Vancouver, Canada. In the digital age, personal histories are increasingly permanent, stored in databases, search engine results, and government archives that can be accessed worldwide. The European Union’s Right to Be Forgotten, embedded in Article 17 of the General Data Protection Regulation (GDPR), gives individuals the power to request the removal of outdated or irrelevant personal information from public access. 

However, the ability to effectively exercise this right is often a question of jurisdiction, and jurisdiction is primarily defined by citizenship. Amicus International Consulting, a global leader in legal identity transformation and multi-jurisdictional structuring, analyzes how holding a second passport can dramatically expand a person’s ability to invoke and enforce privacy rights internationally.

A second passport is more than a travel tool;  it is a legal connection to multiple privacy regimes. Different countries offer vastly different privacy protections, and citizenship is often the key to accessing those protections.

Jurisdiction is the gatekeeper of privacy rights. The EU’s framework is the most widely recognized, but similar provisions exist in Argentina, South Korea, Canada, and parts of Africa. Some rights are granted only to citizens, some to residents, and others to anyone with a legitimate connection to the jurisdiction.

Case Study: Entrepreneur Seeking Cross-Border Data Removal
A technology founder with citizenship in France and Saint Lucia faced outdated and misleading online coverage from a decade ago. Using their EU citizenship, they filed Article 17 requests to search engines and hosting providers across the European Economic Area. The removals were granted, something they could not have achieved under Saint Lucian jurisdiction alone.

Multiple citizenships create multiple points of legal standing. A person who holds citizenship in two or more countries can strategically select the jurisdiction with the strongest privacy framework when making a data removal request.

Case Study: Retired Athlete Transitioning to Private Life
A well-known sports figure, holding Irish and U.S. citizenship, used Irish law under the GDPR to have old injury reports and personal interviews de-indexed in European search results, allowing them to enjoy a lower public profile without rewriting sports history.

Different jurisdictions balance privacy and public interest differently. Some countries lean toward unrestricted access to public records, while others emphasize an individual’s right to control their data.

Case Study: Journalist Protecting Family
An investigative reporter with dual citizenship in Germany and Brazil invoked German privacy law to remove their home address from property records after receiving threats, while keeping their professional reporting accessible under Brazilian law.

A second passport can be a passport to more vigorous enforcement. Once a privacy request is granted in one jurisdiction, that decision can sometimes be enforced internationally through treaties or corporate compliance policies that span multiple countries.

Case Study: Tech Executive Using Dual Jurisdiction Pressure
A Canadian-Spanish dual citizen secured a GDPR ruling in Spain requiring a multinational hosting provider to delete outdated personal data. The same company complied with similar requests in Canada because of the client’s citizenship and the firm’s global policy alignment.

Global digital permanence is shaped by geopolitics. Countries often negotiate mutual recognition of privacy rights. Multiple citizenships increase the likelihood that an individual’s legal protections are included in such agreements.

Case Study: Data Breach Victim with Broader Coverage
A dual citizen of Portugal and the UAE successfully compelled a European controller to erase their breached personal data, using Portuguese law. UAE law did not offer this right, but the dual nationality created a second legal pathway.

Search visibility control is a central component of the Right to Be Forgotten. Even if a source cannot be deleted, de-indexing from major search engines can limit public discovery of sensitive information.

Case Study: Artist Balancing Public and Private Lives
An Italian-Australian artist used their Italian citizenship to have personal photographs removed from European search results, while still allowing professional portfolio pages to be visible in Australia to promote their work.

Regional Comparisons: Where Citizenship Unlocks Privacy Rights

Europe sets the global privacy benchmark. Under Article 17, EU citizens can demand erasure of personal data, subject to certain public interest exemptions.

Case Study: Academic Controlling Old Research Profiles
A Belgian-American scholar used Belgian law to have outdated academic work removed from university websites and search indexes, protecting their professional reputation.

The Caribbean offers strategic structuring opportunities. While many Caribbean states lack formal Right to Be Forgotten laws, their citizenship can be used to reposition tax residency and structure assets in privacy-friendly jurisdictions.

Case Study: Investor Reducing Corporate Registry Exposure
A Saint Kitts and Nevis citizen moved corporate entities into countries with minimal public registry requirements, reducing searchable information about their holdings.

Asia-Pacific privacy laws are expanding rapidly. South Korea and Japan have implemented data deletion rights similar to those in Europe, though the enforcement scope varies.

Case Study: Businesswoman Leveraging South Korean Law
A Canadian-South Korean dual citizen removed old financial disclosures from domestic media under South Korean privacy law, protecting her investment history.

The Middle East provides niche protections. While not comprehensive, some Gulf states offer potent remedies for unauthorized personal data use or defamation, often prioritizing citizens.

Case Study: Engineer Using Emirati and European Rights Together
A dual citizen of the UAE and Spain used Emirati law to remove personal images from domestic platforms, then extended the request internationally via Spanish GDPR claims.

Latin America recognizes constitutional data rights. Argentina’s habeas data allows citizens to correct or delete personal records held by public or private entities.

Case Study: Entrepreneur Enforcing Habeas Data in Two Systems
An Argentine-Italian business owner cleaned up inaccurate business listings in Argentina and extended similar removals to EU-based websites under Italian law.

Africa is emerging as a key player in the privacy rights arena. South Africa’s Protection of Personal Information Act (POPIA) grants citizens the right to request data deletion, which could become more influential regionally.

Case Study: Advocate Using African Privacy Law Internationally
A South African-British human rights advocate used POPIA to delete personal contact information from activist databases, then applied UK law to remove it from European indexes.

Eastern Europe offers growing privacy recourse. Countries like Estonia and Croatia are implementing GDPR-aligned protections, offering more vigorous enforcement for their citizens.

Case Study: Entrepreneur Leveraging Baltic Privacy Rules
An Estonian-American software founder removed outdated corporate filings from European business registries using Estonian GDPR authority, while keeping required U.S. filings intact.

Small island states can offer indirect privacy benefits. Some have minimal public record systems, which inherently reduce online exposure for citizens.

Case Study: Philanthropist Benefiting from Minimal Record Publishing
A dual citizen of a small Pacific island state enjoyed a near-complete absence from online property registries, simply because the jurisdiction did not maintain public-facing databases.

Compliance Planning: How Second Passports Fit into Long-Term Privacy Strategy

Tax residency can be aligned with privacy goals. Some jurisdictions require public asset declarations, while others do not. Choosing residency through secondary citizenship can protect financial confidentiality.

Case Study: Advisor Redomiciling for Privacy
A wealth advisor relocated their tax residency from a disclosure-heavy jurisdiction to one with sealed asset declarations, utilizing their second passport for the transition.

Corporate structuring laws differ dramatically. Where corporate filings are public, secondary citizenship can provide access to countries with less intrusive reporting.

Case Study: CEO Choosing Low-Disclosure Incorporation
A CEO incorporated their latest venture in a jurisdiction that did not require publishing directors’ addresses, avoiding unnecessary public exposure.

Family protection extends beyond the individual. Certain countries allow sealing civil records for citizens, protecting birth, marriage, and death records from public access.

Case Study: Parents Shielding Children’s Identities
Dual citizens of a European country with strong privacy laws registered their children’s births there, ensuring those records remained sealed from public view.

Digital identity compartmentalization is a powerful privacy tactic. Using different citizenships for separate roles, business, personal, and travel reduces linkage in global databases.

Case Study: Consultant Managing Triple Identity Separation
A consultant with three passports, allocated each to a different sphere of life, ensuring unrelated activities were not connected in automated data systems.

Historical Context: How Citizenship and Privacy Intertwined
In the pre-digital era, personal privacy was largely local, controlled by physical archives. As digitalization and search engines have globalized access, the concept of privacy jurisdiction has gained new importance. Citizenship became not only a marker of belonging, but also a gateway to legal remedies against unwanted exposure. Today, that connection is central to exercising the Right to Be Forgotten.

Conclusion
Second passports are not merely gateways to new countries; they are legal keys to different privacy universes. By expanding the jurisdictions an individual can claim, they multiply the chances of finding a legal system willing and able to erase, limit, or control personal data exposure. 

Amicus International Consulting designs second citizenship strategies with both mobility and privacy in mind, ensuring clients have lawful tools to reclaim control of their narratives in an age where the internet never forgets.

Contact Information
Phone: +1 (604) 200-5402
Email: [email protected]
Website: www.amicusint.ca