5 Steps to Implement Restriction of Processing Requests

The Reform Team

Under GDPR, individuals can limit how their personal data is used without deleting it entirely. This is called the right to restriction of processing, and it applies in four specific cases:

Disputed Data Accuracy: When the individual contests the accuracy of their data.
Unlawful Processing: If data was processed unlawfully, but the individual prefers restriction over deletion.
Legal Claims: When data is no longer needed but must be retained for legal purposes.
Pending Objections: While objections to processing are under review.

For businesses, especially in the U.S. handling EU data, managing these requests is a legal requirement. Here's a quick guide:

Step 1: Identify and document restriction requests immediately.
Step 2: Check if the request meets GDPR's legal criteria.
Step 3: Use technical tools to flag and restrict data in your systems.
Step 4: Notify the individual and any third parties who have the data.
Step 5: Regularly review restrictions and maintain detailed records.

Right to Restriction of Processing, English Edition

Step 1: Identify and Document Restriction Requests

Handling restriction requests under GDPR requires swift identification and meticulous documentation. Unlike other GDPR-related requests that may use specific legal jargon, individuals often submit restriction requests in everyday language. This makes it essential to train your customer service team to spot these requests in routine interactions. Once identified, the next step is to assess and document them properly.

How to Identify Valid Restriction Requests

Valid restriction requests don’t always include precise legal terms. GDPR Article 18 outlines four scenarios where restrictions apply: disputes over data accuracy, unlawful data processing, retention of data for legal claims, and pending objections to processing. For instance, a customer might say, “I need you to stop using my data until you correct the errors in my account,” or “Pause processing my data while I challenge this charge.”

As a best practice, pause data processing while investigating these situations to ensure compliance.

You can deny a request if it’s deemed “manifestly unfounded” or “excessive,” but you must provide a clear rationale for your decision. Additionally, if you have valid concerns about the requester’s identity, you’re allowed to request further proof to confirm their identity.

How to Document Requests Properly

Thorough documentation is critical for staying compliant with GDPR. Start by recording the exact date and time of the request in MM/DD/YYYY format and assigning a unique identifier to each case. This ensures a clear timeline for meeting the 30-day response deadline.

Store all requests securely in a centralized system - this could be a folder in your CRM, a compliance database, or secure cloud storage. This setup allows authorized team members to quickly access records whenever needed.

Your documentation should include the method of the request (email, phone call, web form, or in-person), the exact wording provided by the individual, and any context relevant to the request. For phone requests, follow up with an email summarizing the conversation to ensure clarity.

Maintaining an audit trail is essential. Record every action taken, including who handled the request, the steps completed, and the corresponding dates. Using digital forms can streamline this process, standardizing how requests are logged and ensuring all necessary details are captured upfront, minimizing back-and-forth communication. Proper records also lay the groundwork for implementing the technical measures covered in Step 3.

Once requests are identified and documented, the next step is to verify their eligibility.

Step 2: Check Eligibility and Legal Requirements

Once you've gathered the necessary documentation, the next step is to confirm whether the request aligns with GDPR Article 18. This article outlines four specific situations where individuals have the right to request restrictions on processing their personal data.

GDPR's Legal Requirements for Restriction

GDPR Article 18 clearly defines when processing restrictions can be applied:

"The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;

the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;

the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;

the data subject has objected to processing pursuant to Article 21 pending the verification whether the legitimate grounds of the controller override those of the data subject."

Here’s a quick breakdown of these four scenarios:

Contested Accuracy: The individual disputes the accuracy of their data, and you need time to verify it.
Unlawful Processing: The data has been processed unlawfully, but the individual prefers restricting its use instead of deleting it.
Legal Claims: The data is no longer necessary for processing but is still needed for legal claims.
Pending Objections: The individual has objected to processing, and you’re evaluating whether your legitimate interests outweigh theirs.

When restrictions are in place, you can store the data but cannot process it further unless certain exceptions apply, such as obtaining consent or protecting the rights of others. These restrictions are strictly limited to the scenarios outlined above.

How to Document Your Assessment

To ensure compliance, use a structured approach to document your eligibility assessment. A standardized form can help you record key details, such as the scenario under which the request falls, the legal grounds, your reasoning, and the final decision.

Some key questions to guide your assessment include:

Does the request meet one of the four valid scenarios under GDPR Article 18?
Do you have enough information to make a well-informed decision?
Are there conflicting legal obligations that could impact your decision?

Here’s an example table to illustrate valid and invalid restriction scenarios:

Valid Restriction Scenarios	When Restrictions Do NOT Apply
Customer disputes the accuracy of their billing address while it's being verified	Dissatisfaction with marketing emails (opt-out applies instead)
Individual objects to direct marketing, pending your assessment	Restriction request for data necessary to fulfill a contract
Data was unlawfully processed, but the individual wants it preserved rather than deleted	Conflicts with legal obligations requiring data processing
Data is needed for an ongoing legal claim even though the retention period has expired	Vague or unsupported requests without specific legal grounds

For complex cases, evaluate each processing activity individually. This ensures that restrictions are applied correctly without overstepping or falling short of compliance requirements.

Keep detailed records of your decision-making process. Note when the request was received, when the assessment was completed, and when the decision was communicated. If you deny the request, document your reasoning thoroughly to be prepared for any inquiries from supervisory authorities.

Finally, notify the individual when restrictions are implemented or lifted. Include this notification in your compliance records to maintain a clear audit trail. Once eligibility is confirmed, you can proceed with implementing the necessary technical and organizational measures to enforce the restriction.

Step 3: Set Up Technical and Organizational Controls

Put restrictions in place right away with a mix of technical measures to block further processing and organizational protocols to enforce compliance. These steps are essential before proceeding to notify data subjects and relevant third parties.

How to Mark and Restrict Data in Your Systems

Start by setting up a flagging system to clearly identify restricted data across all platforms. Use tools like database tags, CRM status updates, and controlled access permissions to ensure proper handling.

In your CRM, assign a compliance tag to flag restricted accounts. Set this tag to trigger automatic alerts if team members attempt to use the data for activities like marketing or sales outreach.

For databases, apply restriction flags at the record level. For example, if a customer disputes their billing address, flag that specific field while allowing other data to remain accessible for processing. This keeps operations running smoothly without violating restrictions.

Email platforms make it easy to manage restricted contacts. Update subscriber lists to exclude flagged individuals, using segmentation features to automatically filter them out of campaigns.

Control access to restricted data by setting strict user permissions. Allow basic viewing but block actions like exporting, sharing, or processing. This ensures that only authorized personnel can handle restricted data and only for approved purposes, such as responding to legal claims.

Document every technical action taken, including dates, procedures, and responsible personnel. Keeping detailed records is vital for compliance audits and helps onboard new team members who need to understand these protocols.

Using Tools to Automate Compliance

Automation can simplify and streamline your compliance efforts, reducing errors and saving time.

Platforms like Reform offer conditional routing, which automatically directs restriction requests to the right team. For instance, a claim about inaccurate data can go straight to your verification team, while complaints about unlawful processing are routed to your legal department.

Reform's real-time analytics allow you to monitor restriction requests, track response times, and identify trends. Metrics like average response time and resolution rates can help ensure you meet GDPR's one-month response deadline.

Integrate compliance tools with your CRM to automatically update customer restrictions. When a restriction request is approved, the system can instantly update the customer’s status, apply the appropriate tags, and notify relevant team members - eliminating manual entry and reducing compliance gaps.

Email validation features ensure that restriction notifications are delivered to the correct recipients. Since GDPR requires confirmation of restriction implementations, accurate email delivery is a critical compliance step.

Set up automated compliance records to log every restriction action, including timestamps, responsible team members, and specific steps taken. Reform’s analytics dashboard can generate compliance reports to demonstrate your adherence to GDPR requirements during inspections.

Use multi-step forms to guide data subjects through restriction requests, collecting all necessary details upfront. These forms can include conditional questions tailored to the type of restriction, saving time and reducing back-and-forth communication.

Implement automated reminders for temporary restrictions. For example, restrictions pending accuracy verification or objection assessments may need periodic reviews. Automated alerts can notify your compliance team when it’s time to review or lift these restrictions.

Spam prevention is also key for restriction request forms. Fraudulent submissions can drain resources and interfere with legitimate requests. Use spam detection tools to filter out suspicious entries while ensuring genuine requests are prioritized.

Regularly test your automated systems to ensure they’re functioning correctly. Perform monthly checks on restriction flags, CRM updates, and notification systems. Document these tests to show ongoing reliability and compliance to supervisory authorities.

With restricted data properly flagged and automated systems in place, you’ll be well-prepared to notify data subjects and manage restrictions effectively.

sbb-itb-5f36581

Step 4: Send Notifications to Data Subjects and Third Parties

Once technical controls are in place, GDPR mandates prompt notification to both data subjects and third parties. These notifications must be sent within the required timeframe and must clearly explain the restriction status.

How to Notify Data Subjects

When notifying data subjects, confirm the restriction within one month and provide the key details in plain, straightforward language. Your message should include the following:

Effective date: Clearly state when the restriction begins.
Affected data: Specify which personal data is impacted.
Legal basis: Explain why the restriction is being applied.

For example, instead of using complex legal phrases like "pursuant to Article 18(1)(a) of the GDPR", you could say: "We have restricted the processing of your personal data as of 10/15/2025, based on your request to verify its accuracy."

Avoid legal jargon to ensure clarity. Use simple terms to explain what actions will stop and which will continue. For instance: "During this period, we will not use your contact details for marketing purposes. However, your data will still be securely stored and may be accessed if needed for legal purposes."

Provide essential contact details and a reference number for tracking. This allows data subjects to follow up on their request or ask questions.

Additionally, ensure your notifications are successfully delivered. Use email validation tools to confirm that messages reach the intended recipients. Failed delivery could result in non-compliance with GDPR.

Once data subjects have been informed, the next step is to notify any third parties who have received the restricted data.

How to Inform Third Parties

After notifying the data subject, extend the notification to all third parties who have accessed or received the restricted data. GDPR Article 19 requires this communication unless it is impossible or would involve excessive effort.

Start by identifying all relevant third parties. Review your data sharing agreements, vendor contracts, and integration logs to pinpoint who has access to the data. This might include platforms like email marketing tools, CRMs, analytics providers, or business partners.

Send formal notifications to these third parties, detailing the restriction and what actions they must take. For example:

"Effective 10/15/2025, please restrict all processing of John Smith's contact information (email: jsmith@email.com) while we verify its accuracy. Do not use this data for marketing, analytics, or any other processing activities."

Set a compliance deadline and request confirmation that the restriction has been implemented. This ensures accountability and demonstrates that you’ve fulfilled your obligations.

To streamline this process, consider automating third-party notifications. Use conditional routing to generate and send restriction notices based on your data mapping. For instance, once a restriction request is approved, your system can automatically identify the affected third parties and send standardized notifications.

Keep detailed records of all communications with third parties. Log when notifications were sent, responses received, and any follow-up actions. These records are essential for demonstrating compliance during audits.

Finally, monitor third-party compliance throughout the restriction period. Restrictions may be temporary, so you’ll need to notify these parties again when the restriction is lifted. Maintain an up-to-date list of all notified parties to ensure consistent communication about any changes.

Document all delivery confirmations to complete the notification process. With both data subjects and third parties informed, you’ve met the GDPR’s communication requirements for implementing data restrictions.

Step 5: Monitor and Manage Restrictions

Once a restriction is in place, it's crucial to keep a close watch and document everything thoroughly. Regularly review temporary restrictions to determine whether they should remain in effect or be lifted.

How to Review and Adjust Restrictions

Make it a habit to revisit active restrictions and examine the original reasons behind them. For instance, if a restriction was applied because of concerns about data accuracy, check whether your investigation is complete and if you've reached a decision on the matter. Similarly, if the restriction stems from an individual's objection to data processing, reassess whether your legitimate interests now outweigh those objections.

When conducting these reviews, document the date, the evidence you evaluated, and the reasoning behind your decision. If the conditions for lifting the restriction are met, notify the individual before resuming data processing. Keeping these records organized is essential for ensuring compliance and demonstrating accountability.

How to Keep Compliance Records

For every review and decision, maintain detailed records. Include the initial reason for the restriction, the evidence you considered, and the final decision you reached. These records are essential for showing that your data restriction protocols are being followed properly and consistently.

Key Points for U.S. Businesses

For U.S. businesses, tackling GDPR compliance means more than just implementing technical and organizational controls - it requires addressing specific operational hurdles. Managing GDPR restrictions across different jurisdictions can be tricky, so it’s essential to fully understand your obligations when handling EU data.

Train Your Team
Equip your staff with the knowledge to identify and escalate restriction requests. Training should cover legal grounds, technical measures, and notification procedures to ensure everyone knows what to do when these requests arise.

Clarify Roles
Assigning clear compliance roles is crucial. Smaller teams can delegate these responsibilities to existing staff, while larger companies might need to appoint a dedicated Data Protection Officer to oversee the process.

Coordinate with State Privacy Laws
Make sure your GDPR processes align with state-level privacy laws like the CCPA and VCDPA. Break down these regulatory requirements into simple, actionable steps to avoid confusion.

Upgrade Data Management Systems
Invest in tools like Reform to enhance your ability to flag, isolate, and track restricted data. These platforms not only simplify managing restriction requests but also strengthen compliance strategies tailored to U.S. businesses.

Keep Detailed Records
Document every action and decision related to restriction requests. This includes maintaining records of legal basis assessments, the technical measures you’ve implemented, and all communications with data subjects and third parties.

Cross-Border Transfers
Ensure that all cross-border data transfers comply with GDPR’s processing limitations. This is a critical step to avoid potential penalties.

Regular Policy Reviews
Review your policies quarterly to keep up with any changes in privacy laws. Staying proactive helps maintain compliance as regulations evolve.

Plan Your Budget
Set aside funds for both the initial implementation of GDPR measures and the ongoing maintenance needed to support compliance efforts. Proper budgeting ensures your business can adapt to new requirements without disruptions.

Conclusion

Handling restriction requests effectively calls for a structured approach that balances legal obligations with operational needs. By following a clear, step-by-step process, businesses can ensure these requests are managed efficiently, creating a strong framework for compliance.

Preparation is key. Having well-documented procedures in place not only reduces confusion but also speeds up response times. Your team should be equipped with clear guidelines on what actions to take, when to take them, and how to execute them. This includes maintaining thorough records of decisions, implementing technical safeguards, and ensuring all actions are traceable.

For U.S. companies managing EU data, these practices are especially critical due to the complexities of cross-border operations. Technology can play a pivotal role here, streamlining processes and reducing the risks associated with manual handling.

Take tools like Reform, for example. It transforms tedious, manual compliance tasks into automated workflows. With features like multi-step forms, conditional routing, and real-time analytics, Reform helps businesses capture and track data subject requests seamlessly. This not only reduces errors but also creates a scalable, auditable system that can grow alongside your organization.

Adapting to GDPR compliance is not a one-time effort. Regulations will continue to evolve, and your processes need to keep pace. By investing in clear procedures, training your team, and leveraging reliable tools, you’ll build a solid foundation for compliance. This groundwork will not only help you meet regulatory requirements but also safeguard your organization’s reputation in an era where privacy is more important than ever.

FAQs

Managing GDPR restriction of processing requests can be a tricky task for businesses. The challenges often stem from dealing with intricate regulatory requirements, respecting the rights of individuals, and handling cases where the accuracy of data is questioned or objections are brought up.

On a practical level, companies may need to revamp their systems to accommodate these restrictions, refine their data mapping strategies, and uphold transparency throughout the process. These changes can demand significant resources and careful planning to ensure both data security and accountability. To make matters more complex, integrating these new processes into existing workflows often presents technical obstacles that require thoughtful solutions.

U.S. businesses can navigate GDPR compliance alongside state laws like the CCPA and VCDPA by emphasizing shared principles: transparency, consumer rights, and data security. Since these regulations aim for similar outcomes, adapting GDPR frameworks to meet state-specific requirements can be a practical approach.

A unified privacy strategy can help simplify compliance efforts. This means focusing on key areas like data handling practices, consumer consent, and contractual obligations. For companies already following GDPR, existing policies and processes often provide a strong foundation for meeting the requirements of various jurisdictions.

To handle processing restriction requests efficiently and remain GDPR-compliant, businesses can turn to automation tools tailored for privacy management. These tools often offer features like automated workflows, real-time tracking, and reminders, ensuring requests are addressed within the required timelines.

Incorporating AI-driven platforms takes this a step further by automating critical tasks, minimizing manual mistakes, and offering insights into data processing activities. These solutions help save time while improving precision and compliance - an essential advantage for businesses managing sensitive data.