Developing
An Advocate General's opinion is not binding, and no judgment date has been published.
In 60 seconds
- Case C-12/25, Bisdom Gent VZW v Gegevensbeschermingsautoriteit, concerns a man who asked a diocese on March 25, 2021 to delete his baptism entry.
- The diocese struck it through but left it legible; the Belgian authority ordered erasure within 30 days in decision 169/2023.
- Advocate General Medina's October 1, 2026 opinion says striking through is not erasure, and under Article 21(1) the controller must show compelling legitimate grounds to retain it.
- The Court of Justice has not yet ruled.
Impact Layer
- What changed
- The Court's adviser has said what counts as "erasure" for records that are kept for other reasons.
- Why it matters
- If the Court follows, redaction that leaves data legible will not satisfy deletion requests, which matters for CRM and consent records.
- Who is affected
- Data protection officers, CRM owners and anyone handling erasure and objection requests.
- Martech stack area
- Data
- Stack impact
- Check that your deletion process actually removes or irreversibly anonymises data rather than hiding it.
- Business impact
- Low The opinion is not binding and the case is about church baptism registers; PPC Land's summary is secondary.
- Related technologies
- What to watch
- The judgment date and any change to the Belgian ruling.
On October 1, 2026 Advocate General Laila Medina delivered her opinion in Case C-12/25, Bisdom Gent VZW v Gegevensbeschermingsautoriteit, according to PPC Land’s October 6 newsletter.
The background
- A man baptised in 1955 in Ghent asked the diocese on March 25, 2021 to delete his entry. On April 2 the diocese struck it through but left it legible, and he complained on April 14.
- The Belgian authority’s Disputes Chamber (decision 169/2023, December 19, 2023) ordered erasure within 30 days. The diocese appealed and the Brussels Court of Appeal referred the questions to Luxembourg.
The opinion
Medina’s core view: striking data through while it remains legible is not erasure under the GDPR. Under Article 21(1), the controller must show compelling legitimate grounds to retain the data. The opinion is not binding and no judgment date has been published.
Our read
For marketers the point is generic. If a person objects to processing, a flag or a strike-through may not be enough. Check how your CRM and consent platform handle erasure and objection, and keep a separate suppression record only where you have a lawful reason to.
Sources
- PPC Land: October 6, 2026 newsletter (Case C-12/25) (opens in a new tab)
The newsletter section on the case, the Belgian decision and the Advocate General's opinion. It links to a dedicated PPC Land article.