In February 2021, a data subject lodged a complaint pursuant to Article 77 GDPR with the Data Protection Commission concerning an Irish-based data controller. The DPC was deemed to be the competent authority for the purpose of Article 56(1) GDPR.

The details of the complaint were as follows:

a . The data subject emailed the data controller in January 2021 to request erasure of his personal data .

b . The data subject did not receive any response from the data controller

Following a preliminary examination of the material referred to it by the complainant, the DPC considered that there was a reasonable likelihood of the parties concerned reaching informal resolution of the subject matter of the complaint within a reasonable timeframe .

The DPC engaged with both the data subject and the data controller in relation to the subject matter of the complaint . Further to that engagement, it was established that during the week in which the data subject sent his erasure request by email to the controller a new process to better manage erasure requests was implemented by the controller . The data controller informed the DPC that it was in a transition period during the week the email came in and it appears a response was missed . New personnel were being trained on how to manage these types of requests during this transition period . The data controller stated that it was an oversight, possibly due to the technical transition or human error, and it regretted the error . In the circumstances, the data controller agreed to take the following actions:

1 . The data controller agreed to comply with the erasure request; and

2 . The data controller sincerely apologised for the error

In January 2022, the DPC informed the data subject by email of the final outcome of its engagement with the data controller . When doing so, the DPC noted that the actions now taken by the data controller appeared to adequately deal with the concerns raised in his complaint . In the circumstances, the DPC asked the data subject to notify it, within two months, if he was not satisfied with the outcome so that the DPC could consider the matter further .

On the following day the data subject informed the DPC by email that he agreed with the informal resolution given his concerns regarding the data controller were now satisfied. The DPC was subsequently informed by the data controller that the erasure request was completed and that the personal data of the data subject had been erased.

For the purposes of the GDPR consistency and cooperation procedure, the DPC communicated a draft of the outcome which confirmed that:

• The complaint, in its entirety, had been amicably re- solved between the parties concerned;
• The agreed resolution was such that the object of the complaint no longer existed .

No relevant and reasoned objections were received from the concerned supervisory authorities concerning the draft and the DPC subsequently closed the file in this case.