At the beginning of 2010s, with a consent through email, I gave permission to some people, to put my pictures in a catalog, or online catalogs.

Now, I want my pictures to be erased, or any data, which involves me inside, want to be removed, or at least the part where I am.

The data owners deny it. If I go to my lawyer, by law, do I have a right to dictate those data owners to erase any information where I am? If they do not, will there be any law regulations on such people?


If you agreed and took the pictures before the GDPR was in effect, it does not apply now. In the future, you should specify that in any contracts regarding your pictures.

Processing, the process of using or storing your data, in the future would require consent and fall under the GDPR though.

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  • If the GDPR applies in this case, this answer is wrong, since ongoing processing or use of PII involves an ongoing legal basis for that processing or use, which the data processor needs to justify to continue to use the data. Other factors may apply however, such as whether a contract was formed (e.g. payment made in return for use of the persons image etc) which may make this either not covered by the GDPR or covered without consent being the legal basis, and therefore it can't be withdrawn. – user4210 May 14 '19 at 17:17
  • @Moo that is not true. Ongoing processing would require consent in some cases, but if the use occurred before the GDPR, it is not covered. gettingemaildelivered.com/… – Putvi May 14 '19 at 17:23
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    I agree that the GDPR does not apply to paper catalogues distributed before the GDPR was in effect. But I believe it would apply to an online catalogue still accessible today. The GDPR is about processing of data, not about obtaining of data. See also: Does consent given before 25 May 2018 continue to be valid once the GDPR starts to apply on 25 May 2018? – wimh May 14 '19 at 20:49
  • @wimh I agree with the processing part, but using your image in a catalog isn't always processing it. – Putvi May 14 '19 at 20:51
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    Processing is any operation, including "using" and "storing". And at least an online catalogue is processing by automated means. Given the GDPR applies to a picture, I can't think of any way the GDPR would not apply to that picture in an online catalogue. Note that I am not sure yet whether the right to be forgotten applies to this situation. – wimh May 14 '19 at 21:11

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