Right to Be Forgotten

1. Purpose

This document sets out Beacon’s policy for the publication, review, amendment and removal of personal information relating to missing or at-risk people.

Beacon recognises that public appeals can play an important role in locating missing people and protecting their welfare. It also recognises that personal information published during an active search may become unnecessary, excessive or harmful once the person has been located.

This standard is intended to ensure that Beacon’s handling of missing-persons information remains proportionate, necessary and respectful of the privacy, dignity and welfare of the individual and their family.

2. Scope

This standard applies to:

• Beacon Alert pages;
• Beacon posts and updates;
• images and identifying media;
• comments and replies;
• information shared through Beacon’s social-media channels;
• copies of Beacon content where Beacon has reasonable control over its removal or amendment; and
• requests concerning the removal or reduction of missing-persons information.

It applies whether an alert is resolved as:

• Found Safe;
• Found Passed; or
• otherwise closed following confirmation that an active public appeal is no longer required.

3. Legal and public-interest context

The UK data-protection framework recognises that privacy rights must be balanced against freedom of expression, journalism, safeguarding, public-interest activity and legal obligations.

The relevant provisions include the following.

3.1 Right to erasure: UK GDPR Article 17

Article 17 of the UK GDPR establishes the right to erasure, commonly referred to as the “right to be forgotten”. It may apply where personal information is no longer necessary for the purpose for which it was collected or processed.

The right is not absolute. Article 17(3) provides exceptions where continued processing is necessary:

• for exercising the right of freedom of expression and information, including journalism;
• for compliance with a legal obligation;
• for performing a task carried out in the public interest or under official authority;
• for archiving in the public interest, scientific or historical research, or statistical purposes, subject to the conditions set out in the legislation; or
• for the establishment, exercise or defence of legal claims.

The legislation is available at UK GDPR Article 17: Right to erasure.

The Information Commissioner’s Office provides further guidance in its Right to erasure guidance.

These exceptions do not create a permanent right to retain or publish personal information. They apply only where continued processing is necessary for the relevant purpose.

3.2 Freedom of expression and journalism: UK GDPR Article 85

Article 85 of the UK GDPR requires the United Kingdom to reconcile data-protection rights with the right to freedom of expression and information, including processing carried out for journalistic purposes and for academic, artistic or literary expression.

In the United Kingdom, the principal statutory provision is paragraph 26 of Part 5 of Schedule 2 to the Data Protection Act 2018.

The Data Protection Act 2018, Schedule 2, paragraph 26 provides the “special purposes” exemption for processing carried out for:

• journalism;
• academic purposes;
• artistic purposes; or
• literary purposes.

The exemption is conditional. In general terms, the organisation must be processing information with a view to publication, reasonably believe that publication is in the public interest, and reasonably believe that compliance with the relevant data-protection provision would be incompatible with the special purpose.

The exemption is therefore not a general exemption for every public appeal, social-media post or website publication. It must be considered in the specific circumstances and applied only to the extent necessary.

Further information is available in the ICO’s Guide to data-protection exemptions.

3.3 Safeguarding and vital interests

The need to locate and protect a missing person may provide a lawful basis for processing personal information.

Article 6(1)(d) of the UK GDPR permits processing where it is necessary to protect the vital interests of the individual or another person. Where special-category information, such as health information, is involved, Article 9(2)(c) may apply where processing is necessary to protect vital interests and the individual is physically or legally incapable of giving consent.

The ICO describes the vital-interests condition as limited in scope and generally concerned with matters of life and death. It should not be treated as an unlimited justification for the continued publication of personal information after the immediate risk has ended.

Further information is available in the ICO’s guidance on Article 9(2)(c): vital interests.

3.4 Public interest and official functions

Article 17(3)(c) recognises an exception where continued processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority.

This may be relevant to public authorities and law-enforcement bodies carrying out their statutory functions. It does not automatically authorise private individuals, community groups or third-party websites to retain detailed missing-persons information indefinitely.

Police forces operate under separate data-protection arrangements when processing information for law-enforcement purposes. This does not remove the responsibility of other publishers or members of the public to consider whether their own continued publication remains lawful, necessary and proportionate.

3.5 Application to missing-persons appeals

The legal provisions above may justify the initial publication of identifying information where there is a genuine and proportionate need to locate or safeguard a missing person.

However, the purpose of a missing-person appeal is normally time-sensitive. Once the person has been located, the necessity, proportionality and public interest in continuing to publish detailed identifying information must be reconsidered.

The fact that information was lawfully published during an active search does not, by itself, establish that it should remain publicly available after the search has ended.

Beacon will distinguish between:

• information required to support an active search or safeguarding response;
• information needed to confirm that an alert has been resolved; and
• information that no longer serves a necessary public purpose.

Beacon’s policy is to remove or reduce identifying information when the active public-interest purpose has ended, unless there is a documented and proportionate reason to retain it.

This approach is consistent with the ICO’s instruction that data-protection exemptions should be considered on a case-by-case basis, should not be relied upon routinely, and should be reviewed where an exemption no longer applies.

4. Core principle

Beacon will publish and retain personal information only to the extent that it is necessary and proportionate to support the location, safeguarding or welfare of a missing or at-risk person.

Once the immediate public-interest purpose has ended, Beacon will review the information and remove or reduce it wherever appropriate.

The operational principle is:

Personal information should remain public only for as long as it is necessary to support the person while they are missing or at risk.

5. Beacon’s technical and operational controls

Beacon has been developed to support a more proportionate approach to missing-persons information.

Accordingly:

• Beacon Alert pages are configured as non-indexable wherever technically practicable.
• Alert content is reviewed when its status changes.
• Identifying information is removed or reduced following resolution.
• Images are removed from public-facing alert content.
• External Beacon posts are updated where Beacon controls the relevant account or page.
• Information that may be detrimental to a person’s health, safety, recovery, employment or relationships is removed where appropriate.
• Internal records may be retained where necessary for safeguarding, accountability, legal, regulatory or operational purposes.
• Retention of internal records does not, by itself, justify continued public publication.

6. Procedure: Found Safe

When an individual is confirmed as found safe, Beacon should, where practicable:

1. Update the alert status to “Found Safe”.
2. Remove photographs and other identifying images.
3. Remove or redact detailed personal information.
4. Remove exact locations, police references, health information and other information that is no longer necessary.
5. Reduce the public update to a general confirmation that the appeal has been resolved.
6. Where a public update remains useful to people who followed the appeal, retain only minimal information, such as a first name and broad geographic area.
7. Review comments, replies and updates for information that may be intrusive or detrimental to the individual’s ongoing welfare or recovery.
8. Amend or remove the relevant content from Beacon-controlled social-media channels.
9. Record the action taken where an internal audit trail is required.

Being found safe does not necessarily mean that an individual consents to the continued publication of details concerning their whereabouts, health, circumstances or reasons for going missing.

7. Procedure: Found Passed

When an individual is found deceased, the primary consideration becomes respect for the deceased person and their family.

Data-protection rights applying to living individuals do not operate in the same way after death. However, Beacon will continue to apply principles of confidentiality, dignity, proportionality and family sensitivity.

The following actions should be taken where practicable:

• remove identifying photographs and other unnecessary images;
• remove detailed personal information;
• remove exact locations, police references and health information;
• remove speculation concerning the circumstances of the death;
• remove intrusive, insensitive or harmful comments;
• consider the wishes of the family where they are known;
• avoid unnecessary details that may cause distress to children or other relatives; and
• retain only the minimum public information required to explain that the alert has been resolved.

The “Found Passed” status is intended to provide an accurate resolution to an active appeal. It is not intended to create or preserve a permanent public record of private grief or personal circumstances.

8. Third-party copies and social-media sharing

Beacon cannot guarantee the removal of copies created and published by third parties. However, people who share Beacon Alerts are expected to act responsibly when an alert is resolved.

Individuals and organisations sharing a Beacon Alert should:

• monitor the status of the original appeal;
• update or remove copied content promptly;
• remove photographs and identifying information;
• remove comments that may be harmful or intrusive; and
• avoid continuing to circulate information that is no longer necessary.

Unamended copies may:

• incorrectly suggest that a person remains missing;
• expose private or sensitive information;
• affect employment and personal relationships;
• interfere with recovery and reintegration; and
• cause distress to the individual, their children or their family.

Beacon will request the amendment or removal of outdated copies where appropriate and where the relevant platform or publisher can be contacted.

9. Privacy pledge

Beacon and those supporting Beacon Alerts commit to the following principles:

1. Publish information only where there is a clear and proportionate purpose.
2. Keep information public only for as long as it is necessary to support a person who is missing or at risk.
3. Remove or reduce identifying information when the appeal is resolved.
4. Remove photographs and identifying images.
5. Remove exact locations, police references, health information and unnecessary personal details.
6. Remove comments that may adversely affect a person’s health, safety, recovery, employment or relationships.
7. Avoid speculation, judgement and unnecessary commentary.
8. Respect the wishes of the person who has been found.
9. Take the privacy and wishes of families into account, particularly where a person has died.
10. Update or remove copies shared on other public or searchable platforms.
11. Recognise that support for a missing person continues after they have been located, including through the protection of their privacy and dignity.

10. Requests for review or removal

Requests concerning the removal or amendment of Beacon content should be submitted through the designated Beacon contact route.

Requests may be made by:

• the person concerned;
• an authorised representative;
• a parent or guardian where appropriate;
• a close family member;
• a person acting on behalf of the family; or
• another person able to provide relevant safeguarding or welfare information.

Beacon will assess requests according to:

• the nature of the information;
• the current status of the appeal;
• the original purpose of publication;
• any continuing public-interest or safeguarding need;
• the potential impact on the individual and others; and
• whether continued publication remains lawful, necessary and proportionate.

Where information is retained, Beacon should be able to identify and document the reason for retention.

10.1 Copies of account data and account deletion

Signed-in Beacon members can use profile settings to:

• download a portable JSON copy of the data associated with their account after confirming their current password; and
• permanently delete their own account after entering their current password and typing the word **DELETE** exactly.

Account deletion is deliberately difficult to trigger accidentally. It is irreversible and cannot be recovered. It removes the member's profile and the content they created in Beacon's community spaces, including posts, replies, direct communications, Blueys, Scopes, reactions, uploaded media and submitted tributes.

A live Beacon Alert request is treated as an active safeguarding case rather than ordinary social content. If an account is deleted while such a request remains under review, Beacon removes the requester account link and private contact details but may retain the de-identified case record where this is necessary to avoid abandoning an urgent review, meet a legal obligation, maintain a proportionate safety or moderation record, or protect another person. Public missing-person information remains governed by the review and removal rules in this standard.

Administrator accounts cannot be deleted through profile settings while they hold administrator access. That access must first be transferred or removed so that deletion cannot unintentionally disable essential safety and moderation functions.

11. Review

This standard should be reviewed periodically and following any significant change to:

• applicable data-protection law;
• safeguarding guidance;
• platform functionality;
• Beacon’s alert-management procedures; or
• relevant operational learning.

This document is an operational policy and general legal explainer. It is not a substitute for case-specific legal advice.