Though the GDPR’s extraterritorial reach is broad, it is not unlimited. The Court of Justice of the European Union recently issued a decision that held that, when carrying a request for deletion, while Google could be required to de-reference the data subject on all versions of its search engines within the E.U., it could not be required to do so on versions outside the E.U. This article analyzes the decision, with insights from Paula Barrett, a partner at Eversheds Sutherland, and Matthew J. Bacal, counsel at Davis Polk. See “The Right to Be Forgotten: English High Court Details When Google Must Delist Links to Crimes
” (May 9, 2018).