Europol may refuse deletion under Article 36(3) if data remains necessary for operational purposes. However, this justification requires specificity — Europol cannot simply cite general investigative utility. We challenge vague refusals by demanding identification of the specific investigation, the contributing member state, and the proportionality assessment undertaken. If the underlying investigation has stalled, been closed, or no longer requires your specific data, the refusal is legally deficient. EDPS appeals frequently succeed where Europol fails to demonstrate current operational necessity.
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