Processingrestricting

Processingrestricting is a data protection concept describing the temporary limitation of processing of personal data by a controller or processor. It comes into play when a data subject exercises rights or when a controller needs to verify the basis for processing, and aims to prevent ongoing processing while the issue is resolved.

In the European Union, the right to restriction of processing is described in Article 18 of the GDPR. It applies when the accuracy of the data is contested; processing is unlawful but the data subject asks for restriction instead of erasure; the controller no longer needs the data for the original purpose but the data are required for legal claims; or the data subject has objected to processing pending verification. During a restriction, the data may be stored and processed only for limited purposes, such as the saving of the data or for establishing, exercising, or defending legal claims.

Implementation and effects: When a restriction is active, data processing for most purposes should be paused, especially for activities like marketing or profiling. The data may still be stored, and may be processed with the data subject’s consent or for legal claims, with appropriate notices to processors and, where applicable, third parties. Technical implementations typically involve a restricted flag or similar metadata in the data store, enforced across applications and APIs.

Scope and limitations: Not all jurisdictions treat restriction as a separate right, and some systems implement similar controls under other rights such as access or consent withdrawal. Practical challenges include ensuring consistent enforcement across systems, audits, and timely lifting of restrictions once the underlying issue is resolved.

Use cases and relations: Processingrestricting is commonly invoked to address contested data accuracy, after a withdrawal of consent pending resolution, or during investigations. It is distinct from erasure and from objection, representing a temporary state in data governance.