For more on what to do after a rejection, see our guide on how to appeal a Google RTBF rejection.

Template: DPA Complaint Letter After Google Rejection

The following template is for a complaint to a data protection authority after Google has rejected your RTBF request. Adapt the authority name, your member state, and the specific rejection language you received. This is a formal complaint letter, not a web form submission.

After Submitting: What to Expect

Google is legally required to respond to an Article 17 erasure request within one month of receipt. In practice, acknowledgment emails typically arrive within a few days. The substantive decision, whether approval or rejection, typically arrives within three to six weeks. For complex requests, Google may extend the response period by a further two months, but it must notify you of the extension within the initial one-month window.

If Google approves the request, the delisted URLs will stop appearing in search results for searches of your name on EU search domains. The delisting applies to results surfaced by name searches; it does not remove the article from the publisher's website or from search results on non-EU domains. Other people searching for the article directly, rather than searching for your name, may still be able to find it. The article itself remains published; only its indexation under your name in EU search results is affected.

Reading a Rejection

Google's rejection language is formulaic, but it is informative. Common rejection reasons and what they typically mean:

• 1
  "The content appears to be about your professional life or business conduct." Google has determined that the public interest in professional accountability outweighs your privacy interest at this time. This does not mean the request fails permanently. A resubmission that demonstrates you are no longer active in the relevant role, or that provides documentation of resolution, can overcome this rejection reason.
• 2
  "The content appears to relate to a public figure." Google has categorized you as a public figure. If this categorization is incorrect (you were a private individual who received unusual coverage), the resubmission should address this directly with evidence of your private status, including absence of ongoing public role, absence of voluntary public engagement, and the involuntary nature of the original coverage.
• 3
  "We were unable to identify sufficient grounds under the applicable legal framework." This is Google's generic rejection for submissions that do not identify a qualifying Article 17 ground. A resubmission using one of the templates above, with a specific Article 17 subsection cited, is the appropriate response. This rejection does not indicate that the content is ineligible; it indicates that the submission did not establish eligibility.
• 4
  "The content relates to criminal convictions." For requests about criminal records, Google applies heightened scrutiny because of the sensitivity and the ongoing public interest in criminal accountability. This rejection is best challenged at the DPA level, where the DPA can evaluate whether national rehabilitation law creates a legal obligation that overrides Google's balancing decision. See our detailed guide on the right to be forgotten for criminal records and arrests.

For articles that relate specifically to news coverage rather than general search results, our guide on GDPR right to be forgotten for news articles covers the specific considerations that apply when the content you are seeking to delist was published by a news organization claiming journalistic purpose.

Approach Comparison: Success Probability by Request Type

Common Questions About GDPR Erasure Requests