Keep a useful record of a data-erasure request
Keep the wording of your erasure request, its submission date, the acknowledgement and the response. This is usually enough to follow the case without retaining another complete copy of the sensitive material you want removed.
This guide uses the French data-protection authority's framework. The applicability of a particular right depends on the situation and the organisation concerned.
Write down the scope before collecting evidence
Suppose you ask a service to erase a profile photograph. Later, the account becomes inaccessible. That observation does not tell you whether the photograph was erased, whether the account was suspended or whether another access problem occurred. The record needs the original request and the response, not just the current appearance of the login screen.
This fictional example follows a distinction made in the French CNIL's erasure guidance: a request should specify the data concerned, and different requests can have different effects. The guidance also describes exceptions to erasure. This article uses that French regulatory reference; it does not present a universal procedure for every jurisdiction.
A compact record can consist of the service name, the request date, the scope, the submission reference and the response. You do not need to duplicate the entire account archive to document that a request was made.
| Record field | Useful content | Unnecessary expansion to avoid |
|---|---|---|
| Scope | The data or account operation requested | An unrelated history of your use of the service |
| Submission | Date, channel and reference | Repeated screenshots of sensitive account pages |
| Response | The relevant confirmation or explanation | New copies of every document mentioned |
| Open question | A precise point not answered | Unsupported claims about internal systems |
Distinguish an acknowledgement from an answer
An automated receipt establishes that a channel acknowledged something. It may not answer the erasure request. Keep its wording and date, then record the later substantive response separately.
If the response is partial, compare it with the requested scope. It might confirm that a public profile was removed while explaining that another category remains subject to a retention obligation. Do not compress that into “all data erased” or “request refused”. Preserve the distinction so that any follow-up addresses the unresolved part.
Where the organisation requests identity evidence, consider the actual request and its explanation. CNIL guidance describes identity checks where there are reasonable doubts and rejects disproportionate supporting-document demands. That does not justify attaching identity documents automatically to every initial request.
Keep dates without turning them into a legal conclusion
Record when the request was submitted, when it was acknowledged and when a substantive response arrived. If an extension is announced, retain its explanation. Consult the current CNIL guidance for the applicable response timetable and the next step when the answer is missing or unsatisfactory.
The record should support a factual account of the sequence. It should not manufacture a legal conclusion from an ambiguous timestamp or an email that might concern another request. Where several requests are open, use their references to keep the correspondence separated.
Before archiving the case, write one sentence stating what is established and one stating what remains unresolved, if anything. That small discipline makes a later follow-up easier and avoids keeping an ever-growing folder of sensitive material simply because the final status is unclear.
Keep events separate
Use dates and descriptive filenames. Do not put passwords, security answers or unnecessary identity documents into a general notes folder.
Minimise your own evidence copy
A screenshot should show the relevant confirmation, not every open tab or unrelated message. A downloaded response should be stored where access is appropriate to its sensitivity.
If an identity check is requested, verify the request and the official channel before sending information. Keep only what is necessary to understand the process; avoid duplicating the submitted identity material merely for convenience.
Close or escalate the record accurately
Mark the case according to the evidence: answered with the requested scope, partly answered, clarification pending or response not yet received. An inaccessible account alone cannot establish erasure.
If a difficulty remains, consult the CNIL's current instructions for the next step and retain the correspondence needed to explain it. Do not add unsupported claims about the organisation's internal systems.
Before closing the record, check that the response addresses the requested data. Preserve any unresolved point and its date so that a follow-up can ask for a specific answer.
The French guide to erasure rights helps distinguish the request's scope from the organisation's stated response. For the applicable rules, use the current CNIL guidance linked above.
