Right to Be Forgotten: Your Right to Remove Google Search Results
Do you want to have search results removed from Google? Under Article 17 GDPR you have the right to be forgotten. MediaMaze has analyzed 45 Dutch court rulings and helps you with your removal request. Free case assessment.
Describe Your SituationThe Right to Be Forgotten: Article 17 GDPR Explained
The right to be forgotten — also known as the right to erasure — is one of the most important privacy rights in the digital age. It gives individuals the right to request the removal of personal data, including search results in Google and other search engines. This right is laid down in Article 17 of the General Data Protection Regulation (GDPR) and applies throughout the European Union.
The Google Spain Ruling (2014)
The right to be forgotten was established by the European Court of Justice on 13 May 2014 in the landmark Google Spain v. Costeja González case (C-131/12). The Court ruled that search engine operators such as Google are data controllers under data protection law and must process removal requests from individuals. If the right to privacy outweighs the public interest in the information, Google must remove the relevant search results.
Who Can Submit a Removal Request?
The right to be forgotten is a personal right. Only natural persons (individuals) can invoke it — not companies or organizations. You can submit a removal request if search results in Google link to personal data about you that is inaccurate, outdated, irrelevant, or excessive. The request can be directed at Google, Bing, DuckDuckGo, and other search engines. It is important to understand that the right to be forgotten does not remove the source itself: the original web page remains online, but the link to it is removed from search results for your name.
Article 17 GDPR: The Legal Basis
Article 17 GDPR (in the Netherlands: Article 17 AVG) provides six grounds for the right to erasure. For search engine removal requests, the most relevant ground is that the personal data is no longer necessary for the purpose for which it was collected. Additionally, the data subject can object to the processing on the basis of Article 21 GDPR. However, the right to be forgotten is not absolute: it must always be balanced against the right to freedom of expression and information, the public interest, and the right of others to access the information.
The 7 Criteria Courts Use: Analysis of 45 Court Rulings
Dutch courts do not easily grant a right to be forgotten request. Our analysis of 45 Dutch court rulings shows that approximately 78% of requests are denied. Only when the right to privacy clearly outweighs the right to information will a court order Google to remove search results. Courts apply seven criteria, derived from the Google Spain ruling and the guidelines of the Article 29 Working Party (now the European Data Protection Board).
1. Nature of the Information
The type of information is decisive. Information about criminal convictions, health data, or financial problems weighs more heavily in favor of removal than general news reports. Courts examine whether the information falls under the special categories of personal data (Articles 9 and 10 GDPR), which enjoy extra protection.
2. Sensitivity to Private Life
How deeply does the information intrude on the private life of the individual concerned? Information that relates to someone's intimate sphere, family life, or health generally receives more protection. Courts assess the severity of the privacy breach in concrete terms: does the information cause ongoing damage to the person's reputation or daily life?
3. Role of the Data Subject in Public Life
Public figures — politicians, executives, celebrities — have a reduced expectation of privacy. Information about their public functioning will not easily be removed. However, this does not mean that everything about a public figure must remain findable. Private matters that have no connection to their public role may still qualify for removal.
4. Age of the Information
The older the information, the stronger the case for removal. Information that was once relevant may have become outdated, overtaken by events, or no longer serve any legitimate purpose. Dutch courts regularly grant removal of search results about criminal cases that are decades old, especially if the person has been rehabilitated and is no longer in the public eye.
5. Relevance of the Information
Is the information still relevant for the public today? A news article about a topical event serves the public interest; an article about a minor incident from years ago usually does not. Courts weigh whether the information still contributes to public debate or is merely harmful without serving a legitimate purpose.
6. Source of the Information
The source of the information matters. Journalistic publications and government sources receive stronger protection under the right to freedom of expression than user-generated content on forums or social media. A judgment published by the judiciary itself will almost never be removed from search results. However, third-party blog posts or forum discussions about someone's personal situation may qualify.
7. Impact on Private Life
What is the concrete impact of the search results on the person's daily life? Courts look at demonstrable harm: difficulty finding employment, damaged business relationships, psychological distress, or social exclusion. The more concrete and serious the harm, the more likely the court is to grant removal. General discomfort or embarrassment is usually not sufficient.
Each of these criteria is weighed by the court in its assessment. A strong case on multiple criteria increases the chance of success. MediaMaze analyzes your situation against all seven criteria and advises you honestly about the likelihood of a successful removal.
Do You Recognize Your Situation?
The right to be forgotten applies in various situations. Below we describe the most common scenarios from our practice. Each situation requires a specific approach based on the applicable case law.
Criminal Past
If you have been convicted in the past, news articles and court rulings about your case may still appear in Google search results for your name. Particularly after rehabilitation, there are strong legal arguments for removal. Dutch courts increasingly recognize that ongoing findability of old criminal cases causes disproportionate harm.
We help you with thisOutdated News Articles
A news article about an incident from years ago can continue to define your online reputation. If the information is no longer current and its continued visibility causes damage, a removal request may be successful. This is particularly the case when the article relates to a private matter that never had public significance.
We help you with thisBusiness Information
Information about a past bankruptcy, dissolved company, or business dispute can hamper your professional career. Although the right to be forgotten formally applies only to natural persons, information about your role in a company does relate to your personal data. Courts assess whether the commercial information still serves the public interest.
We help you with thisMedical Data
Health information is a special category of personal data (Article 9 GDPR) and enjoys extra protection. If medical data about you appears in search results — for example through court rulings about care disputes or news reports — the case for removal is relatively strong.
We help you with thisSocial Media and Forums
Posts from others about you on social media, forums, or review sites can be indexed by Google and appear in search results for your name. Because this is user-generated content rather than journalistic work, courts offer it less protection. This makes removal through the right to be forgotten potentially more likely to succeed.
We help you with thisRecognize Your Situation?
Describe your situation and receive a free assessment of your removal request. Our specialists analyze your case based on current case law.
Describe Your SituationThe MediaMaze Approach: From Assessment to Removal
MediaMaze has over 15 years of experience with online reputation management and has handled more than 1,200 cases. We know how Google processes removal requests and what works and what does not. Our approach is based on the case law we have analyzed.
Free Assessment
You describe your situation via our contact form. Our specialists assess your case free of charge on the basis of the seven criteria from the case law and advise you honestly about the chances of success.
Legal Strategy
Based on the assessment, we develop a strategy tailored to your situation. We determine which URLs should be removed, which legal basis offers the best prospects, and which additional evidence strengthens your case.
Formal Removal Request
We draft the formal removal request and submit it to Google (or other search engines). A well-argued request that refers to relevant case law significantly increases the chance of success. Google processes EU removal requests through a specialized team.
Monitoring with Reptor.ai
During the handling of your case and 30 days afterward, you receive free access to Reptor.ai Essential. This platform monitors whether the removed search results stay removed and alerts you to new mentions of your name in Google, AI chatbots, and online reviews.
Appeal Proceedings
If Google rejects your removal request, we advise you on the next steps. You can file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or initiate legal proceedings. Our database of 45 analyzed court rulings provides insight into what works in court.
Including Free Reptor.ai Essential
When you submit a request through us, you receive free access to Reptor.ai Essential during the handling of your case plus 30 days afterward. Monitor your online reputation in real-time.
Dutch Case Law on the Right to Be Forgotten
Below you will find all 45 Dutch court rulings on the right to be forgotten that we have analyzed. Each ruling has been assessed by AI for outcome, reasoning, and practical implications. Click on a ruling for the full analysis.
ECLI:NL:RBDHA:2025:16243
A Dutch real estate entrepreneur residing in Germany requested Google to block a URL referring to a 2022 article mentioning his criminal convictions in connection with an investigation into public administration integrity. The court denied the request because the information contributes to a debate of general interest and remains relevant for his professional activities.
ECLI:NL:RBAMS:2025:4460
Legal advisory firm Dynamiet Nederland demanded that Google restore their search results, claiming their website was wrongfully de-indexed or demoted in rankings for casino-related search terms since February 2025. The court denied all claims because Dynamiet could not prove that Google had actually taken measures against their website, and Google had convincingly refuted any de-indexation or other sanctions.
ECLI:NL:RBNHO:2024:2836
A wealthy heir of a prominent real estate family requested Google to remove a blog post from search results, claiming it contained factual inaccuracies about his criminal past and family. The court denied the request as insufficient evidence was provided that a substantial part of the publication was manifestly inaccurate, ruling that public interest in information access outweighed his privacy interests.
ECLI:NL:RBDHA:2022:14569
An oral surgeon requested Google to remove a negative patient review from search results under Article 17 GDPR, claiming it was a fake review. The court denied the request because he could not prove the review was incorrect, while the public interest in information about healthcare providers takes precedence over his privacy rights.
ECLI:NL:RBLIM:2022:6330
A Dutch marketing professional requested Google to remove search results linking to South African wanted notices in which he was sought in connection with fraud at investment fund Electio. The court denied the request because the public interest in warning information about his business activities outweighs his privacy rights, and because it was not proven that the information is incorrect.
ECLI:NL:HR:2022:329
A plastic surgeon requested Google to remove search results about her disciplinary suspension based on the GDPR. The Supreme Court rejected the appeal, ruling that the right to freedom of information outweighs her privacy interests, particularly because the information is of public interest for patient safety.
ECLI:NL:GHARL:2021:10370
A writer requested Google to remove search results about allegations of plagiarism and wrongfully claiming academic titles. The Court of Appeal Arnhem-Leeuwarden denied the right to be forgotten request because the information remains current and of public interest, and because the writer could not sufficiently demonstrate that the allegations were incorrect.
ECLI:NL:RBAMS:2021:3670
A UK resident requested removal of six URLs from Microsoft Bing search results based on the right to be forgotten. The court declared itself incompetent as the applicant could not sufficiently demonstrate that his center of interests is in the Netherlands, despite his involvement with Dutch companies.
ECLI:NL:RBDHA:2020:12154
Two individuals request Google to remove search results about football fraud allegations from 2015. After Google's rejection and expiration of the 6-week appeal period, they submit an identical repeated request. The court refers preliminary questions to the Court of Justice about the scope of the 'at any time' right in Article 21 GDPR for repeated requests.
ECLI:NL:RBNNE:2020:3897
Two real estate entrepreneurs requested Google to remove search results linking to negative reporting about them, including articles about their election as 'Slumlord of the Year'. The court denied their requests because the public interest in warnings about their practices as landlords outweighs their privacy interests.
ECLI:NL:GHAMS:2020:1802
A doctor requested Google to remove search results linking to her disciplinary conviction on a 'blacklist' website. The Amsterdam Court of Appeal denied the request because the information was recent, relevant and factually correct regarding her professional conduct, and the right to freedom of information outweighed her privacy rights.
ECLI:NL:RBAMS:2020:2112
The applicant sought removal of an anonymized court decision from rechtspraak.nl under Article 17 GDPR. The court denied this because judicial decisions as legal analyses do not qualify as personal data under GDPR, and because publication is necessary for the public administration of justice.
ECLI:NL:GHDHA:2019:3539
A real estate entrepreneur requested Google to remove 36 search results linking him to housing sector problems, including criminal convictions and administrative sanctions. The Court of Appeal of The Hague denied the request because the public interest in information about slumlords outweighs the entrepreneur's privacy interest.
ECLI:NL:RBAMS:2019:9887
A dentist who appeared on TV programs asked Google to remove search results about his disciplinary convictions. The court denied the request because as a public figure he must tolerate more and there is a compelling public interest in access to factually correct information about his professional conduct.
ECLI:NL:RBNNE:2019:5169
The court denied a request to remove search results about a 2006 murder case. Although the applicant has served his prison sentence, his TBS treatment continues until 2021, making the public interest in access to information outweigh his privacy rights.
ECLI:NL:RBAMS:2019:9271
An artist requested Google to remove search results linking her name to social media posts about 'fraud' after her art academy closed and students didn't receive refunds. The court largely granted the request as the search results were excessive and referenced incorrect information, while no criminal prosecution had occurred.
ECLI:NL:RBDHA:2019:6302
A privacy law specialist requested Google to remove search results about a million-euro claim she filed against a municipality for privacy violations. The court denied the request because the information is of public interest, the applicant plays a public role as legal expert and contributed to the publications herself.
ECLI:NL:GHDHA:2019:1472
The Court of Appeal of The Hague denied the appeal of two appellants who sought to force Google to remove search results about their activities in the charitable sector. The court ruled that the public interest in transparency in the charitable sector and the public role of appellants outweighs their right to be forgotten.
ECLI:NL:RBROT:2019:948
A real estate entrepreneur and landlord demanded that Google remove 36 search results relating to his criminal convictions and disputes with tenants. The court denied the request because the public interest in accessing this information outweighed the plaintiff's privacy interest, given his role as a professional landlord in public life.
ECLI:NL:RBMNE:2018:5594
A writer requested Google to remove search results about a conflict regarding academic credentials based on the right to be forgotten. The court denied the request because the information is accurate and relevant, the applicant is a public figure, and the societal interest in accessing the information outweighs his privacy interest.
ECLI:NL:RBGEL:2018:5600
Two directors of a real estate company demanded Google remove search results linking to an article about a FIOD investigation into money laundering in which they are suspects. The court denied the claim because the public interest in information outweighs their privacy, given their status as public figures and the societal importance of the information.
ECLI:NL:RBAMS:2018:8606
A plastic surgeon requested removal of search results linking to her inclusion on a 'doctors blacklist' following a disciplinary conditional suspension. The court granted the request as the public interest was insufficient to justify the privacy infringement, particularly since the information is already available through the statutory BIG registry.
ECLI:NL:GHDHA:2018:1296
A man with a criminal history demanded that Google remove search results about his convictions for attempted contract killing, fraud, and handling stolen goods. The Court of Appeal of The Hague denied the claim because the public interest in knowing about his repeated criminal behavior in business contexts outweighs his privacy rights, especially given his recent conviction for handling stolen goods showing he does not appear to intend to reform his behavior.
ECLI:NL:RBMNE:2018:2196
A former financial advisor requested Google to remove search results referring to his criminal and civil convictions in bankruptcy cases. The court denied the request because the search results were accurate and relevant, concerned his professional activities as a public figure, and the public interest in accessing this information outweighed his privacy rights.
ECLI:NL:RBDHA:2018:4672
Plaintiffs asked Google to remove search results regarding an article about their involvement with charity organizations. The court denied the request because the public interest in accessing this information outweighs the privacy interest, particularly since the plaintiff still profiles himself as active in the charity sector and as a political candidate.
ECLI:NL:RBAMS:2018:3355
A former accountant requested Google to remove search results linking to publications about disciplinary proceedings in which he received a reprimand. The court denied the request because the public interest in accessibility of this information outweighed the applicant's privacy interest, particularly given his current work as a lawyer specializing in financial compliance.
ECLI:NL:RBAMS:2018:3357
An individual sought removal of Google search results linking to a news article about his criminal conviction for secret filming. The court granted the request because the applicant's privacy interests outweighed the public interest, as he was not a public figure and the offense was unrelated to his rental activities.
ECLI:NL:RBAMS:2018:3356
A former municipal civil servant requested Google to remove search results about his departure arrangement and alleged sale of municipal software. The court denied the request because the articles were accurate, the public had an interest in information about civil servant integrity, and the reporting concerned his professional life.
ECLI:NL:RBAMS:2018:3354
A music producer requested Google to remove search results about his alleged tax evasion from 2012. The court denied the request because the information does not constitute criminal personal data, is not incorrect, and the public interest outweighs the privacy interest of this public figure.
ECLI:NL:RBLIM:2018:2751
A former director of bankrupt companies requested Google to remove articles about the bankruptcies from search results based on the right to be forgotten. The court denied the request because the information was still current and relevant, the bankruptcies had not been settled, and the public interest in accessing this information outweighed the applicant's privacy rights.
ECLI:NL:RBAMS:2018:1644
An artist manager requested Google to remove a search result linking to an NRC article about his criminal conviction from 10 years ago for document fraud. The court granted the request because the applicant's privacy interest outweighed the public interest in accessing the outdated information about a relatively minor offense.
ECLI:NL:RBAMS:2018:2979
A real estate investor demanded Google remove search results about criminal suspicions related to an inheritance matter. The court denied the claim because the public interest in this information outweighed the applicant's privacy rights, as he was considered a 'public figure'.
ECLI:NL:RBMNE:2017:6893
A businesswoman requested Google to remove search results linking her to alleged conflicts of interest in contract awards by a university. The court denied the request as the search results were not inaccurate, irrelevant or excessive and concerned legitimate news reporting about her professional activities.
ECLI:NL:RBAMS:2017:2896
An entrepreneur demanded removal of a link to an article about a dismissed drug investigation from Google's search results for his name. The court granted the claim because the plaintiff is not a public figure and Google had insufficiently demonstrated why the public has an interest in accessing this sensitive information via the plaintiff's name.
ECLI:NL:HR:2017:316
A man convicted of attempted solicitation of murder sought to have Google remove search results about him. The Supreme Court ruled that lower courts had not correctly balanced his privacy rights against the public interest, and referred the case back.
ECLI:NL:RBMNE:2017:805
A man attempted to force Google to remove search results linking to negative publications about him regarding alleged fraud and false diplomas. The court denied his claim because he could not prove the information was incorrect and the publications were still current enough to remain of public interest.
ECLI:NL:RBOVE:2017:278
A man convicted of indecent acts with a minor requested Google to remove four URLs from search results. The court partially granted the request: one URL had to be removed as it contained criminal personal data, but three other URLs could remain because the applicant had voluntarily published this business information.
ECLI:NL:RBDHA:2017:264
A former real estate entrepreneur requested Google to remove search results about his damage claim against Rotterdam municipality and seizure by Fortis bank, after termination of criminal proceedings against him. The court denied the request because the information could not be classified as criminal personal data and the public interest in findable information about the real estate sector outweighed the applicant's privacy interest.
ECLI:NL:PHR:2016:1116
A man convicted of attempted solicitation of murder sought to have Google suppress certain search results appearing when searching his name. The court denied the claim because his role in public life and the public interest in accessing information about serious crimes outweighed his privacy interest.
ECLI:NL:RBROT:2016:2395
A lawyer sought removal of search results linking to his 2012 criminal conviction for weapons possession. The court granted the request because Google was processing criminal personal data in violation of the law and because the applicant's criminal record was now considered 'spent' under foreign legislation.
ECLI:NL:RBAMS:2015:9515
A journalist requested Google to remove a search result linking to an article about plagiarism from 16 years ago. The court denied the request because the public interest in access to this journalistically relevant information outweighed the journalist's privacy interest.
ECLI:NL:GHAMS:2015:1123
A man convicted of attempted solicitation of murder demanded that Google remove search results containing his name based on the 'right to be forgotten'. The Amsterdam Court of Appeal denied all claims, ruling that the public interest in information about serious crimes outweighs his privacy rights, especially since the case was recent and his appeal was still pending.
ECLI:NL:RBAMS:2015:716
A KPMG partner demanded Google remove search results about his 2012 'container story', where he had to temporarily stay in emergency housing with containers during a construction dispute. The court denied the claim because the information was relevant, accurate and still recent enough, with no compelling reasons that outweigh Google's freedom of information.
ECLI:NL:RBAMS:2014:6118
A man convicted of attempted solicitation of murder sought to have Google remove search results about his conviction and a related book. The court denied all claims, ruling that the man must bear the consequences of his own criminal conduct and the information remains permanently relevant.
ECLI:NL:RBAMS:2007:BA3941
A TV presenter demanded that Google remove search results that wrongly linked her name to sex sites. The court denied the claim because Google's automatic search process is technical and passive in nature and there was no manifestly unlawful conduct by Google.
Frequently Asked Questions About the Right to Be Forgotten
What is the right to be forgotten?
The right to be forgotten (also: right to erasure) is the right to request the removal of your personal data from search engine results such as Google. This right is established in Article 17 of the General Data Protection Regulation (GDPR). It was first recognized by the European Court of Justice in the Google Spain ruling of 2014. The right is not absolute and must be balanced against the right to freedom of expression and the public interest in information.
How do I submit a removal request to Google?
You can submit a removal request to Google via their online form for the right to be forgotten. You must specify exactly which URLs you want removed and explain why the information should be delisted. Google assesses the request against the criteria from the GDPR and European case law. A well-substantiated request with references to relevant court rulings increases the chance of success. MediaMaze helps you draft and submit a strong removal request.
What does it cost to have search results removed?
Submitting a removal request to Google is free. However, a well-substantiated request requires knowledge of the applicable case law and the criteria that Google applies. MediaMaze provides a free initial assessment of your case. If we take on your case, costs depend on the complexity: simple removal requests are significantly more affordable than cases that require legal proceedings. Contact us for a free, no-obligation assessment.
How long does a right to be forgotten procedure take?
Google is obliged to respond to a removal request within one month (Article 12 GDPR). In practice, the first response usually comes within 2 to 4 weeks. If the request is rejected, you can file a complaint with the Dutch Data Protection Authority or initiate legal proceedings. A court procedure in the Netherlands typically takes 4 to 8 weeks for interim injunction proceedings (kort geding), or 6 to 12 months for substantive proceedings.
Can I as a company invoke the right to be forgotten?
No, the right to be forgotten under Article 17 GDPR applies only to natural persons (individuals), not to legal entities such as companies. However, directors, shareholders, and employees can invoke the right in relation to personal data about them in a business context. If harmful search results damage your personal reputation, there may be legal avenues for removal. For removing defamatory business reviews, different legal grounds apply — see our page on fake reviews.
What if Google rejects my request?
If Google rejects your removal request, you have several options. First, you can submit a more detailed or supplemented request. Second, you can file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). Third, you can initiate legal proceedings — either through interim injunction proceedings (kort geding) for urgent matters, or through substantive proceedings. Our analysis of 45 court rulings shows which arguments have been successful in court.
Are the results also removed from other search engines?
A removal request to Google only applies to Google. If you also want to have results removed from Bing, DuckDuckGo, Yahoo, or other search engines, you must submit separate requests to each. Most search engines have their own procedure for this. MediaMaze can submit removal requests to all relevant search engines on your behalf. Note: since the CJEU ruling in Google v. CNIL (2019), removal only applies to EU versions of search engines.
What is the difference between the right to be forgotten and the right to erasure?
In everyday language, these terms are used interchangeably. Technically, the "right to be forgotten" (as established in Google Spain) specifically refers to the delisting of search results, while the "right to erasure" (Article 17 GDPR) is broader and also covers the deletion of personal data held by any data controller. For removing search results from Google, both terms refer to the same procedure.
Can a criminal past be removed from search results?
Yes, under certain conditions. Criminal data falls under the special category of personal data (Article 10 GDPR) and enjoys extra protection. Dutch courts increasingly grant removal requests for old criminal cases, especially when the person has served their sentence and has been rehabilitated. The age of the information, the severity of the offense, and the current relevance are all factors in the assessment. Our case law analysis shows that criminal cases are among the most successful grounds for removal.
What role does Article 17 GDPR play in the right to be forgotten?
Article 17 GDPR (Article 17 AVG in the Netherlands) is the legal basis for the right to erasure and the right to be forgotten. It specifies six grounds on which a data subject can request erasure of personal data. For search engine removal requests, the most relevant grounds are: (1) the data is no longer necessary for the original purpose, and (2) the data subject objects to the processing. Article 17(3) contains exceptions, including for freedom of expression, public health, and archiving in the public interest.
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