Using right to be forgotten for removing autocomplete from searches
Removing autocomplete from searches could be extremely challenging. The same complexity also may apply to similar requests for removing automatic suggestions from Yahoo and Bing searches.
There is some confusion between autosuggestion and autocomplete. Autosuggestion is a Google feature that is based on previous searches that you typed onto Google search bar. Autosuggestion can be easily turned off or removed by clearing the search history in your internet browser. The idea is to help you type faster by remembering your historical activity on Google search.
Google autocomplete, on the other hand, is suggested search phrases that the search engine brings up in the search bar when you type a particular search phrase. For example, you might type someone's name, and the search engine will suggest that you search for the name together with added words, such as their occupation or an event that is linked to the individual you are searching.
Usually there will be a list of 4-6 autocomplete search phrases for you to choose from. The feature of autocomplete might be based on previous searches that you carried out and which Google remembers from your historic activity (an autosuggestion), or searches that other people conducted and which Google believes might help you to either find what you want or help you explore a particular topic.
Google autocomplete is based on artificial intelligence algorithms, a self-learning feature which is constantly learning from people's search behaviour. Google has an algorithm that, among other things, takes into account related and follow up phrases that people have been searching for. The process is completely automated but it is possible for Google to take manual action to remove autosuggestion from internet searches.
Autocomplete could defeat the purpose of a right to be forgotten application because it may encourage Google users to find, via the back door, or via an alternative phrase, the very same web page that you were trying to remove from public sight.
Bing and Yahoo also use autocomplete features but Bing tends to be more responsive to requests to remove autocomplete phrases from search suggestions following a successful right to be forgotten request, whilst Google's and Yahoo's initial response to requests to remove autocomplete is often negative and unwilling.
To have autocomplete removed, you will need to ask the content moderator at Google, Yahoo or Bing, who handled your right to be forgotten request, to refer the matter to the appropriate department within the search engine and to request that they take manual action to have the unwanted search phrases removed from the autocomplete.
Bear in mind that often the search engine’s content moderators don’t even know that it is possible to take manual action to remove autocomplete because their knowledge is often limited to moderating content whilst the autocomplete is more of technical.
If you persist with your request to remove autocomplete from Google under a right to be forgotten, there is a good likelihood that you will be successful.
Because often the effect of the autocomplete is to make a right to be forgotten request meaningless, it is important to initiate a request to have the autocomplete removed as soon as you have successfully completed your right to be forgotten application.
We always ensure that when we take on a right to be forgotten project for a client, the removal of links from search engines' results also covers autocomplete. This might require an escalation of the matter and in some cases even the issuing of court proceedings against the search engine until it agrees to comply.