CJEU - C-12/25
CJEU Advocate General rules on data subject's right to erasure from baptismal registers.
The CJEU Advocate General has provided an opinion on a case concerning a data subject's right to erasure of their personal data from a baptismal register under GDPR. The Advocate General opined that the baptismal register constitutes a filing system, making GDPR applicable. The data subject can request erasure under Article 17(1)(c) GDPR due to emotional distress from being affiliated with the Church after leaving it, unless the Diocese demonstrates overriding legitimate grounds for processing. The opinion also clarified the concept of 'erasure' and the applicability of GDPR to religious entities.
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The lesson from this incident
Full lessonThis case highlights that GDPR's reach extends beyond traditional digital systems to any structured filing system, including physical or ecclesiastical records like baptismal registers. A data subject's right to erasure under Article 17(1)(c) GDPR can be triggered by emotional distress caused by unwanted affiliation — not just by unlawful processing. Religious organizations often underestimate their obligations as data controllers, leaving them exposed to legal challenges when they fail to honor data subject rights. This ruling matters because it reinforces that no organization — secular or religious — is exempt from GDPR compliance when processing personal data in a structured manner.