The Advocate General of the Court of Justice of the European Union has issued an opinion on the applicability of the GDPR right to erasure to personal data contained in baptism registers.

Referred by a Belgian court following a dispute between a citizen and the Diocese of Ghent concerning a request for erasure of data from the baptism register, the Advocate General confirmed in his opinion of 1 October 2026 that the GDPR applies to such processing. Baptism registers are considered structured files of personal data, and the autonomy of religious organizations does not prevent this conclusion. Although the initial processing of the data may be deemed lawful, the data subject can in principle object to it and request erasure. The Church can only continue processing if it demonstrates legitimate and compelling grounds that override the rights and freedoms of the data subject. The proper administration of the sacraments may constitute such a ground, but it is up to the national court to assess on a case-by-case basis whether the processing remains necessary and to balance the rights of the data subject (privacy, data protection, freedom of conscience and religion) against the autonomy and freedom of religion of the Church.