Right to restriction
The right to restriction of processing under Art. 18 GDPR allows data subjects to have the further processing of their personal data temporarily blocked in certain cases, instead of having it deleted outright.
The right to restriction of processing (Art. 18 GDPR) is a data subject right that lets a person require the controller to keep storing their personal data while no longer actively processing it. The restriction works like a temporary block: the data remains in place but - apart from narrowly defined exceptions - may no longer be used. It is therefore a milder measure than full erasure and preserves the status quo for as long as a disputed or not yet fully resolved situation persists.
Art. 18(1) GDPR sets out an exhaustive list of the situations in which the right applies: where the accuracy of the data is contested (for the duration of the verification), where the processing is unlawful but the data subject asks for restriction instead of erasure, where the controller no longer needs the data but the person still requires it to establish, exercise or defend legal claims, or where an objection under Art. 21 GDPR has been raised and it is still being assessed whether the controller's legitimate grounds override those of the data subject.
Under Art. 18(2) GDPR, restricted data may - apart from mere storage - only be processed with the data subject's consent, for the establishment, exercise or defence of legal claims, for the protection of the rights of another natural or legal person, or for reasons of important public interest. In practice the restriction is implemented through technical flagging, temporarily moving the data to a separate system, or blocking access. Where a restriction is lifted, the data subject must be informed beforehand under Art. 18(3) GDPR; for automatically flagged data, recipients must also be notified under Art. 19 GDPR.
Legal Basis
Art. 18 GDPR (in conjunction with Art. 19 and Art. 21 GDPR)
Practical Example
A customer disputes that the postal address stored in the CRM database is correct and requests its rectification. Until the data protection officer has verified the accuracy, the company flags the record as restricted: the address stays stored but is removed from the active mailing and marketing process and may not be used for new campaigns. Only once the matter is clarified is the flag lifted - with prior notice to the customer - or the address corrected.