ECJ i.S. Goog­le Spain: “Right to be For­got­ten” (13.5.2014, Case C‑131/12):

On the mate­ri­al scope of the Directive

28 By auto­ma­ti­cal­ly, con­ti­nuous­ly and syste­ma­ti­cal­ly scan­ning the Inter­net for the infor­ma­ti­on published the­re, the search engi­ne ope­ra­tor thus “coll­ects” per­so­nal datawhich it then “reads out” with its index­ing pro­grams, “stores” and “orga­ni­zes”, “stores” on its ser­vers and, if neces­sa­ry, “pas­ses on” to its users in the form of lists of results and “makes available” to them. The­se ope­ra­ti­ons are express­ly and wit­hout limi­ta­ti­on refer­red to in Artic­le 2(b) of Direc­ti­ve 95/46, so that they must be clas­si­fi­ed as “pro­ce­s­sing” within the mea­ning of that pro­vi­si­on, wit­hout it being rele­vant whe­ther the search engi­ne ope­ra­tor per­forms the same ope­ra­ti­ons on other types of infor­ma­ti­on and whe­ther it distin­gu­is­hes bet­ween that infor­ma­ti­on and per­so­nal data.

38 The acti­vi­ty of a search engi­ne may thus signi­fi­cant­ly affect the fun­da­men­tal rights to respect for pri­va­te life and pro­tec­tion of per­so­nal data, in addi­ti­on to the acti­vi­ty of the publishers of web­sites; as the per­son who deci­des on the pur­po­ses and means of this acti­vi­ty, the search engi­ne ope­ra­tor must the­r­e­fo­re ensu­re, within the scope of its powers and pos­si­bi­li­ties, that the acti­vi­ty com­plies with the requi­re­ments of Direc­ti­ve 95/46, so that the gua­ran­tees pro­vi­ded for the­r­ein can be ful­ly effec­ti­ve and effec­ti­ve and com­pre­hen­si­ve pro­tec­tion of the data sub­jects, in par­ti­cu­lar their right to respect for their pri­va­te life, can be effec­tively realized.

.….

41 Con­se­quent­ly, the ans­wer to Que­sti­on 2(a) and (b) must be that Artic­le 2(b) and (d) of Direc­ti­ve 95/46 must be inter­pre­ted as mea­ning that the acti­vi­ty of a search engi­ne, which con­sists in fin­ding infor­ma­ti­on pla­ced on the inter­net by third par­ties or published on the inter­net, auto­ma­ti­cal­ly inde­xes that infor­ma­ti­on, stores it tem­po­r­a­ri­ly and, final­ly, makes it available to inter­net users in a par­ti­cu­lar order of prio­ri­ty, pro­vi­ded that the infor­ma­ti­on con­ta­ins per­so­nal data, is to be clas­si­fi­ed as “pro­ce­s­sing of per­so­nal data” within the mea­ning of Art. 2 let­ter b of Direc­ti­ve 95/46 and that the ope­ra­tor of this search engi­ne is to be con­side­red as the “con­trol­ler” of this pro­ce­s­sing within the mea­ning of Art. 2 let­ter d of Direc­ti­ve 95/46.

On the ter­ri­to­ri­al scope of the Directive

52 As argued in par­ti­cu­lar by the Spa­nish govern­ment and the Com­mis­si­on, Howe­ver, Art. 4(1)(a) of Direc­ti­ve 95/46 does not requi­re that the pro­ce­s­sing of per­so­nal data at issue be “by” the branch con­cer­ned its­elf is exe­cu­tedbut only that hshe is car­ri­ed out “within the frame­work of the acti­vi­ties” of the branch.

55 In the light of that objec­ti­ve of Direc­ti­ve 95/46 and the wor­ding of Artic­le 4(1)(a) the­reof, it must be held that the pro­ce­s­sing of per­so­nal data car­ri­ed out for the ser­vice of a search engi­ne, such as Goog­le Search, ope­ra­ted by an under­ta­king which is estab­lished in a non-mem­ber coun­try but which has an estab­lish­ment in a Mem­ber Sta­te, “car­ri­ed out in the cour­se of the acti­vi­ties” of that estab­lish­ment, whe­re the estab­lish­ment has the task of pro­mo­ting in the Mem­ber Sta­te the sale of the adver­ti­sing space offe­red by the search engi­ne with a view to making the ser­vice of the search engi­ne pro­fi­ta­ble, and of ensu­ring that sale its­elf.

56 In such cir­cum­stances, the acti­vi­ties of the search engi­ne ope­ra­tor and tho­se of its estab­lish­ment in the Mem­ber Sta­te con­cer­ned are in fact inex­tri­ca­bly lin­kedsin­ce the acti­vi­ties con­cer­ning the adver­ti­sing spaces are the means to make the search engi­ne in que­sti­on eco­no­mic­al­ly via­ble and the search engi­ne is, at the same time, the means that enables the­se acti­vi­ties to be car­ri­ed out.

On the scope of the search engi­ne operator’s responsibility

62 By Que­sti­on 2(c) and (d), the refer­ring court asks c and d, the refer­ring court asks whe­ther Artic­les 12(b) and 14(1)(a) of Direc­ti­ve 95/46 must be inter­pre­ted as mea­ning that, in order to safe­guard the rights pro­vi­ded for in tho­se pro­vi­si­ons, the search engi­ne ope­ra­tor is requi­red to remo­ve from the list of results dis­play­ed fol­lo­wing a search car­ri­ed out on the basis of a person’s name links to inter­net pages published by third par­ties and con­tai­ning infor­ma­ti­on rela­ting to that per­son, even if the name or infor­ma­ti­on on tho­se inter­net pages is not dele­ted before­hand or at the same time and, whe­re appro­pria­te, even if their publi­ca­ti­on on the inter­net pages is lawful as such.

74 Accor­ding to this pro­vi­si­on, the Pro­ce­s­sing of per­so­nal data per­mis­si­blewhen they for the rea­lizati­on of the legi­ti­ma­te inte­restThe data con­trol­ler or the third par­ty or par­ties to whom the data are dis­c­lo­sed shall be requi­red to car­ry out the pro­ce­s­sing, unless the inte­rest or the fun­da­men­tal rights and free­doms of the data sub­ject are at sta­ke., in par­ti­cu­lar, out­weigh their right to pri­va­cy in the pro­ce­s­sing of per­so­nal data pro­tec­ted under Artic­le 1(1) of the Direc­ti­ve. The appli­ca­ti­on of Art. 7(f) of Direc­ti­ve 95/46 the­r­e­fo­re requi­res a Weig­hing up the respec­ti­ve con­flic­ting rights and inte­rests, in the con­text of which the importance of the rights of the data sub­ject deri­ving from Artic­les 7 and 8 of the Char­ter must be taken into account (see ASNEF and FECEMD, EU:C:2011:777, paras. 38 and 40).

80 As alre­a­dy sta­ted in para­graphs 36 to 38 of the pre­sent judgment, pro­ce­s­sing of per­so­nal data car­ri­ed out by a search engi­ne ope­ra­tor, such as that at issue in the main pro­ce­e­dings, may signi­fi­cant­ly affect the fun­da­men­tal rights to respect for pri­va­te life and pro­tec­tion of per­so­nal datawhen the search is car­ri­ed out with this search engi­ne on the basis of the name of a natu­ral per­son, sin­ce this pro­ce­s­sing allo­ws any Inter­net user to obtain, with the list of results, a struc­tu­red over­view of the infor­ma­ti­on to be found on the Inter­net about the per­son con­cer­ned, which poten­ti­al­ly con­cerns num­e­rous aspects of his or her pri­va­te life and which, wit­hout the search engi­ne in que­sti­on, would not have been lin­ked, or would have been lin­ked only with gre­at dif­fi­cul­ty, and thus to crea­te a more or less detail­ed pro­fi­le of the per­son. Moreo­ver, the effect of the inter­fe­rence with the afo­re­men­tio­ned rights of the data sub­ject is fur­ther increa­sed by the signi­fi­cant role of the Inter­net and search engi­nes in modern socie­ty increa­sed, which give ubi­qui­ty to the infor­ma­ti­on con­tai­ned in a list of results (see in this sen­se judgment eDa­te Adver­ti­sing and others, C‑509/09 and C‑161/10, EU:C:2011:685, para. 45).

81 Becau­se of its poten­ti­al seve­ri­ty, such inter­fe­rence can­not be justi­fi­ed sole­ly on the basis of the search engi­ne operator’s eco­no­mic inte­rest in pro­ce­s­sing the data. Howe­ver, sin­ce the rem­oval of links from the list of results may have an impact on the legi­ti­ma­te inte­rest of Inter­net users poten­ti­al­ly inte­re­sted in acce­s­sing the infor­ma­ti­on, depen­ding on the infor­ma­ti­on at issue, an appro­pria­te balan­ce must be struck in situa­tions such as that in the main pro­ce­e­dings bet­ween, inter alia, that inte­rest and the fun­da­men­tal rights of the data sub­ject under Artic­les 7 and 8 of the Char­ter. While the rights of the data sub­ject pro­tec­ted by the­se artic­les gene­ral­ly out­weigh the inte­rest of the Inter­net user in; howe­ver, the balan­ce may depend, in par­ti­cu­lar cases, on the natu­re of the infor­ma­ti­on in que­sti­on, its sen­si­ti­vi­ty to the pri­va­te life of the per­son con­cer­ned, and the public’s inte­rest in having access to the infor­ma­ti­on, which may vary depen­ding, among other things, on the role the per­son plays in public life.

84 In this respect, it should be noted that, sin­ce infor­ma­ti­on published on a web­site can easi­ly be repro­du­ced on other web­sites and the per­sons respon­si­ble for the publi­ca­ti­on are not always sub­ject to Uni­on law, effec­ti­ve and com­pre­hen­si­ve pro­tec­tion of the data sub­jects could not be achie­ved if they had to obtain the dele­ti­on of the infor­ma­ti­on con­cer­ning them from the publishers of the web­sites before­hand or at the same time.

85 Moreo­ver, pro­ce­s­sing car­ri­ed out by the publisher of a web­site in the form of publi­ca­ti­on of infor­ma­ti­on rela­ting to a natu­ral per­son may, whe­re appro­pria­te, be car­ri­ed out “sole­ly for jour­na­li­stic … pur­po­ses”, so that it is sub­ject to exemp­ti­ons from the requi­re­ments of the Direc­ti­ve under Artic­le 9 of Direc­ti­ve 95/46, whe­re­as this is not the case for pro­ce­s­sing car­ri­ed out by the ope­ra­tor of a search engi­ne. Con­se­quent­ly, it can­not be ruled out that, in cer­tain cir­cum­stances, the data sub­ject may invo­ke the rights under Artic­les 12(b) and 14(1)(a) of Direc­ti­ve 95/46 against the search engi­ne ope­ra­tor, but not against the publisher of the web­site.

86 Final­ly, it should be noted that the ground for admis­si­bi­li­ty under Artic­le 7 of Direc­ti­ve 95/46 is not neces­s­a­ri­ly the same for the publi­ca­ti­on of per­so­nal data on a web­site as it is for the acti­vi­ties of search engi­nes; even if that is the case, the assess­ment to be made under Artic­le 7(f) and Artic­le 14(1)(a) of the Direc­ti­ve may be The balan­ce of inte­rests will dif­fer depen­ding on whe­ther the pro­ce­s­sing is car­ri­ed out by the search engi­ne ope­ra­tor or by the publisher of the web­site, sin­ce both the legi­ti­ma­te inte­rests justi­fy­ing the pro­ce­s­sing ope­ra­ti­ons may be dif­fe­rent and the con­se­quen­ces that the pro­ce­s­sing ope­ra­ti­ons have for the data sub­ject, in par­ti­cu­lar for his or her pri­va­te life, are not neces­s­a­ri­ly the same.

87 The inclu­si­on of an Inter­net site and the infor­ma­ti­on it con­ta­ins about a per­son in the list of results of a search con­duc­ted on the basis of the name of the per­son in que­sti­on Name­ly, can signi­fi­cant­ly faci­li­ta­te the acce­s­si­bi­li­ty of infor­ma­ti­on for Inter­net users con­duc­ting a search on the per­son and play a decisi­ve role in the dis­se­mi­na­ti­on of the infor­ma­ti­on. It may the­r­e­fo­re con­sti­tu­te a stron­ger encroach­ment on the fun­da­men­tal right to respect for the pri­va­te life of the per­son con­cer­ned than publi­ca­ti­on by the publisher of the website.

88 The ans­wer to Que­sti­on 2(c) and (d) must the­r­e­fo­re be that Artic­les 12(b) and 14(1)(a) (c) and (d), the ans­wer must be that Artic­le 12(b) and Artic­le 14(1)(a) of Direc­ti­ve 95/46 must be inter­pre­ted to that effect, that, in order to pre­ser­ve the rights pro­vi­ded for in the­se pro­vi­si­ons, if their con­di­ti­ons are met, the search engi­ne ope­ra­tor is obli­ged to remo­ve from the list of results dis­play­ed fol­lo­wing a search per­for­med on the basis of a person’s name links to web­sites published by third par­ties con­tai­ning infor­ma­ti­on on that per­son, even if the name or infor­ma­ti­on on the­se Inter­net pages is not dele­ted befo­re or at the same time and, if appli­ca­ble, even if their publi­ca­ti­on on the Inter­net pages is lawful as such.

On the scope of the rights of the data subject

94 Thus, if, fol­lo­wing a request by the data sub­ject pur­su­ant to Artic­le 12(b) of Direc­ti­ve 95/46, it is estab­lished that the inclu­si­on of links to inter­net pages lawful­ly published by third par­ties and con­tai­ning truthful infor­ma­ti­on about him or her in the list of results dis­play­ed fol­lo­wing a search car­ri­ed out on the basis of his or her name, at the pre­sent time is not com­pa­ti­ble with Art. 6 para. 1 lit. c to e of the Direc­ti­vebecau­se it turns out that, in view of all the cir­cum­stances of the indi­vi­du­al case, the infor­ma­ti­on does not cor­re­spond to the pur­po­ses of the pro­ce­s­sing in que­sti­on by the search engi­ne ope­ra­tor, is not or no lon­ger rele­vant for them, or goes bey­ond them, the rele­vant infor­ma­ti­on and links of the result list must be dele­ted.

97 Sin­ce, in view of his fun­da­men­tal rights under Artic­les 7 and 8 of the Char­ter, the data sub­ject may request that the infor­ma­ti­on con­cer­ned no lon­ger be made available to the public at lar­ge by inclu­si­on in such a list of results, it must be assu­med, as is appa­rent in par­ti­cu­lar from para­graph 81 of the pre­sent judgment, that, in prin­ci­ple, the­se rights pre­vail not only over the eco­no­mic inte­rest of the search engi­ne ope­ra­tor, but also over the inte­rest of the gene­ral public in fin­ding the infor­ma­ti­on in a search con­duc­ted on the basis of the name of the data sub­ject. Howe­ver, this would not be the case if it were to be shown for spe­cial rea­sons – such as the role of the per­son con­cer­ned in public life – that the inter­fe­rence with the fun­da­men­tal rights of that per­son is justi­fi­ed by the over­ri­ding inte­rest of the public at lar­ge in having access to the infor­ma­ti­on con­cer­ned through inclu­si­on in such a list of results.

98 In a situa­ti­on such as that at issue in the main pro­ce­e­dings, in which the list of results obtai­ned by the inter­net user when he car­ri­es out a search using Goog­le Search on the basis of the name of the per­son con­cer­ned inclu­des links to pages of the online archi­ve of a dai­ly news­pa­per con­tai­ning adver­ti­se­ments, which, men­tio­ning the name of the data sub­ject, refer to the auc­tio­ning of a pro­per­ty in con­nec­tion with a sei­zu­re made for social secu­ri­ty claims, it must be assu­med that the data sub­ject, becau­se of the sen­si­ti­vi­ty of the infor­ma­ti­on con­tai­ned in the­se adver­ti­se­ments to his or her pri­va­te life and becau­se the ori­gi­nal publi­ca­ti­on of the adver­ti­se­ments dates back 16 years, has a right to have this infor­ma­ti­on no lon­ger lin­ked to his or her name by such a results list. Sin­ce, in the pre­sent case, the­re do not appear to be any spe­cial rea­sons justi­fy­ing an over­ri­ding inte­rest on the part of the public in having access to the infor­ma­ti­on refer­red to in the con­text of a search based on the name of the per­son con­cer­ned – which, howe­ver, is a mat­ter for the refer­ring court to veri­fy – the per­son may, under Artic­les 12(b) and 14(1)(a) of Direc­ti­ve 95/46, request that the links be remo­ved from the list of results.

99 The ans­wer to Que­sti­on 3 must the­r­e­fo­re be that Artic­le 12(b) and Artic­le 14(1)(a) of Direc­ti­ve 95/46 must be inter­pre­ted as mea­ning that, in the con­text of the assess­ment of the con­di­ti­ons for the appli­ca­ti­on of tho­se pro­vi­si­ons, inter alia it must be exami­ned whe­ther the data sub­ject has a right to have infor­ma­ti­on about him or her no lon­ger asso­cia­ted with his or her name at the pre­sent time by a list of results dis­play­ed fol­lo­wing a search car­ri­ed out on the basis of his or her name, it being under­s­tood that the estab­lish­ment of such a right does not pre­sup­po­se that the data sub­ject suf­fers dama­ge as a result of the inclu­si­on of the infor­ma­ti­on in que­sti­on in the list of results. Sin­ce the data sub­ject, in view of his or her fun­da­men­tal rights under Artic­les 7 and 8 of the Char­ter, may request that the infor­ma­ti­on in que­sti­on no lon­ger be made available to the public at lar­ge by inclu­si­on in such a list of results, the­se rights are in prin­ci­ple out­weig­hed not only by the eco­no­mic inte­rest of the search engi­ne ope­ra­tor, but also by the inte­rest of the public at lar­ge in having access to the infor­ma­ti­on in a search car­ri­ed out on the basis of the data subject’s name. Howe­ver, this would not be the case if it were to be shown for spe­cial rea­sons – such as the role of the per­son con­cer­ned in public life – that the inter­fe­rence with the fun­da­men­tal rights of this per­son is justi­fi­ed by the over­ri­ding inte­rest of the gene­ral public in having access to the infor­ma­ti­on con­cer­ned through inclu­si­on in such a list of results.