- Legal Reference(s): Article 12 (Transparent information, communication and modalities for the exercise of the rights of the data subject), Article 17 (Right to erasure ‘right to be forgotten’)
EXTIA, which specialises in IT and engineering, recruits consultants for various technical projects from its client companies.
In 2024, the French Data Protection Authority (CNIL) received several complaints from former employees or candidates, relating to difficulties encountered in exercising their right to erasure or ‘right to be forgotten’. With a view to investigating these complaints, and also in the context of the Coordinated Enforcement Framework action on the ‘Right to erasure’ launched on the initiative of the European Data Protection Board in 2025, an audit of EXTIA was carried out in April 2025. It identified breaches of several obligations under the GDPR regarding transparency and respect for individuals’ rights.
Of the 265 requests for erasure received by the company in 2024, the majority of which came from candidates and, occasionally, former employees, more than three quarters had not been dealt with or had not been dealt with satisfactorily.
Failure to process erasure requests (Articles 12 and 17 GDPR)
The CNIL’s restricted committee – the body responsible for issuing sanctions – noted that 12 requests for erasure received by the company in 2024 had not been processed. It considered that that failure had adversely affected the rights of those persons, including the right to retain control over their data.
Failure to inform individuals of the action taken on their request for erasure (Article 12 GDPR)
The CNIL’s restricted committee considered that the company had failed to fulfil its obligation to inform the persons who had requested the erasure of their data. It noted that 166 persons who had made a request for erasure in 2024 had not been informed of the action taken on that request. Another 27 people had received this information late (outside the legal one-month deadline), with delays of up to several months.
Consequently, the restricted committee imposed a fine of EUR 300 000 on EXTIA, taking into account the infringement of essential principles relating to the rights of individuals, the number of persons concerned and the fact that EXTIA had already been reminded of its obligations on two occasions.
Excerpt from the official page. The original is authoritative.