Portability and the right to be forgotten

Since September 2024, your customers can request their data in a structured file, or the removal of a photo still on your site. This is no longer theoretical. An SMB must know what it can deliver, and what it does not control (Google, social networks).

Portability: in practice

A person may request their personal information in a structured, commonly used format (often CSV, JSON, or a native CRM export), to transfer it to another organization when technically possible.

Test the export before the first real request. Nothing is worse than promising a legal deadline and having a CRM whose extraction procedure nobody knows.

• Map your systems: CRM, online store, billing: who holds what.
• Try an export: time it and note missing fields.
• Exclude what the law allows: information about third parties, protected trade secrets.

Cessation of dissemination and de-indexing

A person may request stopping the dissemination of personal information (e.g. photo or testimonial on your site) or de-indexing (removal from search results) when the legal conditions are met.

Typical SMB examples:

• Former employee whose biography still appears on the "Team" page.
• Customer who wants to remove a review published with their name.
• Outdated page still indexed: you remove the content on your site; with Google, that is a separate process.

Removing a page is not the same as de-indexing Google. Be honest with the person about what you control and what depends on a third party.

Prepare your systems and vendors

1. Cooperation clauses in contracts (vendors).
2. Unified procedure with rights requests: same register, same deadlines.
3. Document limits: what the host or web agency can or cannot remove.

In brief

Portability and "forgetting" require technical work and transparency. Prepare exports, clarify limits with vendors, and do not promise the moon on Google if you only control your own site.

Useful references

• CAI, Individual rights: portability, cessation of dissemination, and remedies.
• Steps 2022–2024: reminder of the September 2024 phase.
• Customer rights: SMB process and sample responses.

This text is for information only and does not constitute legal advice. For a decision that binds your organization, consult the CAI and a legal professional.

Check your website

Biographies, testimonials, and forms: many "forgetting" requests start from the public site. Our free technical scan helps spot observable gaps. It complements, but does not replace, your compliance program.