Updated

On March 5, 2025, the European Data Protection Board (“EDPB”) announced that EU Supervisory Authorities (“SAs”) will undertake a coordinated enforcement action in 2025 regarding data subjects’ right to erasure under Art. 17 of the GDPR.  For context, the EDPB selects a particular topic each year as its focus for pan-EU coordinated enforcement.

In 2024, regulators focused on the right of access.  On January 20, 2025, the EDPB published its report providing an overview of the actions SAs took in the context of the 2024 action.

The 2025 initiative is the fourth coordinated enforcement action, and 32 SAs participate.  Participating SAs will contact companies to inquire how they implement the right of erasure in practice.  For example, they will ask companies to explain “how they apply the conditions and exceptions for the exercise of this right.”  Engagement may take the form of questionnaires or formal investigations.  SAs will compile their findings and send them to the EDPB.  The EDPB will then analyze the results and publish a report upon completion.  See our previous blog post here for more details on how coordinated enforcement actions operate.

Update: On April 14, 2025, the German Supervisory Authority of Baden-Wuerttemberg published examples of questions that data protection authorities could ask when investigating a company’s compliance with the right to erasure in Article 17 of the GDPR.

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Covington’s Data Privacy and Cybersecurity team regularly advises companies on their most challenging compliance issues in the EU and other key markets, including on how to respond to data subject rights.  Our team is happy to assist companies with completing SA’s questionnaires and any other inquiries related to data privacy and cybersecurity.

(This blog post was written with the contributions of Alberto Vogel).

Tags: Coordinated Enforcement, EDPB, Right To Erasure
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Photo of Kristof Van Quathem Kristof Van Quathem

Kristof Van Quathem advises clients on information technology matters and policy, with a focus on data protection, cybercrime and various EU data-related initiatives, such as the Data Act, the AI Act and EHDS.

Kristof has been specializing in this area for over twenty…

Kristof Van Quathem advises clients on information technology matters and policy, with a focus on data protection, cybercrime and various EU data-related initiatives, such as the Data Act, the AI Act and EHDS.

Kristof has been specializing in this area for over twenty years and developed particular experience in the life science and information technology sectors. He counsels clients on government affairs strategies concerning EU lawmaking and their compliance with applicable regulatory frameworks, and has represented clients in non-contentious and contentious matters before data protection authorities, national courts and the Court of the Justice of the EU.

Kristof is admitted to practice in Belgium.

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According to Chambers UK, his “level of expertise is second to none, but it’s also equally paired with a keen understanding of our business and direction.” It was noted that “he is very good at calibrating and helping to gauge risk.”

Dan is qualified to practice law in the United States, the United Kingdom, Ireland and Belgium. He has also been appointed to the advisory and expert boards of privacy NGOs and agencies, such as the IAPP’s European Advisory Board, Privacy International and the European security agency, ENISA.

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Photo of Anna Sophia Oberschelp de Meneses Anna Sophia Oberschelp de Meneses

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Anna Sophia Oberschelp de Meneses advises on EU data protection, cybersecurity, and consumer law. Her practice covers the full range of Europe’s digital regulatory framework, including GDPR, ePrivacy, NIS2, the Cyber Resilience Act, the AI Act, the Digital Services Act, the Data Act, the European Health Data Space, and EU consumer protection law, including product safety, product liability, and consumer rights legislation. She focuses on the operational side of compliance — helping clients design policies and processes, draft documentation, and build the internal frameworks needed to meet regulatory requirements in practice.

She also advises on contentious matters, drawing on experience managing investigations before national regulators and proceedings before national courts and the Court of Justice of the European Union. She works closely with Covington’s disputes teams on matters at the intersection of regulatory compliance and litigation.

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