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Be ready for the Reform of data protection legislation ECJ’s ruling on the ‘right to be forgotten’

On 13 May 2014, the Court of Justice of the European Union issued a landmark ruling on the ‘right to be forgotten’, in relation to online search engines. This opens the data protection debate and companies are highly encouraged to actively manage their database following the data protection principles.

The Data protection Principles are to:

  1. Obtain and process information fairly
  2. Keep Data only for one or more specified, explicit and lawful purposes
  3. Use and disclose data only in ways compatible with these purposes
  4. Keep data safe and secure
  5. Keep data accurate, complete and up-to-date
  6. Ensure that the data is adequate, relevant and not excessive
  7. Retain data for no longer than is necessary for the purpose or purposes
  8. Give a copy of his/her personal data to an individual, on request

The right to be forgotten is reflected in the principle number 7: “Retain data for no longer than is necessary for the purpose or purposes”. This can affect your company if you don’t have the right processes in place to delete obsolete data. Hence, it is important to be managing your database actively through the year.


SME may have limited resources to do so. Therefore the accuracy of data can be improved by outsourcing once per year this process. It is a good practice to do a yearly data cleansing exercise and be aligned with European regulations.

Steps for the database management cleansing exercise:

  1. Get your database in a workable format
  2. Merge datasets if your team is working on different databases. Have in mind possible duplicates and data formatting issues.
  3. Designate human and technical resources for this project including:
    • Employees with telephone skills
    • Dedicated line for this outbound call campaign – so you can receive callbacks
    • Secure access to the database ( remember to backup records before to start)
  4. Train your team on Data Protection policies and Data Handling best practise (or outsource to us)
  5. Create a script and a process for calls and updating records – including data normalisation and formatting (spellings, uniformity…)
  6. Continuous monitoring of employees to adhere to data protection laws and quality standards
  7. Integrate the final result with other systems on your company


Check our database management service page for more information about the process and benefits of outsourcing this process to us.