A client approaching this request for the first time almost always phrases it the same way: "take this article off the internet." The reality of the legal instrument is far narrower and more technical. The right to be forgotten lets you remove a specific link from a specific search engine's results for a specific query — typically, a person's full name. The source page itself stays on the server, remains accessible via a direct link, can still be indexed by other search engines, and may still appear in other jurisdictions. The difference between "removing a link from search results" and "deleting information from the internet" isn't a technical nuance — it's the foundation for realistic expectations about everything that follows.

For business owners, senior executives, and private individuals with international assets, this distinction matters even more: decisions by banks, consulates, and deal counterparties increasingly hinge on what shows up in an open search by name. For more on how that works, see "Digital Profile and International Compliance." The right to be forgotten is one tool for managing that picture — but far from the only one, and not a universal fix.

The Spaniard Who Sued Google — and Why It Changed the Rules for Every Search Engine

In 2014, the Court of Justice of the European Union heard what looked like a private dispute: a Spaniard named Mario Costeja González demanded that Google remove a link to a 1998 notice about the forced sale of his property over debts — an old, long-irrelevant story that nonetheless surfaced first when his name was searched. The newspaper that had originally published the notice had done nothing wrong and refused to take the material down — a legally sound position. The court asked a different question: is a search engine, which merely aggregates other people's content, responsible for what it displays when someone searches a specific name?

The court's answer became the foundation of the right to be forgotten as we know it today: a search engine operator is an independent "data controller" and, on request from an individual, must stop displaying links to information that has become inadequate, irrelevant, or excessive — even when the underlying publication is lawful and remains on the source website. The ruling in Google Spain SL, Google Inc. v. AEPD and Mario Costeja González split the fate of a search result from the fate of the page itself — previously treated as one and the same, and legally two separate questions ever since 2014.

Russian law codifies the same logic in Article 10.3 of Federal Law No. 149-FZ — in force since January 1, 2016 (introduced by Federal Law No. 264-FZ) — giving citizens the right to require a search engine operator to stop displaying links to information that is inaccurate, unlawfully disseminated, outdated, or no longer relevant, subject to the exceptions discussed below.

The practical takeaway for anyone encountering this tool for the first time: a granted request removes a link from a specific search engine's index (Google separately, Yandex separately) for a specific name, typically within a defined jurisdiction. The source page isn't deleted, the site isn't blocked, and the information keeps being indexed by other search engines and stays accessible in other countries. That's what fundamentally separates the right to be forgotten from removing material at the source — a mechanism covered in "Removing a Wikipedia Article: How It Actually Works" — and from SEO suppression, which doesn't remove a link from the index but reduces its visibility by promoting other content instead (more in "SEO Reputation Management: How to Suppress Negative Content from Google and Yandex Top Results").

Five Myths That Get in the Way of a Sober Assessment

Myth 1: Anyone — Including a Company — Can File a Right-to-Be-Forgotten Request

Reality: this is a personal right belonging to an individual with respect to their own personal data — only that person or their legal representative can use it. Legal entities aren't subjects of this right at all: a company can't file a right-to-be-forgotten request about itself or on behalf of its employees or executives. The toolkit for organizations is different — a business reputation claim under Article 152 of the Russian Civil Code, working directly with the source publication, or systematic SEO reputation suppression. Confusing these mechanisms is a common reason a formally correct request gets rejected at the first stage as filed by the wrong type of claimant.

Myth 2: If the Request Is Approved, the Article Disappears from the Internet

Reality: only the link in a specific search engine's results for a specific name is removed — the source page stays on the server and remains accessible directly, through other search engines, or from other countries.

Myth 3: Approval in One Country Applies Everywhere Else

Reality: every jurisdiction and every search engine reviews the request separately. A favorable decision on Yandex has no effect on Google's results in another country, and vice versa — more on this in the jurisdictions section below.

Myth 4: If Information Is Unpleasant, That's Grounds Enough for Removal

Reality: you need formal grounds — inaccuracy, obsolescence, disproportionality. There are also hard exceptions where a request will almost certainly be denied: information of significant public interest affecting a broad group of people; the exercise of duties in a current public office; an unexpunged conviction for a serious offense; or active, unresolved litigation.

Myth 5: A Lawyer or Agency Can Guarantee the Outcome and the Timeline

Reality: the decision belongs to the search engine operator, not the applicant or their representative; if denied, the next step is a regulator or the courts. A responsible approach means a realistic probability assessment based on the type of grounds involved — not a promised result.

Legal Grounds Across Jurisdictions

The right to be forgotten isn't a single global standard — it's a patchwork of national and regional rules that differ in wording, review timelines, and the territorial reach of a decision. That matters most for clients with assets, citizenship, or business interests in more than one country: a favorable ruling in one jurisdiction doesn't automatically carry over into another.

Russia. Article 10.3 of Federal Law 149-FZ — the applicant approaches the search engine operator directly (Yandex, or Google with respect to results shown to Russian users), specifying the exact links and grounds; if refused, the next step is the courts.

European Union and the United Kingdom. Article 17 of the GDPR (General Data Protection Regulation) — the "right to erasure," which operates alongside the Regulation's other grounds (inaccurate data, no lawful purpose for processing, an objection to processing). After Brexit, the UK applies its own version — the UK GDPR — with similar logic but a separate regulator, the ICO.

United States. There's no direct federal equivalent of the right to be forgotten — largely because of the First Amendment, which protects freedom of speech and the press even where information is unpleasant or outdated. Narrower mechanisms do exist: California's so-called "online eraser law" (California Business and Professions Code § 22581) lets minors demand removal of content they themselves posted on a platform. Outside that exception, the available tools are different — DMCA takedown notices for copyright infringement, and defamation claims where the information isn't just unwelcome but factually false.

UAE and other jurisdictions with recent data-protection legislation. Several countries in the Gulf and Asia have adopted their own personal-data-protection laws in recent years (for example, the UAE's Federal Personal Data Protection Law), partly borrowing GDPR logic, including the right to correct and erase data. Enforcement practice under these frameworks is still far less developed than in the EU, and both the scope and speed of compliance differ noticeably from the European experience.

Multi-jurisdictional situations — where the same information is indexed across different countries and language versions of search results — require coordinating several legal tracks at once, not filing a single universal request.

Case Study · 3 Jurisdictions The Investor Who Googled and Walked Away Search result synchronization across Italy, the US, and the UK in 7 months — exactly the kind of multi-jurisdictional coordination described above. Read the case study →

"The right to be forgotten is a precise legal instrument with a narrow scope: one link, one search engine, one jurisdiction, one specific ground. A durable reputation in the digital environment is a different order of outcome — it comes from systematic work across sources, compliance databases, and search results simultaneously, not from a single successful request, however well-founded."

Aegis Reputation Lab Team

AEGIS Perspective

What Filing a Single Request Looks Like in Practice

A composite, illustrative example drawn from several real cases without reference to any specific client: a senior executive discovers that a five-year-old article about a long-closed and settled legal dispute with a former business partner sits on Google's first page for his name. The publication contains nothing false, but the case was resolved long ago, and the dispute no longer reflects the person's current business standing. Formally, this is exactly the kind of case where the right to be forgotten applies — not false information, but information that has become outdated and disproportionate to the person's current status.

  1. Audit and scope definition. The exact list of URLs, search engines, and jurisdictions is fixed, along with the formal ground — in this case, obsolescence and disproportionality, not inaccuracy.
  2. Building the evidentiary record. Confirmation of the applicant's identity, plus documents establishing that the dispute is closed and doesn't reflect current status — the court order terminating the case and its effective date.
  3. Filing the formal request. Google's form is completed with a precise legal formulation of the ground — not "this harms my reputation," but a specific category (obsolescence, disproportionality) and the complete list of URLs.
  4. Escalation and monitoring. If the operator refuses or asks for clarification, the next step is a regulator complaint or the courts; once approved, monitoring continues to make sure the same link doesn't get reindexed under a different URL.

The weak point is almost always the same one — the first step. A vague list of URLs and jurisdictions almost guarantees a request for clarification or a rejection for lack of specificity; a fuzzy statement of grounds at step three works just as poorly as no statement at all.

How Long This Actually Takes, and the Odds of Approval

Technical error / clear data mismatch3–6 weeks
Outdated or no-longer-relevant information6–12 weeks
Disputed classification / disproportionate mention2–4 months
Complex multi-jurisdictional case6 months to a year
An averaged model based on typical scenarios (scale: weeks up to a year) — not a guaranteed timeline for any specific case

Neither Yandex nor Google publishes or discloses exact approval rates to applicants, and neither commits to a review timeline — no agency or lawyer can honestly promise otherwise. The one thing that can be assessed in advance is a qualitative likelihood based on the type of ground involved. Technical errors and clear factual inaccuracies (name collisions, outdated personal data) are typically reviewed faster and approved more often, since they don't require weighing competing interests. Cases where the information is technically accurate but disproportionate to the person's current status, or that span several jurisdictions at once, require more extensive legal analysis and are more likely to end up escalated to a regulator complaint or the courts.

Right to Be Forgotten vs. Other Removal and Suppression Tools

The right to be forgotten is just one tool in the set, and it's often confused with adjacent but fundamentally different mechanisms. Here's how they compare on the key parameters.

MechanismWhat it removesWho can fileGroundsWhen to use it
Right to be forgottenA link from a specific search engine's results for a nameIndividuals onlyInaccuracy, obsolescence, disproportionality (149-FZ, GDPR Art. 17)Information is formally outdated or excessive, but the publication itself is lawful
Claim under Art. 152 of the Russian Civil Code (protection of honor and business reputation)Compels a retraction or removal of false information at the sourceIndividuals and companiesInformation is factually false and damages reputationThe publication is actually false, not just outdated
Removal at the source / DMCAThe publication or material itself on the source platformRights holder, data subject, or the platform under its own rulesCopyright infringement, platform rule violation, court orderThe material needs to come down entirely, not just move in search results — see the Wikipedia case
SEO reputation suppressionThe visibility of unwanted material in top search results (not the link itself)Individuals and companiesA commercial objective, without approaching the search operatorThe material is formally lawful and can't be removed — see the SEO reputation methodology
Correcting a record in a compliance database (World-Check and similar)An inaccurate or outdated record in a closed screening databaseThe individual (subject of the record)A Subject Access Request, the right to rectify and erase data (GDPR)The problem isn't search visibility but banking/compliance screening — see the article on World-Check and PEP status

What to Do If Your Request Is Denied

A denial from a search engine operator isn't the end of the process — it's a signal to revisit the wording and grounds of the request: the reason for refusal is often that the stated ground was too general or doesn't fall within the categories recognized by law. The next step is a complaint to the relevant regulator: Roskomnadzor in Russia, the ICO (Information Commissioner's Office) in the UK; in certain cases — particularly where the issue is business reputation rather than the right to be forgotten as such — a claim under Article 152 of the Russian Civil Code applies instead.

If a link is formally lawful and doesn't fall under any ground for delisting, yet is still reputationally damaging — for instance, it presents true facts in an unflattering light without distorting them — a legal instrument is powerless here by definition. That's where an alternative or complementary approach comes in.

Service Negative Content Suppression Discuss →

Frequently Asked Questions

What to Do Next

If an outdated, inaccurate, or disproportionate publication ranks under your name on Google or Yandex, the first step isn't filing a request and hoping for the best — it's an audit: which links formally qualify for delisting, and which will need a different tool — a reputation claim, work with the source, or SEO reputation suppression. This article is informational and doesn't substitute for legal advice; the specific grounds and prospects of a request depend on the details of the situation and the jurisdiction involved.

Aegis Reputation Lab conducts these audits confidentially, benchmarks a digital profile against compliance risk requirements, and — where it makes sense — folds delisting into broader work on building an individual's digital profile, alongside compliance risk assessment. Contact us to discuss your situation.