The Evaluation of the Right to be Forgotten Specific to Search Engines by the Personal Data Protection Authority (“Authority”) was updated on 30.04.2025 and published by the Authority.

In this context, the summary of the updated assessment is as follows:

The right to be forgotten is defined as the right of the individual to request the removal of access to information and content published in accordance with the law in the past from search engine results with the passage of time, in line with judicial decisions, doctrine and the opinions of international organizations.

Since it is possible to establish the right in question through the regulations in our country, it is considered that the requests of the persons concerned regarding this right can be fulfilled without the need to define the right to be forgotten as a separate right and that the provisions in question can contribute to the realization of the purpose of the Law.

It has been taken into consideration that search engines determine the purposes and means of processing the data they collect on the internet belonging to third parties and search engines have been accepted as data controllers.

In addition, it is stated that individuals should first submit their requests within the scope of the right to be forgotten to the search engine operator, and if the data controller rejects the request or does not respond to the applicant, they may file a complaint with the Authority. The data controller must finalize this request free of charge as soon as possible and within 30 days at the latest. In the event that the application is rejected or the response is insufficient/no response is given, persons may file a complaint to the Authority within 30 days from the date of learning the response/60 days from the date of application.

It was also decided that it is possible for individuals to apply directly to the judiciary.

It is stated that the Authority will balance the fundamental rights and freedoms of the individual and the interests of the public in the examination to be made by the Authority and that additional criteria may be brought to the agenda by the Authority in each concrete case.

The Authority’s decision also lists the criteria to be taken into account in the evaluation of applications to remove search results from the index: the public position of the person, the accuracy and timeliness of the content of the information, the content of private data, whether the information belongs to children, whether the information is related to a criminal offense, whether it was published by the person.