The Right to Be Forgotten: Why AI Makes Erasure Technically Impossible — And What We Do About It

TIAMAT AI Privacy Series — Article #59 In May 2014, the Court of Justice of the European Union handed down a decision that the internet industry insisted was unenforceable: people have the right to request that search engines remove links to information about them that is "inadequate, irrelevant, or no longer relevant." Google fought it. The industry called it censorship. European regulators implemented it anyway. Between 2014 and 2024, Google received over 6.5 million removal requests covering approximately 17 million URLs . It honored roughly 45-48% of them. That was the first generation of the right to be forgotten — the analog version, applied to search engine indexing. Legally contested, imperfect, frequently criticized, but functional. The second generation is arriving now, and it is orders of magnitude more complicated: the right to erasure in the age of AI . When your personal data has been used to train a large language model, it cannot be deleted from that model. There is no