The “right to be forgotten”: what it actually means, how long it really takes, and what works in different countries
The phrase “right to be forgotten” sounds comforting in a way that stops people asking follow-up questions.
It suggests an expiry date. A moment where something unpleasant quietly drops off the internet and stops following you around. In reality, that version does not exist.
What does exist is a messy combination of data protection law, platform policy, public-interest tests, and human judgement, applied very differently depending on where you live and what the information relates to.
If you have ever Googled yourself, seen something you thought should no longer be there, and wondered whether time alone fixes it, this is the part most people never explain properly.
I’m going to be very direct about timelines here, not because there are guarantees, but because patterns absolutely exist. Pretending otherwise just wastes people’s time.
This is not legal advice. It’s what I’ve actually seen work.
A quick but important clarification before we go any further
Before getting into timelines and countries, it’s worth being clear about what the right to be forgotten is and what it isn’t.
This is not the route for dealing with false accusations, defamatory claims, or things that are simply untrue. If something written about you is inaccurate or misleading, the right to be forgotten often does not apply at all. Those situations are about correction, removal, or legal remedy, and they sit in a different category entirely.
The right to be forgotten usually applies where something did happen, it was lawfully reported, and it is now historic, resolved, and disproportionately affecting your life.
A typical example in the UK would be someone who committed a relatively minor offence years ago, served their sentence, rebuilt their life, and is now being blocked from work or opportunities because their name is permanently associated with something that happened a decade ago.
That is what this article is about.
And if you are reading this from the US and thinking the outlook sounds bleak, it does not automatically mean you are stuck. Where content is false, misleading, or breaches platform rules, there are still options. This piece focuses on truthful, historic information, not lies.
One thing people almost always misunderstand
The right to be forgotten does not mean deletion.
In almost every case, it means unindexing.
That means:
the article stays published
the website keeps it
history is not rewritten
What changes is whether that result appears when someone searches your name.
If someone has to actively search a newspaper’s website to find an article, that is very different from it sitting on page one of Google next to your LinkedIn profile. That difference is the entire point.
Another reality people underestimate
Most people trying to handle this themselves are not going to get newspapers to take articles down.
Publications are cautious, rightly so. They are balancing press freedom, legal precedent, and risk. They are not inclined to remove lawful reporting simply because someone emails and asks.
That is usually why people hire me.
I have long-standing working relationships with editors and journalists, which means real conversations can happen. Context can be explained. Evidence can be shown. Legal outcomes can be laid out properly. Sometimes that results in content being amended, updated, or removed entirely.
For the average person, though, the good news is this: you often don’t need the newspaper to delete anything.
In practice, Google are actually very reasonable when it comes to unindexing content that is historic, resolved, and clearly disproportionate. For most people, removing a result from name-based searches is enough. It stops the issue from defining them day to day, without rewriting history.
And historically, that has been enough, because nobody sat down before hiring someone or going on a date and thought, “Let me manually search the archives of every national newspaper.”
They Googled.
What this looks like in real life
It’s easy to talk about proportionality in theory, but the impact shows up in quieter, more human ways.
One client I worked with committed a very minor offence more than eight years ago. He served six weeks in prison, did his time, and moved on. No repeat behaviour. No pattern. Just someone who got mixed up with the wrong people at the wrong moment.
He is, genuinely, one of the sweetest people I’ve ever met.
Years later, the original coverage still dominated his Google results. Not because it was relevant, but because nothing had replaced it. The consequences weren’t dramatic, but they were relentless.
He struggled to get an accountant. Not because he was dishonest, but because professionals would Google his name, see the headlines, and quietly decide not to take the risk. Things you would never expect to be affected by an old, resolved issue suddenly became barriers.
I’ve seen similar knock-on effects with other clients too. Employment, obviously. Banking. Renting. And dating.
We live in an age where meeting someone online and Googling them is completely normal. If you meet someone on Raya and the first thing you see when you search their name is a crime from a decade ago, stripped of context and outcome, that is off-putting, even if you consider yourself open-minded.
Most people are not trying to hide their past. They just want the chance to explain it themselves, in their own words, rather than being defined by a headline that often simplifies or distorts what actually happened.
That is the gap the right to be forgotten is meant to address.
“They did the crime, they deserve the consequences”
This is usually the objection that follows, and it’s worth addressing directly.
Yes, people should be accountable for their actions. That is the point of the justice system.
But the justice system was never designed to punish people indefinitely.
Before Google, there was an assumption built into law and society that once you served your sentence, your punishment ended. You were allowed to move on. You were not permanently branded every time someone searched your name.
The internet changed that entirely.
Now, mistakes are indexed, cached, surfaced, and prioritised forever. A short custodial sentence can quietly turn into a life-long reputational penalty that affects work, housing, relationships, and basic dignity.
That is not justice. It is permanence by algorithm.
The right to be forgotten exists because lawmakers recognised that technology has made consequences far harsher than they were ever meant to be.
How this actually works in practice, country by country
United Kingdom
There is no fixed time limit, but outcomes follow patterns.
Under 3 years: almost always refused
3–5 years: occasionally possible, but rare
5–10 years: realistic with strong evidence and clear outcomes
10+ years: strongest category
What blocks requests includes public office, regulated professions, consumer-protection issues, repeat behaviour, or renewed attention.
Being found innocent does not automatically guarantee success. Proportionality matters more.
Europe
Broadly similar to the UK:
under 3 years, almost never
3–5 years, occasionally
5–10 years, often viable
10+ years, strongest
Some countries lean slightly more towards privacy, but the logic is consistent.
United States
There is no right to be forgotten.
If content is lawful and truthful, age makes very little difference.
What can work:
court-proven defamation
clear privacy breaches
copyright issues
platform policy violations
Waiting does not help.
Australia
Sits between the UK and US.
Very roughly:
under 5 years, unlikely
5–10 years, sometimes
10+ years, more realistic for private individuals
Context matters more than age.
Asia and the Middle East
Highly fragmented.
In countries like Japan and South Korea, unindexing can sometimes work in the 5–10 year range for private individuals. Elsewhere, outcomes depend far more on platform policy and hosting location than time passed.
Where experience genuinely changes outcomes
Despite all of this, outcomes are not fixed.
I have personally been successful in having serious criminal proceedings unindexed from Google, sometimes well within the 5–10 year window, where innocence was unequivocal and the continued prominence of coverage clearly distorted reality.
That does not happen by repeatedly filling in forms. It happens through evidence, credibility, and knowing how to approach the right teams in the right way.
The difference is not persistence. It’s judgement.
The next complication: AI search
There is, however, an uncomfortable reality people need to understand.
Even when something has been successfully unindexed from Google, AI tools may still surface it.
AI systems do not rely on Google in the same way. They scan broadly. They summarise. They connect information across the open web. They do not care whether something was removed from name-based search results.
Historically, it was unlikely someone would think, “Let me search the archives of the Financial Times before I hire this person.”
Now, it is increasingly likely someone might ask an AI tool, “Do you know anything about this person?”
That is a shift we are only just beginning to feel.
It does not make unindexing pointless. It still removes the most common point of discovery. But it does mean reputation management is moving beyond Google alone.
The principles remain the same, proportionality, accuracy, relevance over time, but the mechanics are changing quickly.
The pretty annoying truth
Most right-to-be-forgotten requests fail.
That does not mean the system is broken. It means it is cautious.
The right exists to prevent permanent distortion of the present, not to tidy up the past.
Anyone promising guaranteed removal is selling something that does not exist.
How to use this information properly
If you’ve read this and thought:
“it’s probably too soon”
“this might be borderline”
“this is never moving”
that’s a sensible reaction.
If you want clarity, you can send me the link you’re worried about and tell me:
roughly how old it is
where you’re based
what the outcome was
I’ll tell you, plainly, whether it’s:
too early
realistically challengeable
or very unlikely
Sometimes clarity is more useful than hope.