ABSTRACT
This study scrutinizes the essence of the “right to be forgotten,” a legal mechanism enabling individuals to request the removal of specific information from the Internet, both within a global context and under Turkish legal principles.
I. INTRODUCTION
The subject of this study is the legal nature of the right to be forgotten within the realm of the Internet. Prior to engaging in a detailed evaluation of this right, its conceptual framework and historical evolution will be delineated. Subsequently, the legal parameters of the right to be forgotten will be examined through both global practices and Turkish law, with an assessment of how it is balanced against other fundamental rights such as freedom of expression and the right to access information. Furthermore, the limitations of the right to be forgotten and its evolution through judicial decisions will constitute critical focal points of this analysis.
II. THE RIGHT TO BE FORGOTTEN
It is an undeniable fact that the infringement of fundamental rights and freedoms, as guaranteed by constitutions and international treaties, is an indisputable reality in the online domain. Despite the legality of certain content, materials that undermine an individual’s reputation, dignity, and honor should not persist indefinitely on the Internet against the individual’s will. Given the necessity for social interaction, protecting one’s reputation, honor, and dignity within social networks remains a fundamental right. Herein lies the relevance of the “right to be forgotten.” This right encompasses the ability of individuals to request the removal or restriction of access to certain historical information from the Internet. Humans, by nature, possess an inherent need to forget. Indeed, in Turkish, the etymology of the term human includes “nisyan,” which signifies forgetfulness, thereby indicating that forgetfulness is an intrinsic human trait1. Historically, forgetfulness has been regarded as a frailty of humanity, with numerous efforts dedicated to addressing this vulnerability. However, in the current digital era, characterized by facile information storage and instantaneous access due to rapid digitization, personal information is similarly archived alongside political, social, and economic data. As Mayer-Schönberger aptly notes, “forgetting has become the exception rather than the norm”2.
In this light, the right to be forgotten is of paramount importance, particularly for the protection of personal data and the safeguarding of individual privacy in the digital age. It empowers individuals to manage information related to themselves in the digital sphere and provides the means to request the deletion of outdated information. In other terms, the right to be forgotten can be construed as the fundamental rightto be expunged from digital memory and to prevent the publicization of one’s past and privacy. Regulated under the European Union General Data Protection Regulation (GDPR), this right is applicable under specific conditions and must be balanced with other fundamental rights such as freedom of expression and the right to access information. Individuals exercising the right to be forgotten may seek remedies such as the de-listing of lawful content from search engines like Google (de-referencing) or the removal of content where breaches of personality rights are significant.
III. REGULATIONS ON THE RIGHT TO BE FORGOTTEN IN GLOBAL LAW PRACTICE
The right to be forgotten, one of the rights introduced by the digital age, has gradually been integrated into the legal domain. A key example of this right is the European Court of Justice’s (ECJ) ruling in the Google Spain case of May 13, 20143. The case began when Spanish lawyer Mario Costeja Gonzalez filed a complaint regarding outdated and personally distressing news about him remaining on the Internet. Gonzalez approached the Spanish Data Protection Agency, which led to the ECJ accepting Gonzalez’s request in its judgment C-131/12. In its ruling, the ECJ emphasized that personal data are protected under Articles 7 and 8 of the Charter of Fundamental Rights of the European Union, and under Article 6(1)(c) and (e) of Directive 95/46/EC on the Processing of Personal Data and on the Free Movement of Such Data, data should be deleted when it becomes “inadequate, irrelevant, or excessive” over time4. This ruling established the ECJ’s recognition of search engines as data controllers and defined their functions as locating, automatically indexing, temporarily storing, and presenting information according to user preferences. Additionally, it granted individuals the right to request the removal of search engine results linked to their names under certain conditions.
With the evolution of the Internet, concerns about privacy protection have increased. In response to these concerns, the European Commission addressed the issue by including the “right to be forgotten” in Article 17 of its 2012 draft. This article stated that personaldata without a legitimate purpose should be removed upon the request of data subjects5. Consequently, this right was incorporated into Article 17 of the European Union General Data Protection Regulation (GDPR) under the heading “Right to Erasure”6. Alongside international regulations, the right to be forgotten has established itself in both theoretical and practical terms within the global legal framework.
IV. REGULATIONS ON THE RIGHT TO BE FORGOTTEN IN TURKISH LAW
In Turkish law, the right to be forgotten does not have a direct legislative framework. However, it is associated with Article 207 of the Constitution, titled “Privacy of Private Life,” and given that the right to protect personal data is established as a constitutional right in Türkiye, Law No. 6698 on the Protection of Personal Data8 (“KVKK”) was enacted on April 7, 2016, incorporating the right to be forgotten within its scope.
KVKK provides a detailed regulatory framework concerning the processing, storage, and deletion of personal data, thus enhancing the applicability of the right to be forgotten. In Türkiye, the right to be forgotten was recognized by the Civil Chamber of the Court of Cassation in its decision dated June 17, 2015, numbered 2014/4-56 E. and 2015/1679 K. The court emphasized thatindividuals should have the right to request the removal of negative information from digital memory after a certain period9. This decision marks a departure from the European Union’s approach by extending the right to be forgotten beyond digital data to include personal data located in any publicly accessible repository. The Civil Chamber of the Court of Cassation, in this ruling, framed the right to be forgotten as part of the right to protect personal data, aiming to erase past negative events from digital memory and prevent their disclosure by others. It also stated that, in the absence of a superior public interest, the right to request the erasure of personal data after a certain period would contribute to the development of both individuals and society by allowing individuals to build a better future and overcome past negative impacts10.
In the evolving legal landscape, the right to be forgotten has been evaluated within the context of the Internet through various rulings by the Court of Cassation. In the decision of the 19th Criminal Chamber of the Court of Cassation dated May 5, 2017, and numbered 2017/532511, acquitted individuals requested the restriction of access to news articles published in 2007, which were archived on the Internet by certain newspapers. Their request for access restriction was based on Article 9 of Law No. 5651, enacted in 2016. Following their acquittal, after a lapse of nine years, it was determined that the news had lost its “relevance” and thus no longer met the criteria of “accuracy and truthfulness” from that period. Consequently, the Court of Cassation decided to block access to the news.
In line with the addition made on 01.10.2020 to Article 10 of the Law No. 5651 on the Regulation of Publications Made on the Internet and Combating Crimes Committed Through These Publications in Türkiye, it has been taken under the guarantee of the legislation that the judge may decide not to associate the name of the applicant with the Internet addresses subject to the decision within the scope of this article, if requested by persons whose personal rights have been violated due to the content of the publications made on the Internet.
Although the right to request the removal of content and/ or blocking access to content and the right to be forgotten are terminologically distinct concepts, their application is intertwined within Turkish Law. The right to be forgotten allows individuals to request that legally published content be made inaccessible via search engines or other public sources, while the content remains available at its original source and can still be accessed through the website’s URL, social media posts, or other search engines. Exercising the right to be forgotten involves applying to the Criminal Court of Peace to request the removal of published content that infringes on personal rights or privacy from the Internet (i.e., from the original source) and/ or to block access to such content.
The Constitutional Court addressed the exercise of the right to be forgotten in its decision on the individual application dated March 3, 2016, with application number 2013/5653. According to this decision, certain measures can be taken within the framework of Law No. 5651 to balance the right to be forgotten with freedom of expression and press. However, these measures must adhere to the principle of proportionality as outlined in the Constitution. Methods such as deleting personal data, anonymizing news, or blocking access to specific content should be utilized. The role of the judiciary is not to ensure the complete removal of news from the Internet, but to maintain a fair balance between protecting honor and reputation and upholding freedom of the press.
When evaluating the exercise of the right to be forgotten, it is crucial to consider both the limits of freedom of expression related to the content and the scope and necessity of the public’s freedom to access ideas. Consequently, while the “right to be forgotten” is not separately legislated in Turkish law, it remains a significant right under legal oversight. It plays an important role in the protection of personal rights, particularly through its close connection with and protection by existing legislation.
V. THE RELATIONSHIP OF THE RIGHT TO BE FORGOTTEN WITH OTHER RIGHTS
A. The Interplay between the Right to Be Forgotten and Freedom of Expression, the Dissemination of Ideas, and Freedom of the Press
Freedom of expression is an indispensable value in contemporary democratic societies. It is an undeniable fact that allowing individuals to express their thoughts freely and without apprehension plays a crucial role in enhancing and developing societal awareness. One of the most valuable manifestations of this fundamental value, which is essential to democratic societies, is freedom of the press12. Although it is obvious that the press plays a very important role in raising societal awareness, its primary purpose and benefit is to inform the public about real and current events and to stimulate their thinking. In a democratic political environment, while state actions are subject to judicial and administrative oversight, the public also exercises control through the press. By exposing the actions and decisions of political authorities, the press ensures the proper functioning of democracy and facilitates public participation in decision-making processes13. Again, in Article 28 of the Constitution of the Republic of Türkiye, titled “Freedom of the Press,” it is stipulated that the press is free and cannot be censored. According to Article 3 of the Press Law No. 5187 dated 19.06.2004, freedom of the press includes the rights to obtain information, disseminate it, criticize, interpret, and create works, and should be exercised in accordance with the requirements of a democratic society. However, this freedom may be subject to restrictions aimed at protecting the reputation and rights of others, public health and morals, national security, public order and security, state secrets, the prevention of crime, and the impartiality of the judiciary14. Article 26 of the Constitution, titled “Freedom of Expression and Dissemination of Thought,” stipulates that everyone has the right to express and disseminate their thoughts and opinions, individually or collectively, through words, writings, images, or other means. However, freedom of expression and the press are not absolute and may be subject to certain limitations15. The Internet, which plays a crucial role in the dissemination and reception of news and opinions, is also protected under freedom of expression as outlined in Article 26 of the Constitution. Given the broad range of activities on the Internet, whether published news and opinions fall within the scope of press freedom guaranteed by Article 28 of the Constitution should be assessed on a case-by-case basis. Although Article 28 of the Constitution and subsequent articles primarily define freedom of the press for printed media, online journalism today plays a significant role and is more widely consumed than printed publications. As long as internet journalism performs the “watchdog” function, which is one of the main roles of the press, the content published on this platform can be considered within the bounds of press freedom. The Constitutional Court has also stated that restrictions on Internet access should be evaluated within the framework of freedom of expression16. However, it is not possible to accept that all kinds of news and opinion transmission over the Internet are within the scope of freedom of the press guaranteed in Articles 28 to 32 of the Constitution. In some cases, it is inevitable that the press, which has a great contribution to society, will cause as much harm, and for this reason, the fundamental rights and freedoms of individuals should not be violated while exercising freedom of the press. While informing the society about a real event, the need to respect the private life of the person who is the subject of the event should not be discarded and attention should be paid to the sensitivity of the protection of personal data. For this reason, it is one of the requirements of the law to limit freedom of expression in order to protect human dignity in matters where the rights of individuals may be violated.
The right to be forgotten is one of the most important grounds for this limitation. In the practice of Turkish Law, individuals can also request the removal of content or the blocking of access based on Article 9 of the Law No. 5651 on the Regulation of Publications
Made on the Internet and Combating Crimes Committed Through These Publications, citing the right to be forgotten. According to this provision, those whose personal rights are violated may request the removal of content and/ or blocking of access. The decision to block access is not a punishment, but a preventive measure17 and the content of the publication does not need to be a crime for this measure. In this case, it is necessary to enforce the right in accordance with the principle of proportionality, so as not to restrict freedom of expression more than necessary and to enable the person to exercise his right to be forgotten. In other words, if anonymizing personal data is sufficient, opting for less severe methods than deletion or blocking of personal data would be more appropriate18.
VI. CONDITIONS OF EXERCISING THE RIGHT TO BE FORGOTTEN
In order to intervene in a publication under the right to be forgotten, it is essential to evaluate whether the content includes factual information, its contribution to the public interest, its status as historical data, its relevance on a case-by-case basis, and whether personal rights are violated. Even if the applicant’s name and identity are not explicitly included in the news or other content, it must be assessed whether such information can be inferred from other details within the news. This evaluation should consider other factors such as timeliness and public interest.
In one of its decisions, the General Assembly of the Court of Cassation delineated the boundaries between the freedom of science and art and the right to be forgotten. In this case, the plaintiff’s attorney argued that the publication of the Court of Cassation’s decision in a criminal case concerning sexual harassment constituted an attack on the defendants’ personal rights, claiming that including their names in a scientific work was an infringement of their personal rights. The defendants, however, sought the dismissal of the lawsuit, asserting that the work was of a scientific nature, that the names were mentioned in accordance with European Court of Human Rights decisions, and that the book did not reach a broad audience. The Court of Cassation summarized its decision by stating that the plaintiff sought to have a past negative event erased from public memory and wished to start afresh. Under the right to be forgotten, the plaintiff sought to prevent their personal data from being known by third parties and to be removed from public memory. The Court ruled that explicitly including the name of a victim from four years ago in a scientific work violated the right to be forgotten and the right to privacy. Emphasizing that personal data not significantly relevant to the public interest should not be clearly stated, as outlined in the “Google Decision” by the Court of Justice of the European Union, the Court found the plaintiff’s claim for non-pecuniary damages justified and concluded that the conditions for awarding such damages were met due to the violation of the right to be forgotten19.
In some instances, content that was originally published in compliance with legal standards may become outdated over time. When such content loses its relevance and capacity to inform the public, it can adversely affect the honor and reputation of the individual featured in the news. As previously discussed, the right to be forgotten is not explicitly codified in legislation within our legal framework but is instead delineated through the jurisprudence of the Court of Cassation, the Constitutional Court, and various legal doctrines. In their rulings on the right to be forgotten, both the Court of Cassation and the Constitutional Court assess the matter in conjunction with other relevant factors, rather than applying a fixed temporal criterion. Their decisions are guided by considerations of the timeliness of the information and its significance to the public interest. For instance, in one notable decision, the Court of Cassation ruled that a request from a prominent individual to block access to information about an event that occurred two years prior could not be accommodated under the right to be forgotten, given the continued public interest in the event. The Court emphasized that blocking access to news published as recently as two years ago would constitute a disproportionate interference with press freedom unless the content in question infringed upon personal rights20.
VII. CONCLUSION
Considering factors such as accessibility, the storage duration of news and ideas, capacity, and the transmission of large volumes of information, the Internet plays a critical role in public information dissemination and retrieval processes. It offers a significant opportunity for individuals to broadcast their ideas and ensures that news and information are accessible without limitations. The Internet also provides extensive space for freedom of expression, the dissemination of ideas, and press freedom. However, this expansive domain sometimes requires certain constraints to protect personal rights. One of the primary legal mechanisms for implementing these constraints is the right to be forgotten.
As a novel right emerging from the digital era, the right to be forgotten provides a crucial control mechanism over how individuals’ past personal information is handled and how long it remains accessible on the Internet. This right addresses the need to safeguard individuals’ honor, dignity, and privacy, while also delineating the boundaries for information storage in the digital environment.
Globally, as discussed earlier, the right to be forgotten has established itself in the legal domain through various judicial decisions, international conventions, legislation, and doctrines. Within the context of Turkish Law, although the right to be forgotten has not yet been directly codified, the Personal Data Protection Law (KVKK) and relevant decisions by the Supreme Court and the Constitutional Court demonstrate the applicability of this right and outline the judicial approach that should be adopted. Consequently, the right to be forgotten allows individuals to redefine themselves and focus on the future by relieving themselves of the burden of their past. This right represents a step toward protecting personal privacy in the digital age, ensuring that personal traces in technology’s memory become a safeguard for individual freedom and the right to reconstruct one’s identity.
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FOOTNOTE
1 Mahmut Kökver, “Hatırlama” Ve Kur’an’i Bağlamda “Zikir”, Journal Of Analytic Divinity Center, 2(3), 2018 p. 48-62.
2 Çiğdem Yılmaz, “Kişiliğin Korunmasında Unutulma Hakkı”, Yayımlanmamış Yl. Tezi, İstanbul 2019 Bilgi Üniversitesi
3 Google Spain SL, Google Inc. v Agencia Española de Protección de Datos, Mario Costeja González, 13.05.2014 (C-131/12) (C-131/12).
4 Yaşar Salihpaşaoğlu ve Burcu Değirmencioğlu, Unutulma Hakkının Bir “İnsan Hakkı”na Dönüşme Yolculuğu, 2020, p. 372.
5 Ayşenur Ocak, Hakları Dengelemek: Unutulma Hakkı İfade Özgürlüğüne Karşı ( Balancing Rights: The Right To Be Forgotten v. Freedom of Expression), 2017, s.6. https://dergipark.org.tr/en/download/ article-file/980892 (Access date, 25.07.2024).
6 European Parliament and Council, “Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC,” Official Journal of the European Union, L 119, 4 May 2016, p. 1-88.
7 Türkiye Cumhuriyeti Anayasası: https://www.mevzuat.gov.tr/#anayasa (Erişim Tarihi, 25.07.2024).
8 6698 sayılı Kişisel Verilerin Korunması Kanunu: https://www. mevzuat.gov.tr/mevzuat?MevzuatNo=6698&MevzuatTur=1&MevzuatTertip=5 (Access Date, 25.07.2024).
9 Sinan Sami Akkurt, “17.06.2015 Tarih, E. 2014/4-56, K. 2015/1679 Sayılı Yargıtay Hukuk Genel Kurulu Kararı ve Mukayeseli Hukuk Çerçevesinde ‘Unutulma Hakkı’,” Dergipark, https:// dergipark.org.tr/tr/download/article-file/621723, (Access Date, 25.07.2024).
10 Kazancı, “Yargıtay Hukuk Genel Kurulu’nun 17/06/2015 Tarihli, E. 2014/4-56 Sayılı Kararı,” Kazancı, https://kazanci.com.tr/gunluk/ hgk-2014-4-56.htm, (Access Date, 25.07.2024).
11 Yargıtay 19. Ceza Dairesi. E. 2016/15510, K. 2017/5325, 5.06.2017, Lexpera. https://www.lexpera.com. tr/ictihat/yargitay/19-ceza-dairesi-e2016-15510-k-2017-5325-t-5-6-2017, (Access Date, 25.07.2024).
12 Ali Akkurt, Basın Özgürlüğünün Kapsamı ve Sınırları, Adalet Yayınevi, Ankara, 2014, p. 1.
13 Anayasa Mahkemesi, Kadir Sağdıç Başvurusu, B. No: 2013/6617, 08.04.2015, Kararlar Bilgi Bankası, (Access date, 26.07.2024.)
14 Anayasa Mahkemesi, “Başvuru No: 2013/5653, 03/03/2016 Tarihli Karar,” Kararlar Bilgi Bankası, https://kararlarbilgibankasi.anayasa. gov.tr/BB/2013/5653, Access Date, 26.07.2024)
15 Ulaş Karan, İfade Özgürlüğü, Anayasa Mahkemesine Bireysel Başvuru El Kitapları Serisi 2, Avrupa Konseyi, Ankara, 2018, p. 103.
16 Anayasa Mahkemesi, Yaman Akdeniz ve Diğerleri, B. No: 2014/3986, 02.04.2014; Youtube LLC Corporation Service Company ve Diğerleri [GK], B. No: 2014/4705, 29.05.2014.
17 Burcu Görkemli, Yargı Kararları Işığında Türk Hukuku’nda İnternet Erişiminin Engellenmesi, Adalet Yayınevi, Ankara, 2015, p. 119.
18 Zafer Kahraman, Unutulma Hakkı, Vedat Kitapçılık, İstanbul, 2022, p. 58.
19 Yargıtay Hukuk Genel Kurulu, E. 2014/4-56, K. 2015/1679, 17.06.2015, Lexpera, https://www.lexpera.com.tr/ ictihat/yargitay/hukuk-genel-kurulue-2014-56-k-2015-1679-t-17-6-2015 (Access Date, 27.07.2024).
20 Yargıtay 19. Ceza Dairesi, E. 2020/6868, K. 2021/1703, 17.02.2021, Lexpera, https://www.lexpera.com. tr/ictihat/yargitay/19-ceza-dairesi-e2020-6868-k-2021-1703-t-17-2-2021, (Access Date, 27.07.2024).
