GDPR and AI: The "Right to Be Forgotten" Now Means "Unlearning"
When GDPR's Article 17 was written, 'erasure' meant deleting a row from a database. In 2026, it means something far more complicated. If a user's data was used to train an AI model, deleting the database record isn't enough. The data has been absorbed into model weights, influencing predictions for every subsequent user. The EDPB has made right to erasure its coordinated enforcement priority for 2025-2026, with 30 data protection authorities investigating how organisations handle deletion requests. And the Italian DPA already fined OpenAI 15 million euros for, among other things, failing to handle training data properly under GDPR. This post explains what machine unlearning is, why it's a nightmare for developers, and what practical architectural decisions you can make right now to avoid the problem in the first place.