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10 บทบัญญัติทางกฎหมายว่าด้วยสิทธิที่จะถูกลืม (Right to be Forgotten)
และแนวทางแก้ไขกฎหมายที่เกี่ยวข้อง

These countries include the European Union, Australia, Japan,

Hong Kong, Taiwan, the Philippines and Singapore.
However, based on a comparative method of legal

research, this research finds that an absence of the term
“right to be forgotten” and details on personal data delisting,

without erasing or destroying personal data, can cause compliance
challenges to the data controller who provides search engine
services.

A data subject may exercise his or her right as
guaranteed by Section 33 of the Personal Data Protection Act

B.E. 2561 (2019) to request a data controller, including an original
publisher (for example the press) and a search engine provider

(for example Google) to “erase” “destroy” or “anonymize”.
However, a search engine provider such as Google may only delist
the search results which can be deemed as an action that helps

protect the privacy of a data controller without directly erasing
or destroying personal data published by another personal data

controller such as the press.
This research finds that challenges of protecting right

to be forgotten may stem from the fact that personal data
protection may differ among countries. A right to request for

delisting personal data as guaranteed in one country may not exist
in another country. It is possible that a search engine provider
providing services and displaying search results to users residing

in Thailand may have its business operation in a foreign country.