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The ‘Right to be Forgotten’ and the role of the Information Commissioner’s Office (ICO)

Overview

The Information Commissioner’s Office (ICO) is the UK’s independent regulator for data protection. It makes sure that people’s personal information is handled fairly and safely, and that organisations follow the UK General Data Protection Regulation’s (GDPR) and the Data Protection Act 2018 (DPA 2018).

The ICO’s work covers anyone who processes personal data in the UK, from large companies and government bodies to individuals running websites or online groups.

What allows the ICO to take action?

Under the law, personal data can only be used if there is a lawful reason (known as a “lawful basis”).

Information about criminal convictions or alleged offences is particularly sensitive. It can only be used by authorised organisations, and only with strong safeguards in place.

Websites that share conviction details, “name and shame” individuals, or post allegations without a lawful purpose are likely breaking data protection rules. They may be violating these key principles:

  • Lawfulness, fairness and transparency: data must be used legally and fairly.
  • Purpose limitation: data collected for one reason can’t be reused for another.
  • Data minimisation: only the minimum information necessary should be used.

Sometimes, people running these sites claim they are doing “journalism.” However, posting names and photos to shame people is not journalism and does not serve the public interest.

What can the ICO do?

The ICO has a range of powers to investigate and take action against unlawful data use:

How effective is the ICO?

Many people have raised concerns about how effective the ICO really is. Whilst they are supposed to protect people’s data rights, critics say they often fall short. Common concerns include weak enforcement, slow complaint handling, limited accountability, and questions about its independence.

Weak and inconsistent enforcement

  • Few formal actions: Around 93% of complaints reportedly lead to no formal action. This leaves many people feeling that their data rights aren’t being properly protected.
  • Avoiding fines: Under its current leadership, the ICO has moved away from issuing fines, especially to public sector bodies. Instead they give ‘reprimands’ (letters expressing disapproval without legal consequences). This approach doesn’t deter bad behaviour.
  • Focus on headline cases: The ICO is often seen as prioritising large, high-profile investigations over individual complaints. As a result, smaller organisations may feel less pressure to comply with data protection laws.

Complaint handling and accountability

  • Long delays: People often wait a long time to have their complaints reviewed. Automated responses suggest it can take around 29 weeks (203 days) just for a case to be assigned. This is well beyond the expected three-month update period.
  • High bar for action: The ICO often only takes stronger action when there’s evidence of a widespread or systemic problem. This can leave individuals feeling that their personal cases don’t matter.
  • Few options to challenge: If the ICO decides not to take action, there are very limited ways for people to appeal or challenge that decision. The ICO has also stated that it isn’t required to investigate every complaint it receives.

Independence and potential conflicts of interest

  • Funding model: The ICO is funded mainly by fees from the organisations it regulates. This raises concerns about a conflict of interest, as it may be reluctant to take tough action against major fee-paying companies.
  • Political influence: Proposed changes in the Data Protection and Digital Information (DPDI) Bill could allow ministers to influence the ICO’s work. Critics fear this could weaken its independence and objectivity.

What can you do if you believe your data is being breached?

If personal or criminal record information about you has been shared online without your consent, you can:

  1. Contact the organisation, website host or platform and request the removal of the information. This is often referred to as the Right to Erasure or Right to be Forgotten (under Article 17 of GDPR). You can find further information on what to include in your request at ‘The Google Effect and the Right to be Forgotten.
  2. Complain to the ICO if your request to the organisation is refused, and ask them to investigate.
  3. Ask for compensation through the civil courts if the misuse has caused you distress or harm.

Summary

Everyone deserves a fair chance to move on from the past.

The ICO plays a crucial role in protecting that right, ensuring that personal information is handled lawfully, fairly, and with respect for privacy and dignity.

Fighting for our right to rehabilitation: online articles are a life sentence

Johannes – Google removed links to my name 6 months after my conviction was spent

“Don’t let trolls affect your goals” – getting links to your name removed from the internet

Thanks to a close friend, Emlyn found out about the Unlock website and specifically how he could apply to Google to have links to his name removed. As his story demonstrates, this process really can be successful.

 

My conviction dates back to 2004, when I was 22. I was still living at home, was terrible at managing money and had an enormous amount of debt. This was mostly store and credit cards that I was struggling to pay. I had just got into a stable relationship, and things were starting to work out well for me. I took a job at a call centre for a credit card company, as it was well paid and local. I happened to have a credit card and debt with them but they didn’t check this.

Although I did not set out to, after working there for several months, I discovered that there was a way to wipe my own debt just by pushing a button. The temptation was too much for me, and although I knew it was wrong, I did it. Within seconds my entire debt was wiped. But, it didn’t stop there, I got greedy and I began transferring money from customer accounts into my bank account as cash and then replacing it with credit on their accounts so that they wouldn’t notice. Or so I thought. My own bank noticed the payments, questioned them, and informed the company that I worked for. I was immediately suspended, an investigation was completed and I was arrested and charged.

My case initially went to the magistrates court who referred it to the crown court for sentencing as I had pleaded guilty where I was given a prison sentence. Fortunately, my partner and my parents all stood by me.

All of this happened before Facebook, camera phones and other social media and I was lucky that my story was only published by one local newspaper who also spelt my name wrong. Other than this, there was no public record of my offence.

A year after my conviction my partner and I relocated to Italy, where we began work restoring a Tuscan barn. We took an Italian mortgage to pay for the work and I lived off some money that had been left to me after the death of my grandmother. Unfortunately my relationship with my partner ended and I returned home to live with my parents.

I took a job at a local coffee shop in order to get to know new people, make friends and earn an income. Whilst there I befriended a young, troubled teenager and we became close. I confided in him about my criminal conviction even though I’d not disclosed it to our employer (it hadn’t been asked for on the application form). However after a falling out, he informed our manager of my conviction.

An investigation and enquiry was conducted to determine whether I had obtained the job by deception and whether I should have informed my employers of my criminal record. I faced losing my job but after a meeting with my manager it was decided that as I hadn’t been asked about my record I shouldn’t have been expected to disclose it.

Not long after this, I received an incredible job opportunity with the chance to move to London. It was a fresh start, a way of finally putting everything behind me and to move on with my life.

Apart from the existing friends who knew about my conviction, for most of the time I lived in London I did not think about my criminal record or tell anybody about it. It was a part of my past. I had served my time, learnt from it and was now a completely different person in a different situation. I no longer had credit cards or any debt and was able to manage my finances.

However last year I started to suffer from a series of online attacks after an individual I’d had some previous dealings with came across the only article published about my criminal record. The individual concerned threatened to re-publish the article and although I consulted my solicitor and informed the police there was very little I could do as the information was already in the public domain.

The individual followed through with his threats and this resulted in further trolling and abusive messages with many of the tweets and Facebook messages branding me a “thief” and a “liar”. It was an extremely traumatic time for me and my family and friends, triggering lots of painful memories and all because of the original article which could still be found online about me.

Talking to a friend one evening he told me that there might be a way to have the article removed from the Google search and he suggested that I have a look at the Unlock website and the page relating to the “Google-effect”. It looked like the first step would be to apply to Google to get the links to my name removed from their search engine so, using the template and links on the Unlock website, I immediately completed the online form.

Four days later, I received a response and confirmation from Google that in accordance with my request, they would remove the URL’s for queries related to my name. It was astonishing news. I immediately tested it by typing in my name and sure enough, the article relating to my conviction no longer appeared. I was shocked that it worked and by how quickly it had been actioned.

The article still exists and can still be found but it no longer comes up simply by searching my name and that’s enough for me. It will no longer follow me around or be available just by searching my name. This provides comfort and assurance, knowing that I have more control over who can access this information about me. It also prevents anyone from using my criminal record against me for malicious purposes.

Had I known that it was possible to make a request to have these links removed, I could have saved myself and my family a lot of heartache and distress.

By Emlyn (name changed to protect identity)

Useful links

Google, It’s time to do better – spent convictions should stay spent

Facing possible rejection again – applying to Google to have links to my name removed

Source: Adobe Stock

As far as she’s aware, the fact that there is information online about her criminal record hasn’t had too much of an impact on Lucy. However, since her conviction became spent she has started to feel very strongly that either the articles themselves, or links to them should be removed.

Back in May 2014 the Court of Justice of the European Union ruled that individuals should be able to request the deletion or removal of personal data published online where there is no compelling reason for it to remain. This has become known as the ‘right to be forgotten’.

I was on holiday in Devon when this news broke and I can remember listening to the radio and thinking of the enormous impact this could have on somebody like me – a person with a criminal record whose name could easily be found online.

Following my release from prison, I’d been lucky enough to get a full time job and, although I’d disclosed my unspent conviction to my manager, I lived in constant fear that a work colleague would ‘google’ me and spill the beans about my past. To the best of my knowledge I don’t think this ever happened but I can never be sure. So, having the opportunity to apply for links to my name to be removed was potentially a massive deal for me.

A few days after the Court of Justice case had been reported on some of the more right wing newspapers were criticising the changes. One said:

Applications have come from corrupt public figures and criminals desperate to hide their past.

Although Google stressed that they would deal with each delisting application on a case by case basis, it quickly became clear that they were unwilling to remove search results relating to unspent convictions. Knowing that it was going to take many years for my conviction to become spent making an application to Google seemed less of an option for me.

As I was married with a family, changing my name also presented more challenges than it overcome and so, I made a conscious decision to try and increase my positive profile on the internet.

Creating a profile on sites like Linkedin gave me an immediate presence online as did commenting on articles written by others. I started submitting my own articles to publications and sites and was surprised when they were published. I later found out that many trade magazines struggle to get people to write articles for free and are open to accepting those written on topical issues.

It wasn’t a quick process but within a year I’d managed to push a lot of the negative newspaper reports to page 3 on Google and, as time went on, removing links to my name became less important.

However, once my conviction became spent it actually bought home to me how wrong it is that the links to my name still exist online. I may be naive in thinking that an employer seeing this might still give me the opportunity to explain myself if they felt I had the skills and experience to do the job. But what about colleagues? I doubt whether they’d confront me over what they’d read but some would undoubtedly believe everything the newspaper had reported.

And so I’ve decided to face rejection again and make an application to Google to have the links to my name removed. I wanted to share this experience with all those that read theRecord and pass on anything I learn from this journey.

I can’t say it’s started too well. Today I’ve tried to pull together a list of URL links for every article appearing in a search on my name (you need to provide these on the online application form). I’m not sure what made me read every article but I did. I find it hard to recognise the woman being described on those pages but I remember so clearly how chaotic and out of control her life was at that time. It’s hard reading this stuff and I’ve certainly shed a tear or two.

I get the feeling that this process might be harder than I imagined but as they say “tomorrow is another day“. Just watch this space.

By Lucy (name changed to protect identity)

A comment from Unlock

Since the news in 2014 of ‘the right to be forgotten’ Unlock has been actively looking at if and how this is being applied to spent convictions. We would encourage anybody who has been unsuccessful with Google (or other search engines) to refer their case to the Information Commissioners Office as a formal complaint.

Useful links 

I fought the big guys and won – getting a newspaper article removed

Having successfully applied to have links to her name removed from search engines such as Google and Bing, Lucy decided to make a request to the newspaper to have the source article taken down.

My conviction was 25 years ago but it had made the press and whilst it wasn’t that much of a big deal at the time, in the age of the internet, I soon found it to be a major problem. I found that I couldn’t apply for the jobs I wanted to because even though my conviction was spent, people could easily look me up on Google and see the press articles.

I considered changing my name but for me it wouldn’t have helped. If I’d had to have a criminal record check I would have needed to disclose my previous name and the reason for changing it. Employer’s or hiring staff would then be able to look me up and see everything.

For years I avoided the jobs I wanted and felt really down about it. It seemed so unfair that I was not able to move on properly with my life, knowing all the while that these articles were out there, lurking, just waiting to be found.

However, everything changed for me when I came across the Unlock website and a page about applying to Google to get links to your name removed. I read the page over and over and then set about filling out the request form, not just to Google but for several other search engines.

A couple of weeks later I was surprised to get a notification from Google, Bing and a few others agreeing to my request. I typed my name to test it out and sure enough nothing appeared.

A website was, however, still linking to the articles and when I contacted them to find out why, they explained that as they received their information upstream, they were unable to remove it; I’d have to go directly to the source (this was a national newspaper).

I wrote to the newspaper outlining my reasons for wanting the article removed and provided them with the correspondence from Google and Bing which confirmed their agreement to remove the links. The newspaper refused my request.

Feeling really deflated I contacted the Unlock helpline to find out whether there was anything else I could do. They advised me to make a complaint to the Information Commissioners Office (ICO).

This time the newspaper got their legal team involved but they still refused my request on the basis that the articles were still of significant interest to the public. They might have been trying to scare me but I felt empowered after all my research. I appealed their decision mentioning the Rehabilitation of Offenders Act and how I had a right to live a life free of being periodically stigmatised by their articles. I stated that the articles were no longer in the public interest, that they were irrelevant, excessive and they infringed my right to live as if I had not committed those crimes; I copied this letter to the ICO.

A week later and another email from the Head of Legal at the newspaper, they agreed to my request to take down the article.

How amazing is that! A David and Goliath situation and little me won!

I’m delighted that after so long I can apply for the jobs I want without worrying about being ‘Googled’. I didn’t have a clue that I could do anything about getting this article removed or where to begin but once I knew it was possible, I wasn’t going to give up.

By Lucy  (name changed to protect identity)

Useful links

Google, you know my name but don’t judge me when you don’t know my story

Having overcome the impact of his criminal record from 25 years ago, Nick was devastated to find that links to his name (and his conviction) had been made available on an internet archive site. Read about his efforts to get the links to his name removed.

 

 

25 years ago I received a conviction which resulted in a 3 line article in a local newspaper. 

The conviction resulted in a community order which I completed as soon as I could and since then, I’ve worked hard and done well career wise. As it was so long ago, very few people other than my immediate family know about it and I’m sure that many who know me now would be shocked to learn that I have a criminal record.  

I was therefore horrified to discover last year that these 3 lines of print had suddenly reappeared online on an internet archive site.  

Like a lot of people with a criminal record, the experiences you’ve had never quite leave you and I became totally stressed out about the consequences of this becoming known to family, friends and colleagues. I have a very unique surname and I knew that if anybody googled me, then this article would come up straightaway.  

I didn’t believe that my conviction was ‘still of public interest’ and I started to hope that it might fall under the category of “right to be forgotten”. I did a lot of research and eventually discovered that I could apply to Google to have the links to my name removed which I did.  

Google came back to me very quickly, to tell me that in their opinion, my story was still in the public interest. I was distraught, not least because the article relating to me was now even nearer the top of page 1 in the google search.  

I was sure that if my employers found the article (or somebody told them about it) then they’d dismiss me immediately, just on the grounds of reputational harm. As much as I told myself this wouldn’t happen, the effect it was having on my mental health was frightening. I couldn’t believe that a private company like Google could take it upon themselves to be the ‘judge and jury’ of what constitutes public interest.  

I started to investigate the cost of involving a solicitor but found that they often couldn’t give me any idea of my chances of success but wanted to charge me an exhorbitant amount of money. One really helpful company that I spoke to suggested that I could try making a complaint to the Information Commissioners Office (ICO) which is what I did next.  

As I waited for a response from the ICO, I started to think back to when I’d originally applied for my job. I couldn’t remember whether I’d been asked about my conviction but if I had, I knew that I hadn’t disclosed it. I was worried that it might have been unspent at that time and that I should have told my boss. Further anxiety followed until I found out for sure that my conviction had been spent when I’d applied for my job and so I’d done nothing wrong in not disclosing. 

It took the ICO quite a while to get back to me – they seem very busy dealing with similar cases to my own. However, I eventually got the news I wanted, the ICO had found in my favour and asked Google to de-list the search results. The following day I received an email from Google telling me that they’d  

Reviewed my case and would de-list the search results in the UK and EU”

I’m delighted with the result but can’t believe that 25 years on I’ve had to deal with this all over again. I worry that individuals being convicted now are so exposed to the internet and social media and that companies carry out google searches as a way of informally checking someone’s record.  

At the time that I was seeking help, I was worried that I was going to loose my job so I was careful about every pound I spent. Some of the solicitors I spoke to were giving me quotes of £5,000 to deal with my case with very little certainty that they’d get any kind of result; this just wasn’t financially viable for me.  However, as my story demonstrates, you don’t need a solicitor to help you, with a bit of time and patience you can do it yourself. My advice to anybody affected like this is to apply to Google and if that doesn’t get a positive result take it to the ICO.   

By Nick (name changed to protect identity)

 

Comment from Unlock

In April 2018 the High Court ruled on two cases involving individuals with spent convictions that brought claims against Google for refusing to de-list search engine results.

If an application you’ve made to Google has been refused then there are possible legal remedies – further information can be found here.

Useful links

I got the link to my sexual offence conviction removed from a search engine

Russell felt strongly that as his conviction was spent, internet search engine links should be removed. Despite his request being refused by both the search engine and the Information Commissioners Office, Russell never gave up and his tenacity eventually paid off.

 

I was convicted of internet related offences under the Sexual Offences Act following online contact with teenage girls. I accepted full responsibility, expressing genuine remorse for my actions.

My case was reported in my local newspaper although it exaggerated and misrepresented the facts of the case. Mercifully, the article was taken down but not before it was copied to a very unsavoury, vigilante website.

At the beginning of 2018, I applied to an internet search engine for this link (and others) to be removed after my sentence became spent. I sent them a host of evidence including expert reports expressing the view that I was rehabilitated and did not present any risk of re-offending. I also sent key evidence from the UK police confirming that vigilante websites were not in the public interest and compromised the personal safety of the individual. This included quotes from a managing Chief Inspector who spoke of the “inevitable inaccuracies” contained within such websites. Also sent was unequivocal evidence clearly demonstrating the inaccuracy of the information in question. The internet search engine responded within 24 hours stating:

The information is still relevant and therefore in the public interest”

I asked the internet search engine to elaborate as well as confirm their position in relation to vigilante websites but was met by a generic response advising that a decision had been taken in accordance with internet ‘policies’ and my only option was to contact the webmaster. I feel that the 24-hour turnaround was too quick, and it couldn’t have been any clearer to me that they had simply not bothered to look at the evidence, preferring not to delist based on the nature of the offence alone.

After getting some advice from Unlock, I referred the matter to the Information Commissioners Office (ICO). I sent them the same evidence and after a couple of months received a response which, to my dismay, endorsed the position taken by the internet search engine.

The only reason given was the nature of my conviction and even when I emailed them back with further evidence, I was once again ignored. As a last throw of the dice, I applied to the ICO for a managerial review and to cut a long story short, I was eventually able to get the ICO to acknowledge the relevant evidence provided. To the ICO’s credit, the assessing manager dealt with the matter both professionally and objectively. I suspect it will have taken some courage to go against the apparent ‘trend’ of simply saying ‘no’ and am certainly grateful to the ICO for that. By this time, the DPA 2018 and the GDPR had come into force which I was also able to use to my advantage.

Finally in September 2018 after umpteen emails, phone calls and unrelenting pressure, the ICO wrote to the internet search engine advising them that the links should be removed. I’m pleased to report that this has now taken place.

The moral of the story is:

Where there’s a will, there is a way”

I hope my story can provide some help and comfort to individuals in a similar position. Below is a quick breakdown of some of the key strategies/approaches I used to force the right decision. I would say that perhaps the most important key to my success was remaining calm and controlled under repeated provocation. Evidence and facts will eventually speak for themselves and cannot be ignored forever.

  1. Prepare a direct response to the ICO’s Delisting Criteria
  2. Send any evidence (expert reports etc) relating to rehabilitation
  3. Reference the recent decision in the case of N1 and N2 where there is evidence of genuine remorse/rehabilitation/change of circumstances
  4. Reference Article 10 of the GDPR when dealing with vigilante websites holding criminal databases
  5. Reference Section 47 of the DPA 2018 when dealing with factual inaccuracies
  6. Reference Government recidivism statistics which confirm that sexual offences have the lowest rate of re-offending
  7. Under Article 22 of the GDPR, an internet search engine must provide “compelling legitimate grounds” to justify why their right to data process outweighs your own right to removal. Simply stating that the information is ‘still relevant’ is not enough. They need to explain clearly why this requirement has been fulfilled and this is particularly the case where your personal safety is being compromised.

Remember internet search engines are not the arbiters of criminal justice and public interest. This is the job of the UK authorities. If in doubt, seek legal assistance. Good luck with your applications.

By Russell (name changed to protect identity)

 

A comment from Unlock

Whilst there has been some success in getting internet search engines to remove links that relate to some convictions, where the link refers to a sexual offence, internet search engines have been reluctant to remove these. This is the first case of where a link to a sexual offence has been removed but we hope that because of the case of N1 and N2, people with a spent sexual conviction will now be treated more fairly when requesting that links be removed.

Useful links

 

Getting a US visa capped a very successful two years of rehabilitation post-conviction

Once you’ve received a conviction, it can be easy to assume that the worst will happen and life as you know it will end. However, as Ben has found out, if you plan for everything and don’t give up hope then there is light at the end of the tunnel – just make sure you head towards it.

 

I have always been resourceful. Always had decent jobs, even holding down a fairly senior job. My world changed in 2016 when I was found guilty of a fraud offence.

I pleaded guilty and received a fine. Unfortunately my employer found out about it and decided that I posed too much of a risk to them from a publicity perspective and I agreed to resign.

Fortunately, I had already planned for this eventuality following my arrest some months earlier. I knew when my court date was and guessed that my employer would find out soon after and that they would want me to leave. That’s where my master rehabilitation plan swung into action!

To protect myself from the ‘google-effect’, I changed my name by deed poll and went through the arduous process of changing it across bank accounts, insurances, government agencies and family/friends.

I looked at the job market and started to consider a new career in my new name, therefore preventing the ‘DBS by Google’ impact. If they chose to Google me, they wouldn’t find anything negative that they could use against me.

As I agreed to resign, I also negotiated with my outgoing employer to have an agreed reference confirming that my reason for leaving was one of resignation and nothing that could be deemed more sinister. When the HR team requested the reference, I made them aware to do so in my old name, I explained it was my former professional name – it didn’t raise any questions and the reference came back as agreed.

So, from a work perspective I was sorted. New job to start following my court appearance, new name, new documents and looking forward to moving on with my life post-conviction. I just had to ride out the initial 12 months to cover the time it would take before it became ‘spent’, and a further 12 months to make it 2 years so that my employment was protected from unfair dismissal.

My next challenge was that I was planning a holiday to the USA – luckily it wasn’t for 2 years but I had read the horror stories and forums about anyone who had a fraud conviction (a crime involving moral turpitude) would not be eligible for a visa waiver and therefore have to go down the visa route which is not always successful – having spent over 10 holidays in the States over the last 15 years, I was thinking about the prospect of never being able to go back.

Using the US Consular website I completed my DS-160, applied for my police certificate from ACRO and printed off my VCU1 form – I made sure that all of the information matched across the various forms, I went back through my diary and passports to ensure I captured any visits to the US and the countries around the world – I wasn’t taking anything for granted and after all, I had nothing to hide.

I paid my $160 and managed to get an appointment for a Friday morning. Again, the forums paint a range of stories about long queues, consulate staff who can be obstructive, long waiting periods and bad news stories but my experience was quite the opposite.

I travelled to London the night before. I arrived at the Embassy wearing my best suit, shirt and tie, carrying a folder containing every document I could ever need to prove my ties to the UK and financial status. Going through a very smart and efficient security checkpoint and into the Embassy visa department, you get a ticket and wait for your number to flash up on the screen.

The screen flashed up my number and I headed round to one of the private booths away from the rest of the standard visa windows. The lady took my fingerprints, asked why I could not use the ESTA system, scanned my documents and then asked me to wait to be called and interviewed.

I waited for another 30-40 minutes when I was called to another room. I was greeted by an American lady who proceeded to question me about my employment status, how long my last visit to the US was for, when I was looking to go back again and then the details around my conviction – I explained everything honestly and with full detail. After what seemed to be ages, the lady looked up from her screen and said “I’ve approved you for a visa”. I’d got a full tourist visa for multiple entries and then the revelation came – it was for 10 years!

If it wasn’t for the glass security screen, I would have hugged her. She explained that I would be getting an email in the next couple of days with the details of where to pick up my passport.

The email came through a couple of days later and I drove to pick up my gleaming passport with the new 10 year visa stuck in it – I was elated.

My 2 year rehabilitation is now complete – new job, new name, new outlook, no negative online footprint and a new 10 year US tourist visa to boot. Regardless of what happens, try to be one step ahead and ensure you plan for every eventuality. In this process it usually will happen and with a clear plan in place, you should be able to deal with any pitfalls.

By Ben (name changed to protect identity)

 

Useful links

  • Comment – Let us know your thoughts by commenting below
  • Information – We have some practical information on travelling to the USA
  • Discuss this issue – There are some interesting discussions related to this issue on our online forum.

 

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