I haven't read all of this thread, so apologies if this has already been covered, but I'm stunned by how clueless the ICO are and would like to add my own experience:
Several years ago I applied for results related to my name to be delisted (a link to a newspaper article about an old conviction). The article appeared on page 1 when I searched for my name AND my current employer, but the ICO refused my request because when they searched for it, they couldn't see the result anywhere. Clearly, they have no idea how a search engine works. The search results will vary significantly depending on a wide range of factors: previous search history, browser, location and time of day amongst others. These are variables in every search algorithm.
My point is: which page a listing appears on in a search shouldn't be a factor in the ICO's decision making process. This is because for some people it will appear on page 1 (maybe because their IP address is local to the newspaper in question), but for others it could be on page 1,000 (because they are searching from the other end of the country). All that matters is if it is listed in major search engines. If anything, it would the ICO's job easier by streamlining the process and making it a more universal rule.
At the moment, as an organisation the ICO are really not fit for purpose. I'll end with one last example to demonstrate this. When I first made my application (this was several years back) it took them several months and several reminder emails to get back to me. They declined the application on the grounds that I didn't supply the required information. They didn't tell me any more than that. For some reason, they returned my original documentation in an email and when I checked this, I noticed that the PDF form had cut off a huge chunk of the information I had supplied. I checked the original document I had sent them which didn't have this issue - so somewhere, at some point, they messed something up in the formatting and just decided to dismiss the application (after months of waiting). They didn't even let me send them the original form, and told me I had to start the application from scratch.
Apologies for the long rant, but it's helpful to know what we're working with here!
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