Enhancing Data Governance in Data Trustees Through ODRL-Based
End-of-Life Policies
Michael Steinert
1,2 a
and Daniel Tebernum
1 b
1
Fraunhofer Institute for Software and Systems Engineering ISST, Dortmund, Germany
2
TU Dortmund University, Dortmund, Germany
Keywords:
ODRL, End-of-Life Data Management, Data Trustees, Data Spaces, Data Governance.
Abstract:
While data sharing drives innovation, ensuring compliance with legal, regulatory, and trust requirements
presents significant challenges. Research identifies data trustees as intermediaries between providers and
consumers, facilitating compliant and trusted data sharing. However, an underserved aspect is managing the
end-of-life (EoL) of shared data, where standardized, machine-interpretable mechanisms for detailed EoL poli-
cies are lacking. To address this gap, we propose an extension of the Open Digital Rights Language (ODRL)
to incorporate semantically rich EoL policies. This enables the specification of data deletion requirements,
supporting legal and regulatory obligations. Data trustees can use these enhanced policies to coordinate EoL
actions among all parties. The explicit semantics within these policies facilitate clearer accountability and
support the creation of auditable logs by making EoL obligations machine-interpretable and unambiguous.
Our ODRL extension has been evaluated by ODRL and data governance experts, ensuring its robustness and
relevance for practical implementation. This work contributes to the standardization of EoL data management
by analyzing and articulating the detailed requirements for EoL policies in the context of data trustees, and by
proposing a specific ODRL extension to meet these requirements. For practitioners using ODRL, our exten-
sion provides enhanced, machine-interpretable EoL capabilities, improving compliance and trust.
1 INTRODUCTION
In times of constantly growing data volumes and
ever more complex legal requirements, efficient end-
of-life (EoL) data management is becoming increas-
ingly important. This is particularly relevant with the
widespread adoption of generative AI, which can pro-
duce vast quantities of data, further emphasizing the
need for systematic data deletion strategies. A sys-
tematic approach to data deletion is essential (Teber-
num and Howar, 2023), especially for data trustees
who facilitate trusted and neutral data access between
data providers and data consumers while comply-
ing with legal requirements (Specht-Riemenschneider
and Kerber, 2022). In this process, data trustees must
maintain the trust and interests of all stakeholders.
Acting neutrally does not mean having no interests
of their own; rather, it means balancing the various
stakeholders’ interests (Schinke et al., 2023), a core
aspect emphasized in defining their trusted role (Lind-
a
https://orcid.org/0009-0008-3888-2092
b
https://orcid.org/0000-0002-4772-9099
ner and Straub, 2023). To address these interests,
data trustees can operate in a specific sector (e.g., the
building sector) to meet stakeholder needs and under-
stand data and regulatory requirements (Steinert et al.,
2025). Incorporating EoL considerations offers data
trustees technical advantages (such as improved re-
source and cost optimization, reduced attack surfaces,
higher data quality (Tebernum and Howar, 2025)) and
strengthens stakeholder trust (Steinert and Tebernum,
2025).
To ensure the protection and targeted use of data,
data providers and consumers conclude data pro-
cessing agreements with data trustees to govern data
flows, enforce agreed-upon rules, and manage con-
sent or usage rights (Stachon et al., 2023). These
agreements (also called data contracts) contain com-
prehensive usage guidelines in which prohibitions,
permissions, and duties are defined (Iannella and
Villata, 2018). One way of making such policies
machine-readable and automatically enforceable is to
map them in Resource Description Framework (RDF)
using Open Digital Rights Language (ODRL). Simi-
lar access and usage policy mechanisms are already
Steinert, M. and Tebernum, D.
Enhancing Data Governance in Data Trustees Through ODRL-Based End-of-Life Policies.
DOI: 10.5220/0013669800003985
Paper published under CC license (CC BY-NC-ND 4.0)
In Proceedings of the 21st International Conference on Web Information Systems and Technologies (WEBIST 2025), pages 27-38
ISBN: 978-989-758-772-6; ISSN: 2184-3252
Proceedings Copyright © 2025 by SCITEPRESS Science and Technology Publications, Lda.
27
being used in data spaces (Dam et al., 2023; Ei-
tel et al., 2021), i.e., digital infrastructures that en-
able the secure, controlled, and sovereign exchange
of data between different stakeholders (Otto et al.,
2022). However, while ODRL provides a robust
foundation for general usage policies, including a
basic odrl:delete action, specifying the complex nu-
ances required for verifiable and compliant EoL data
management presents a challenge within the standard
ODRL vocabulary. Specifically, important aspects
such as the explicit rationale behind a deletion re-
quirement (e.g., legal mandate vs. user consent with-
drawal vs. data quality remediation), the mandated
deletion method (e.g., logical deletion vs. crypto-
graphic shredding), requirements for proof of deletion
or the handling of data dependencies are not natively
supported in a standardized, machine-interpretable
way. Representing these EoL specifics often requires
extensions or remains implicit within policy defini-
tions. This semantic gap hinders interoperability and
the automated traceability of deletion duties and au-
ditable compliance trails, particularly within multi-
stakeholder environments, such as data spaces, facili-
tated by data trustees.
The importance of EoL data management is un-
derscored by external research, such as a survey of
35 data trustee experts, which found that respondents
consider reliable and traceable data deletion to be
a part of data trustees’ activities
1
. Acknowledging
these findings and the identified semantic gap in cur-
rent policy languages, we aim to enhance EoL data
governance for data trustees by addressing the follow-
ing two research questions:
RQ1: What specific requirements must an EoL
policy vocabulary fulfill to enable EoL data manage-
ment by data trustees, particularly within data spaces?
RQ2: How can the ODRL standard be ex-
tended with a semantically rich vocabulary to meet
these EoL requirements and facilitate machine-
interpretable specification of deletion policies?
To answer these questions, we first analyze and ar-
ticulate the requirements for a uniform, semantically
rich vocabulary for data deletion policies suitable for
data trustees. Subsequently, we propose an ODRL ex-
tension incorporating these requirements, drawing in-
spiration from existing EoL frameworks like the De-
stroyClaims concept (Tebernum and Howar, 2025)
2
.
Our contribution focuses on defining the essential
components of this vocabulary to facilitate machine-
interpretable EoL policies. The aim is to establish
a more comprehensive data governance model, en-
abling automated compliance with EoL duties and
1
https://doi.org/10.5281/zenodo.14992879
2
https://github.com/DaTebe/destroyclaims
thereby reinforcing trust in data trustees.
The remainder of this paper is structured as fol-
lows: Section 2 provides the theoretical background
on data trustees, data spaces, and the intricacies of
EoL data management. Section 3 delves into the
requirements for an EoL policy vocabulary tailored
for data trustees, directly addressing RQ1, and also
presents our proposed ODRL extension, detailing the
vocabulary and associated mechanisms needed to ful-
fill these requirements, thereby answering RQ2. Sec-
tion 4 describes the methodology and findings of our
qualitative evaluation, focusing on an expert work-
shop to assess the feasibility and conceptual sound-
ness of our ODRL extension. Section 5 discusses the
implications, potential benefits, and limitations of our
ODRL extension. Finally, Section 6 summarizes our
findings and outlines directions for future work.
2 THEORETICAL FOUNDATION
This section first outlines the core concepts that un-
derpin our work: data trustees and data spaces. Un-
derstanding these concepts is crucial for contextualiz-
ing our proposed ODRL extension for EoL data man-
agement. We also discuss the importance of EoL data
management.
2.1 Data Trustees
Data trustees represent a specific form of data inter-
mediary designed to act in the best interests of ex-
ternal stakeholders, namely data providers and data
consumers, without pursuing commercial goals con-
cerning the data itself (Specht-Riemenschneider and
Kerber, 2022). Literature distinguishes between a
narrower focus on fiduciary data management and a
broader view emphasizing the trustee’s role in facili-
tating trusted data sharing (Reiberg et al., 2023; Lind-
ner and Straub, 2023). Their fundamental role is to
serve as a trusted entity facilitating interactions be-
tween these parties (Schinke et al., 2023), ensuring
neutrality and transparency in their operations (Lind-
ner and Straub, 2023). By fulfilling this role, data
trustees ensure that data access and utilization occur
responsibly and compliantly.
Typical responsibilities of a data trustee include
mediating between data supply and demand, support-
ing the technicalities of data exchange, and fostering
trust among participants (Specht-Riemenschneider
et al., 2021). They offer an alternative to platform
models, thereby helping to counteract the forma-
tion of platform monopolies (European Commission,
2022). This contributes to market pluralization and
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enables smaller or specialized actors to participate ef-
fectively in the data economy, which can strengthen
market innovation (Shaharudin et al., 2024). The op-
erations of data trustees are grounded in technical, le-
gal, ethical, and organizational standards that guaran-
tee security and reliability. Functionally, they can ei-
ther hold the data directly or facilitate the direct shar-
ing of data between the parties involved (Lauf et al.,
2023). In either scenario, the objective is to safeguard
the interests and rights of all participants, cultivate
trust within the data ecosystem, and ensure fair and
transparent data sharing (Stachon et al., 2023). Fi-
nally, data trustees should have domain knowledge,
such as in the building sector, which can further en-
hance their ability to meet stakeholder needs and nav-
igate specific regulatory requirements (Steinert et al.,
2025).
2.2 Data Spaces
The concept emerged partly from the need to manage
increasingly diverse and distributed data sources be-
yond traditional centralized databases (Franklin et al.,
2005). Data space technology offers a technical foun-
dation for implementing the functionalities required
by data trustees, enabling secure and sovereign data
sharing (Otto et al., 2022). CEN and CENELEC, the
European bodies responsible for developing techni-
cal standards, define a data space as an “interopera-
ble framework, based on common governance prin-
ciples, standards, practices, and enabling services,
that enables trusted data transactions between par-
ticipants” (European Committee for Standardization,
2024). The goal of data spaces is to facilitate the
controlled sharing and cooperative use of data be-
tween different organizations, irrespective of the data
types involved, while ensuring data providers retain
sovereignty over their assets (Otto, 2022). Techni-
cal implementations often follow architectures like
the International Data Spaces Reference Architecture
Model (IDSA RAM) (Otto et al., 2019), which out-
lines components and layers for secure data shar-
ing. Consequently, data spaces empower organiza-
tions and individuals to gain deeper insights from
their data, thereby improving decision-making pro-
cesses and fostering innovation (Bacco et al., 2024).
2.3 The Interplay of Data Trustees and
Data Spaces
Data trustees and data spaces are complementary con-
cepts (Steinert and Altendeitering, 2024). In addition,
the broader category of data intermediaries, which in-
cludes data trustees, is also seen as part of the role
model of data spaces (Gemein et al., 2023). Data
trustees provide the organizational, legal, and trust-
building framework necessary to govern sovereign
data sharing according to agreed rules and policies.
Conversely, data spaces provide the technical infras-
tructure required for secure, efficient, and sovereign
data management and sharing. The data trustee es-
tablishes the governance and trust layer by defining
the rules of engagement (often codified in ODRL
policies), while the data space provides the technical
means to enforce these rules, manage data flows, and
facilitate secure interaction. This interplay ensures
that data can be protected effectively while being uti-
lized purposefully, benefiting all participants and con-
tributing to an innovative and competitive data econ-
omy. Our work enhances this interplay by introducing
EoL data management within data trustees that oper-
ate within or interact with data spaces.
2.4 End-of-Life Data Management
Data deletion, the deliberate and often irreversible ac-
tion of removing or obliterating information, consti-
tutes the final stage of the data lifecycle (Tebernum
and Howar, 2023) (also referred to as EoL data man-
agement). It transcends the simplicity implied by
a delete’ command, representing a necessary pro-
cess driven by multifaceted requirements and con-
veying significant implicit meaning. Despite its in-
creasing importance, research indicates this area re-
mains under-addressed compared to other lifecycle
stages (Tebernum et al., 2021, 2023). Understand-
ing the depth of data deletion is paramount, particu-
larly within trust-based ecosystems facilitated by data
trustees.
Controlled data deletion ensures compliance with
legal and regulatory requirements, such as the
GDPR’s “right to be forgotten” (European Commis-
sion, 2016), mitigating significant legal and financial
risks. It also improves security by reducing the attack
surface; removing redundant or sensitive data mini-
mizes the potential damage from breaches. Moreover,
it maintains data quality (Wang and Strong, 1996) and
utility, ensuring that decisions are based on current,
relevant, and accurate information, which is impor-
tant, for example, when needing to remove specific
data points from trained models (Ginart et al., 2019).
Furthermore, it optimizes resource utilization, reduc-
ing storage costs and potentially improving system
performance, aligning with principles of efficient re-
source management and Green IT (Van Bussel and
Smit, 2014). Finally, ethical considerations, organi-
zational policies, or evolving risk assessments may
require data removal.
Enhancing Data Governance in Data Trustees Through ODRL-Based End-of-Life Policies
29
Given its destructive and irreversible nature, data
deletion demands a systematic and precise approach.
A simple instruction to delete is often insufficient.
Effective deletion requires detailed specifications, in-
cluding: precise identification of the target data (e.g.,
specific records, files identified by hashes, data within
certain systems); explicit documentation of the ratio-
nale for deletion (e.g., compliance, user request, qual-
ity issue); definition of preconditions (e.g., temporal
constraints, geographical location, completion of re-
lated processes); specification of the deletion method
(e.g., logical deletion, cryptographic wiping, physi-
cal destruction); assignment of responsibility; and im-
plementation of safeguards (e.g., simulations, explicit
approvals) to prevent errors.
Crucially, the action of deletion, particularly when
formally specified and recorded, carries inherent
meaning beyond the mere absence of data. The doc-
umented specification itself becomes valuable meta-
data. The stated rationale reveals the intent behind
the deletion (compliance, risk reduction, etc.). The
decision to delete implies a value assessment - the
data is no longer deemed necessary, useful, or its re-
tention poses unacceptable risk according to defined
policies. Specified conditions provide context about
operational workflows or regulatory constraints. The
chosen deletion method reflects the perceived sen-
sitivity of the data and the required level of assur-
ance. Furthermore, the existence of a structured, doc-
umented deletion process signifies the organization’s
governance maturity (Tallon et al., 2013) and com-
mitment to the responsibilities of data trustees, pro-
viding an auditable trail that is important for account-
ability.
However, standard policy languages like ODRL,
with basic actions such as odrl:delete, lack the seman-
tic depth required for comprehensive EoL data man-
agement. This gap in expressiveness, particularly in
defining the rich context of deletion for traceable and
auditable processes, motivates the ODRL extension
detailed in this work.
3 PROPOSED ODRL EXTENSION
FOR EOL POLICIES
Building upon the analysis of data trustee needs (Sec-
tion 2) and the identified semantic limitations of stan-
dard ODRL for EoL management (Section 2.4), this
section details our ODRL extension. Our goal is to
create a semantically rich and machine-interpretable
vocabulary that enables the precise specification, au-
tomated processing, and auditing of data deletion
policies by data trustees, particularly within data
spaces.
This ODRL extension addresses RQ1: What spe-
cific requirements must an EoL policy vocabulary
fulfill to enable EoL data management by data
trustees, particularly within data spaces? by fulfill-
ing the specific requirements derived from our anal-
ysis. It then answers RQ2: How can the ODRL
standard be extended with a semantically rich vo-
cabulary to meet these EoL requirements and fa-
cilitate machine-interpretable specification of dele-
tion policies? through the proposed eol: vocabulary
and its mechanisms. Specifically, the ODRL exten-
sion is designed to fulfill the following requirements:
REQ1: Semantic Richness for Rationale: Ex-
plicitly capture the reason for the EoL action (e.g.,
GDPR request, contract end, data quality).
REQ2: Specification of Deletion Method: Al-
low specification of the required deletion method
(e.g., logical delete, wipe, physical destruction).
REQ3: Granular Data Identification: Enable
precise identification of data assets, potentially
beyond URIs (e.g., via hashes, record IDs).
REQ4: Clear Temporal and Spatial Specifica-
tion: Support unambiguous temporal and spatial
constraints for deletion actions.
REQ5: Machine Interpretability and Automa-
tion: Be defined formally (e.g., RDF) for unam-
biguous machine interpretation and automation.
REQ6: Support for Traceability and Auditing:
Ensure traceability and auditability of EoL actions
(e.g., via logs or confirmations) to enable confir-
mation processes.
REQ7: Compatibility and Extensibility within
ODRL: Integrate seamlessly with ODRL and fol-
low its design principles as a modular extension.
REQ8: Contextual Applicability for Data
Trustees: Be suitable for multi-party scenarios
managed by data trustees within data spaces.
REQ9: Operational Policy Management Fea-
tures: Incorporate attributes for practical policy
management at the rule level, allowing for control
over execution behavior.
To meet these requirements, we propose defining
this ODRL extension using RDF, introducing a new
vocabulary under the namespace eol:.
3.1 The eol: Vocabulary Extension
The eol: vocabulary complements standard ODRL by
adding specific classes and properties tailored for EoL
data management, addressing the requirements out-
lined above.
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3.1.1 Rule-Level Operational Attributes
(Addressing REQ9)
To provide operational control over individual rules
within a policy, we introduce several properties ap-
plicable directly to instances of odrl:Rule (such as an
odrl:obligation or odrl:permission):
eol:simulated (xsd:boolean): Indicates if the rule
execution should only be simulated (e.g., for test-
ing or impact analysis) rather than enacted.
eol:notification (xsd:boolean): Specifies if the as-
signee should receive a notification before the data
associated with the rule is deleted.
eol:optIn (xsd:boolean): Indicates whether the
deletion of data as per the rule must be explicitly
accepted (opted-in) by the assignee, rather than
being processed automatically.
eol:strict (xsd:boolean): Mandates that rule ex-
ecution should only proceed automatically if the
processing system understands all classes, prop-
erties, and values within the rule. This prevents
unintended actions due to partial interpretation.
3.1.2 Specifying WHAT to Delete: The
eol:Locator (Addressing REQ3)
Standard ODRL uses odrl:target to identify the as-
set. However, EoL actions often require more gran-
ular identification, especially for distributed data or
specific data fragments. We introduce:
eol:Locator (Class): Represents a detailed de-
scription of an asset’s location or identity beyond
a simple URI. Instances of eol:Locator can have
various specific properties to accommodate differ-
ent types of location or identification information
(e.g., content hashes, file paths, persistent identi-
fiers, database UIDs, URLs).
eol:hasLocator (Property): Links an odrl:Asset
(and therefore also an odrl:AssetCollection, as
it is a subclass) to one or more eol:Locator in-
stances. Its domain is explicitly set to odrl:Asset,
allowing locators for both individual assets and
collections.
eol:locatorSHA256Hash (Property): This prop-
erty serves as one example of how an asset can be
identified within an eol:Locator instance, specifi-
cally using its SHA256 content hash (xsd:string).
Other properties could be defined for different
identification schemes.
This allows policies to precisely target specific
data instances or collections for deletion, even if indi-
vidual items lack persistent URIs, using precise iden-
tifiers like content hashes or other suitable locator
properties.
3.1.3 Specifying WHY: The eol:Reason
(Addressing REQ1)
Understanding the rationale behind a deletion require-
ment is important for compliance, auditing, and ap-
propriate handling (e.g., notifying stakeholders). We
introduce:
eol:Reason (Class): Represents the justification
for the policy, rule, or action. Instances of
this class would typically be URIs representing
concepts like eol:reason:LegalObligation,
eol:reason:UserConsentWithdrawal,
eol:reason:DataQualityIssue, etc.
eol:hasReason (Property): Links an odrl:Rule
(or an odrl:Action within it) to an instance of
eol:Reason, providing machine-interpretable con-
text.
3.1.4 Specifying HOW: eol:destructionMethod
and Refinements (Addressing REQ2)
The core odrl:delete action lacks specificity regard-
ing the deletion method. We leverage ODRLs
odrl:refinement mechanism within a odrl:Constraint
attached to the rule governing the odrl:delete action.
We introduce:
eol:destructionMethod (LeftOperand): Defined
as an odrl:LeftOperand, this represents the con-
cept of the required method or level of destruc-
tion. It is used as the odrl:leftOperand in a re-
finement constraint associated with an action (like
odrl:delete).
Specific Destruction Method Identifiers (Right-
Operands): The required method is specified us-
ing an IRI as the odrl:rightOperand in the re-
finement constraint (typically with odrl:operator
odrl:eq). These IRIs can represent:
Abstract destruction levels, such as
eol:method:Recycled (implying data might
be restorable), eol:method:Deleted (standard
logical deletion), eol:method:Wiped (data is
overwritten and not practically restorable), or
eol:method:PhysicallyDestroyed (the storage
medium itself is destroyed). These abstract
levels of recoverability are inspired by Cantrell
and Runs Through (2019).
Concrete algorithms or techniques, for exam-
ple, an IRI representing a specific wiping al-
gorithm (e.g., a Gutmann method variant) or a
destruction level from standards such as NIST
SP 800-88, ISO/IEC 27040 or DIN 66399.
Enhancing Data Governance in Data Trustees Through ODRL-Based End-of-Life Policies
31
While the specific eol: vocabulary elements
detailed above directly address REQ1 (Rationale),
REQ2 (Method), REQ3 (Identification), and REQ9
(Operational Attributes), the overall design, based
on RDF and ODRLs extensibility, inherently sup-
ports other requirements. Standard ODRL temporal
(odrl:dateTime) and spatial (odrl:spatial) constraints
are leveraged to meet REQ4 (Temporal and Spa-
tial Specification). The use of RDF ensures REQ5
(Machine Interpretability), which, combined with the
explicit semantics, provides a foundation for REQ6
(Traceability and Auditing). Compatibility (REQ7) is
maintained by adhering to ODRL patterns. How these
elements integrate to support data trustee operations
in multi-party contexts (REQ8) is further detailed in
Section 3.3.
3.2 Illustrative Example EoL Policy
Listing 1 demonstrates how these extensions inte-
grate within an ODRL policy, reflecting the struc-
ture from our formal definition (provided in the Ap-
pendix of this paper) and incorporating terms shown
in the following JSON-LD structure. The policy ref-
erences an ODRL profile (via the odrl:profile), which
defines or imports the eol: vocabulary terms and
their usage. This ensures that all parties understand
the semantics of the EoL extension used. It shows
an odrl:Agreement where a data trustee assigns an
obligation to a data consumer. The obligation rule
within the policy specifies that its execution will not
be simulated (eol:simulated is false), requires strict
interpretation (eol:strict is true), mandates assignee
opt-in for deletion (eol:optIn is true, meaning it is
not fully automated without acceptance), and trig-
gers a notification to the assignee (eol:notification
is true). The obligation is to delete (odrl:delete)
an asset (odrl:Asset, which uses eol:hasLocator to
refer to a eol:locatorSHA256Hash, triggered by
user consent withdrawal (eol:hasReason pointing
to eol:reason:UserConsentWithdrawal). This obli-
gation is constrained temporally, active from Jan-
uary 1, 2025, and expiring by December 31, 2026,
and spatially limited to the EU (via an odrl:spatial
isA constraint). Furthermore, the deletion action
is refined to require a specific destruction method
(eol:destructionMethod equal to a URI representing
the Gutmann method).
3.3 Integration Within Data Trustees
This extended ODRL vocabulary integrates into the
operational workflows of data trustees, potentially
within data spaces. While this section outlines how
this integration would function, its concrete imple-
mentation and empirical validation are planned for fu-
ture work. Data trustees use these policies in data con-
tracts to specify EoL duties. Technical components
(e.g., a data space connector enhanced with policy
enforcement capabilities) can parse and act on these
machine-interpretable policies (REQ5). The explicit
semantics, such as eol:hasReason and the specific
eol:destructionMethod, along with rule-level opera-
tional attributes like eol:simulated or eol:notification,
guide implementation (e.g., triggering specific dele-
tion scripts or workflows) and facilitate targeted no-
tifications or compliance checks (REQ9). Crucially,
this structure enables automated logging and auditing
based on policy terms (e.g., recording when a policy
with a specific reason and method was executed), en-
hancing traceability and auditing (REQ6). This ap-
proach aligns with ODRL principles (REQ7) and di-
rectly supports the data trustee’s governance role in
managing multi-party data lifecycles (REQ8).
In summary, this proposed ODRL extension, char-
acterized by the eol: vocabulary and driven by the
identified requirements, provides a concrete mech-
anism to facilitate expressive, machine-interpretable
EoL policies, thereby strengthening data governance
for data trustees.
4 EVALUATION
To assess the feasibility and appropriateness of the
proposed ODRL extension for EoL policies, and to
validate the underlying requirements, a qualitative
evaluation study was conducted. Nine experts par-
ticipated in semi-structured interviews. These experts
were selected to represent a diverse range of relevant
domains: one data scientist, two mobility and smart
city experts, one manufacturing expert, one cloud in-
frastructure expert, and four data space experts. Cru-
cially, all participants had knowledge of and practical
experience with data governance and policy manage-
ment, as well as expertise with ODRL. The interviews
were guided by a framework covering six evalua-
tion criteria: Relevance & Completeness of Require-
ments (addressing RQ1), Suitability of the Solution
Approach, Semantic Clarity & Expressiveness, Tech-
nical Feasibility & Integration, and Potential Impact
& Usefulness (all addressing RQ2). Interview tran-
scripts were analyzed using qualitative content anal-
ysis to identify recurring themes, patterns, and criti-
cal insights regarding the proposed ODRL extension,
following established procedures for deductive con-
tent analysis and systematic qualitative analysis of
text data (McKibben et al., 2022; Puppis, 2019).
WEBIST 2025 - 21st International Conference on Web Information Systems and Technologies
32
{
// Cont ext de fin i t io n s omi t te d to save s pa ce
" @t yp e ": " Ag re e men t ",
" u id ": " urn : pol i cy: e xam p le0 1 - delete - ob li g a ti o n ",
// Prof ile w ou ld def i ne or im po rt t he eol : v o ca b u la r y t er ms an d their us ag e
" od rl : p r of i l e ": { " @i d ": " htt p: // e x am ple . c om / od rl / pro fi l e / data - t ru ste e " } ,
" dc t :de s c r ipt i o n ": { " @v al ue ": " De le te use r da ta ( co n se n t w ith d raw a l )" } ,
" dct: i ssu e d ": "20 25 -01 -01" ,
// R EQ 7: Co m p a ti b i l it y / REQ5: In t erp r e t a bil i t y / RE Q6 : A ud i ti n g
" obli g ati o n ": [{
" @ id ": " urn : pol i cy: e xam p le0 1 - delete - ob li g a ti o n # obli g ati o n ",
// R EQ 1: WHY - S e man t ic Ri ch n ess for Rat i on a l e
"eol:hasReason" : { " @id ": " e o l :Us e r C o n s e n t Wit h d r a w a l " } ,
// R EQ 9: Op e r at i o na l Poli cy Ma nag e men t Fe at u re s
"eol:simulated" : false ,
"eol:notification" : tr ue ,
"eol:optIn" : tr ue ,
"eol:strict" : tr ue ,
// R EQ 8: Co n te x t ua l Ap p l ica b i l it y ( Da ta T rus tee Con t ex t )
" ass i gn e r ": " ur n : p ar t y : t r ust e e " ,
" ass i gn e e ": " ur n : p art y : c o n sum e r " ,
" tar ge t ": {
" @t yp e ": " Asset ",
" @ id ": " u r n: a s s e t :us e r X Y Z ",
" dct : t it l e ": " Us er XYZ Data Se t ",
"eol:hasLocator" : {
" @t yp e ": "eol:Locator" ,
// Loca tor ca n use va r io us p rop e rti e s ; thi s is one e xam pl e
"eol:locatorSHA256Hash" : " db2 d c5 .. ."
}
},
" act io n ": {
" @ id ": " odr l : de l e te ",
" refi n eme n t ": [{
// R EQ 2: HOW - Re fin e men t sp ec i f yin g th e De l et i on Me th od
" le ft O p era n d ": "eol:destructionMethod" ,
" ope r at o r ": " odr l :e q ",
" ri gh t O p er a n d ": " htt p: // exa mpl e . com / odrl - eo l / me t ho d / gu tma nn - met h od "
}]
}
// R EQ 4: W HE N & W HE RE - C o ns t r ain t s on t he Ob li ga ti on s a pp l i c abi l i t y
" cons t rai n t ": [
{
" le ft O p era n d ": " od r l :d a t e Ti m e " ,
" ope r at o r ": " od rl : gte q ",
" ri gh t O p er a n d ": "20 25 - 01 -01"
},
{
" le ft O p era n d ": " od r l:s p a tia l " ,
" ope r at o r ": " odrl :is A ",
" ri gh t O p er a n d ": " ur n : l oc a t i o n:E U "
},
{
" le ft O p era n d ": " od r l :d a t e Ti m e " ,
" ope r at o r ": " od rl : lte q ",
" ri gh t O p er a n d ": "20 26 - 12 -31" ,
" sko s : no t e ": " Ru le E x p ir a t ion D at e "
}
]
}]
}
Listing 1: Example ODRL Policy with EoL Extensions in JSON-LD.
Enhancing Data Governance in Data Trustees Through ODRL-Based End-of-Life Policies
33
4.1 Relevance & Completeness of
Requirements (RQ1)
There was a strong consensus among the experts re-
garding the relevance of addressing EoL data man-
agement with more granularity than standard ODRL
provides. The identified set of nine requirements
(REQ1-REQ9) was generally perceived as compre-
hensive and well-founded for specifying EoL policies
in the context of data trustees.
Semantic Aspects (REQ1, REQ2, REQ3): The
need to specify the rationale (REQ1) for deletion was
acknowledged for context and auditability, although
some experts questioned its direct technical necessity
for policy execution engines. Specifying the dele-
tion method (REQ2) was deemed crucial for compli-
ance and operational clarity, prompting discussions
on the technical capabilities required by the execut-
ing party. The requirement for granular data iden-
tification (REQ3) beyond simple URIs, potentially
using hashes or internal identifiers via the proposed
eol:Locator, was strongly supported as a necessary
enhancement, although challenges regarding consis-
tency of identifiers across systems were noted.
Contextual & Technical Aspects (REQ4,
REQ5, REQ6, REQ7): Leveraging standard ODRL
for temporal and spatial constraints (REQ4) was
considered pragmatic. The fundamental need for
machine interpretability (REQ5) through a formal
RDF structure was undisputed. Supporting traceabil-
ity and auditing (REQ6) was recognized as a critical
goal, though experts highlighted the practical limi-
tations and dependency on the logging mechanisms
and trustworthiness of the executing environment.
Ensuring compatibility with ODRL (REQ7) by using
an extension vocabulary was seen as the correct
approach.
Operational & Ecosystem Aspects (REQ8,
REQ9): The suitability for multi-party scenarios typ-
ical for data trustees (REQ8) was confirmed by the
inherent structure of ODRL for defining roles (assign-
er/assignee). The operational policy management fea-
tures (REQ9), such as those for simulation, notifica-
tion, opt-in, and strict interpretation at the rule level,
were particularly well received and considered highly
valuable for practical policy deployment and control.
Discussions arose regarding the optimal placement of
these attributes (policy vs. rule level) depending on
the desired scope (e.g., EoL as part of a larger usage
policy).
Potential Gaps Identified: A recurring theme
was the challenge of addressing the EoL of derived
data products (e.g., aggregated datasets, trained AI
models), which was considered important but poten-
tially beyond the scope of this initial vocabulary. The
need for explicit notification or confirmation mecha-
nisms upon successful deletion was also suggested by
some participants, a point partially addressed by the
eol:notification flag. Furthermore, a clearer definition
of responsibilities for policy enforcement and verifi-
cation within the ecosystem was deemed necessary.
4.2 Evaluation of the ODRL Extension
(RQ2)
Suitability of Approach: Extending ODRL was
broadly accepted as a suitable and pragmatic ap-
proach, given ODRLs prevalence in data spaces and
related initiatives. Its flexibility was seen as an ad-
vantage, while its known complexity and lack of stan-
dardized tooling were acknowledged as general chal-
lenges. The proposed eol: vocabulary was found to be
logically structured and consistent with the identified
requirements.
Semantic Clarity & Expressiveness: The vocab-
ulary was perceived as clear and understandable, par-
ticularly when presented with the policy examples.
Experts confirmed its ability to effectively express the
EoL nuances (reason, method, granular target, oper-
ational controls), representing a significant improve-
ment over standard ODRL for this purpose. The lim-
itation regarding derived data was reiterated here.
Technical Feasibility & Integration: While the
vocabulary and its ODRL integration were considered
sound, experts identified several practical implemen-
tation challenges. These primarily centered on the
need to develop specific policy engine logic to in-
terpret and act upon the eol: terms, the mapping of
eol:Locator information to diverse target systems, en-
suring target systems support the specified deletion
methods, and potential limitations in existing APIs
(e.g., for custom attributes). However, the overarch-
ing challenge of policy enforcement - ensuring that
the specified actions are actually carried out reliably
and verifiably in the target environment - was empha-
sized by almost all participants as a hurdle, indepen-
dent of the policy language itself.
Potential Impact & Usefulness: The experts
saw potential value in the proposed ODRL exten-
sion. Benefits highlighted included enhanced com-
pliance support, improved data quality management,
increased transparency in data handling, and foster-
ing trust within data ecosystems, particularly for the
governance role of data trustees. While the potential
to improve current EoL practices was acknowledged,
concerns about widespread, rapid adoption were also
expressed, citing the general inertia of detailed policy
implementation and the reliance on perceived need
WEBIST 2025 - 21st International Conference on Web Information Systems and Technologies
34
and regulatory pressure.
General Acceptance & Suggestions: Overall
feedback was positive, confirming the need and
general direction of the proposed ODRL extension.
Strengths were seen in the semantic richness and op-
erational control features. The main perceived weak-
ness is the reliance on effective enforcement mecha-
nisms. Suggestions for improvement included con-
sidering more flexible placement of operational at-
tributes and possibly including notification mecha-
nisms. The critical role of clear governance frame-
works defining EoL standards and responsibilities
within data ecosystems was repeatedly emphasized.
4.3 Evaluation Summary
The expert interviews broadly confirmed the identi-
fied requirements for enhanced EoL data management
(RQ1) and confirmed the suitability of the proposed
ODRL extension (RQ2) to address these needs. The
eol: vocabulary was found to be semantically ex-
pressive for EoL concepts and operationally valuable.
However, the evaluation emphasized that the success
of such a policy framework depends on addressing
the persistent challenge of policy enforcement and es-
tablishing clear governance structures within the tar-
get data ecosystems. While the proposed eol: vo-
cabulary provides the necessary means to specify de-
tailed EoL policies, ensuring their implementation re-
quires complementary technical and organizational
measures. The results provide valuable input for re-
fining the vocabulary and underscore the importance
of integrating policy definition with robust enforce-
ment and governance strategies in future work.
5 DISCUSSION
The introduction of the eol: vocabulary as an ODRL
extension for EoL data management by data trustees
presents several practical and theoretical implications.
This section discusses these implications, the bene-
fits, and limitations of the proposed approach, and its
broader significance for data governance, building on
the validation from our expert evaluation (Section 4).
Practical Implications: Leveraging ODRL for
EoL Management. A design choice was to ex-
tend ODRL rather than proposing a new policy lan-
guage. This decision carries practical advantages.
Data trustees and participants in data spaces are fa-
miliar with ODRL for defining access and usage poli-
cies (Dam et al., 2023; Eitel et al., 2021). Integrat-
ing EoL specifications into ODRL avoids the over-
head of developing, learning, implementing, and exe-
cuting a separate language and its associated tooling.
Systems already capable of parsing and interpreting
ODRL (e.g., data space connectors) can potentially
be adapted to handle the eol: extension, lowering the
barrier to adoption. This pragmatic approach directly
supports REQ7 (ODRL Compatibility) and enhances
the likelihood of practical implementation within ex-
isting data governance frameworks. While conceptual
integration into the ODRL model is straightforward,
practical implementation of interpretation engines re-
quires more work. Here, it is necessary that, over
time, practical experience feeds back into research to
identify the most important aspects, so that robust in-
terpretation engines can be developed on this basis.
Towards Holistic Data Lifecycle Governance
with ODRL. ODRL focuses on the phases of data ac-
cess and usage. Our extension incorporates the final
phase of the data lifecycle. By enabling the specifica-
tion of why data should be deleted (eol:Reason), how
it should be deleted (eol:destructionMethod), and pre-
cisely what data is targeted (eol:Locator), ODRL be-
comes a more comprehensive language for govern-
ing data throughout its entire lifecycle. This aligns
with the need for holistic data lifecycle management
(Tebernum and Howar, 2023) and moves ODRL to-
wards being a language capable of expressing poli-
cies that span from data creation and sharing through
to its eventual, traceable deletion. While inspired
by concepts seen in frameworks like DestroyClaims
3
,
our integration within the ODRL standard facilitates
broader interoperability and standardization potential.
Theoretical Implications: Formalizing EoL as
Policy. Beyond the practical benefits, our work
demonstrates the theoretical feasibility and utility
of modeling EoL actions declaratively as machine-
interpretable policies. Traditionally, data deletion
might be handled through procedural scripts, man-
ual processes, or implicit understandings. Formaliz-
ing EoL duties within ODRL elevates these actions to
the level of explicit governance rules that are suitable
for automated reasoning, traceability, and auditing.
The ability to capture the meaning behind deletion
(as discussed in Section 2.4) via properties such as
eol:Reason adds semantic depth, transforming a sim-
ple delete command into a rich, context-aware gov-
ernance instruction. This formalization is important
for building trustworthy data trustees, where trans-
parency and accountability are paramount.
Addressing the Need for a Uniform EoL Vocab-
ulary and Standardization. The lack of a standard-
ized vocabulary for EoL actions represents a signif-
icant barrier to reliable and verifiable data deletion
across organizational boundaries, as highlighted in
3
https://github.com/DaTebe/destroyclaims
Enhancing Data Governance in Data Trustees Through ODRL-Based End-of-Life Policies
35
our problem statement. Ambiguity regarding deletion
requirements hinders automated enforcement, partic-
ularly when obligating data consumers to perform
deletion, and complicates compliance auditing. Our
work tackles this by systematically identifying the
necessary semantic components (REQ1-REQ9) and
proposing a concrete vocabulary (eol:) integrated
within ODRL. While proposing a full W3C standard
is beyond the scope of this initial work, the definition
and validation of these requirements, coupled with the
demonstration of their feasibility using ODRL exten-
sions, represent a novel and necessary contribution. It
lays the crucial groundwork for future standardization
efforts, providing a candidate vocabulary that aims to
foster a common understanding and improve trust and
compliance regarding EoL duties in data spaces.
Facilitating Enforceability and Auditing. A per-
sistent challenge in data sharing is ensuring that data
consumers adhere to usage policies, including dele-
tion duties. While our ODRL extension cannot guar-
antee technical enforcement on a consumer’s system
(which remains dependent on their implementation
and willingness to comply), it facilitates enforceabil-
ity and auditability. The machine-interpretable nature
(REQ5) allows consumer systems to automatically
recognize and process deletion duties. Explicit re-
quirements for deletion methods (REQ2) and reasons
(REQ1) clarify expectations. Crucially, the structured
policy enables better auditing (REQ6). Data trustees
can log the issuance of EoL policies, and mechanisms
could be envisioned (potentially linked to data space
components like clearing houses) to track acknowl-
edgments or require confirmations of deletion from
consumers, based on the policy rules. This provides a
verifiable trail, enhancing accountability even if direct
technical enforcement is limited.
Supporting Legal Compliance and Risk
Management. The proposed ODRL extension
ensures compliance with various legal and regulatory
frameworks, including the GDPR and CCPA. The
ability to specify the legal basis for deletion (e.g.,
eol:UserConsentWithdrawal, eol:LegalObligation)
and the required deletion standard aligns with data
protection principles. Furthermore, the rule-level
operational attributes introduce risk management
features. eol:simulated allows for impact analysis be-
fore actual deletion, mitigating the risk of accidental
data loss. eol:strict prevents automated execution if
the policy semantics are not fully understood by the
processing system, reducing the chance of incorrect
actions. eol:optIn ensures assignee consent for
deletion when required, and eol:notification provides
transparency. However, it is important to recognize
that while these features help manage risk, they do
not eliminate operational risk entirely; robust backup
and recovery strategies, along with careful policy
authoring and review processes, remain essential.
Limitations and Future Directions. Despite the
positive feedback on our evaluation, we acknowledge
the limitations of our approach. First, the challenge of
technical enforcement on consumer systems remains.
While our ODRL extension improves the clarity and
auditability of the deletion duty, verifiable deletion
still relies on consumer cooperation and additional
technical mechanisms. Second, handling cases across
multiple jurisdictions presents governance challenges
that the eol: vocabulary cannot solve alone. Third,
extending ODRL is pragmatic but adds complexity to
the standard. This requires careful consideration of
tooling support and potential interactions with other
ODRL profiles. Fourth, the eol: vocabulary may
require refinement to address more complex scenar-
ios, such as intricate data dependencies, the need for
specific proof-of-deletion artifacts, and partial data
anonymization as an alternative to deletion. Finally,
the success of our ODRL extension depends on com-
munity adoption and integration into data spaces. Fur-
ther dissemination, the development of best practices,
and pilot implementations are necessary next steps.
6 CONCLUSION
This work addressed the gap in EoL data manage-
ment within data trustee operations, particularly in
the context of data spaces, by answering our research
questions concerning the requirements for (RQ1) and
the implementation of (RQ2) an expressive EoL pol-
icy vocabulary. Our proposed solution extends the
ODRL standard with an eol: vocabulary, enabling the
machine-interpretable specification of deletion poli-
cies. The qualitative evaluation via an expert work-
shop (Section 4) provided initial validation, indicat-
ing that the identified requirements are relevant and
the proposed ODRL extension is perceived as a con-
ceptually sound, technically feasible, and potentially
impactful approach.
Building on this, we have shown that effective
EoL data management is essential for data trustees,
yet current policy languages such as ODRL lack
the semantic depth to specify detailed, machine-
interpretable EoL policies. This paper tackled this
issue by first identifying the requirements for an
EoL policy vocabulary (RQ1), covering the why (ra-
tionale), how (method), what (data identification),
when/where (context), and operational aspects of EoL
policies. We then proposed the eol: vocabulary,
an ODRL extension designed to meet these require-
WEBIST 2025 - 21st International Conference on Web Information Systems and Technologies
36
ments, thereby enabling the machine-interpretable
specification of EoL policies (RQ2). Our qualita-
tive evaluation with experts validated the relevance of
these requirements and the conceptual soundness of
the ODRL extension, underscoring its potential to en-
hance compliance, trust, and overall data governance.
The primary contribution, therefore, is the for-
malization of EoL policy requirements tailored for
data trustees and a practical vocabulary to imple-
ment them. This approach facilitates more holis-
tic data lifecycle governance by rendering EoL poli-
cies explicit, machine-interpretable, and auditable.
While this work improves policy specification, en-
suring technical enforcement in distributed systems
and establishing robust ecosystem governance remain
challenges. Future work should focus on refining the
eol: vocabulary for data deletion, exploring mecha-
nisms for verifiable EoL execution, and developing
best practices for its integration within data spaces.
As another part of EoL data management involves
not only data deletion but also data retention, future
work could also include the development of a com-
plementary ODRL extension to specify retention poli-
cies. By promoting standardized, expressive policies
for the full scope of EoL data management, encom-
passing both deletion and retention, we aim to further
strengthen data governance and trust in data trustees.
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APPENDIX
@pr ef i x odrl: <www . w3 . or g /ns / o drl /2 / > .
@pr ef i x eo l : < www . ex a m p le . com / odr l - e ol #> .
@pr ef i x rd f : < www . w3 . org / 1 9 9 9 / 02 /2 2 -r df - sy nt
a x- n s #> .
@pr ef i x rdfs: <www . w3 . or g / 2 00 0/ 0 1 / r df -s c h e m a
#> .
@pr ef i x skos: <www . w3 . or g / 2 00 4/ 0 2 / s k o s / cor e #
> .
@pr ef i x ow l : < www . w3 . org / 2 00 2/ 0 7/ owl # > .
@pr ef i x xs d : < www . w3 . org /2 0 01 / X ML S ch em a# > .
@pr ef i x dc t : <p url . o r g /dc / te r ms / > .
# P o l i c y - L ev el A tt r i b ut es ( RE Q9 )
eo l :s im u l a te d a rdf : P r o p e r t y , owl : D a t a
ty pe Pr o p e r t y , s k o s : C o n c ep t ;
rdf s :l a b e l " Si mul at e d " @ e n ;
sk os :d ef in it i o n " Ru l e e x e c ut io n is simu l
a ted if tr u e . " @en ;
rd f s: d om a in odr l: R u l e ;
rdf s :r a n g e xs d: b oo le an .
eo l : n o t if ic a tion a rdf :P r o p e r t y , owl : D a t a
ty pe Pr op e r t y , s k o s : C o n c e p t ;
rdf s :l a b e l " Noti fic a tion " @e n ;
sk os :d ef in it i o n " Ass i gn ee is not i fi e d
bef o re d a t a de l e ti o n if t r ue . " @ e n ;
rd f s: d om a in odr l: R u l e ;
rdf s :r a n g e xs d: b oo le an .
eo l :o pt I n a rdf : P r o p e r t y , owl : D a t a
ty pe Pr op e r t y , s k o s : C o n c e p t ;
rdf s :l a b e l " Op t- I n Req ui r ed " @ e n ;
sk os :d ef in it i o n " Ass i gn ee must
ex p l i ci tl y o pt- i n for de l et io n if
true . " @en ;
rd f s: d om a in odr l: R u l e ;
rdf s :r a n g e xs d: b oo le an .
eo l : s tr ic t a rd f: Pr op er ty , owl: D at a
ty pe Pr op e r t y , s k o s : C o n c e p t ;
rdf s :l a b e l " St ri c t " @en ;
sk os :d ef in it i o n " Au tom a t e d ex ec u ti on
only if a ll t erm s a re k nown ." @en ;
rd f s: d om a in odr l: R u l e ;
rdf s :r a n g e xs d: b oo le an .
# WHA T : Gr a nul a r D a t a Ide n t i fi c a ti o n ( R E Q 3 )
eol :L o c a tor a r dfs :C l a ss, o wl : Cl ass,
sk o s : C o n c e p t ;
rdf s :l a b e l " Loc a tor " @en ;
sk os :d ef in it i o n " Rep re s e n ts a det a i l ed d
at a a ss et l o c a t o r ." @en ;
sk o s: no t e " Des c r i be s a sset lo c a tio n s . "
@en .
eol: h a sLoc a t o r a rdf :P ro pe rt y,
ow l: Ob j e c t P ro pe rt y ;
rdf s :l a b e l " h a sL o c a t o r " @ e n ;
sk os :d ef in it i o n " Li nks a n As s et to its
Loc a t o r ." @en ;
rd f s: d om a in od r l: As s e t ;
rdf s :r a n g e eo l :L o c a tor .
# Ex a mp l e loc a t o r pr op e rt y
eol :l o c a to r SH A2 5 6 H a sh a r d f : P r o p e r t y , o w l:D a
ta ty p e P r o p e rt y , s ko s: Co nc ep t ;
rdf s :l a b e l " SH A2 5 6 H a sh Loc a tor " @en ;
sk os :d ef in it i o n " SH A2 5 6 con t en t ha sh of
the A sse t ." @en ;
rd f s: d om a in eol : Lo c a tor ;
rdf s :r a n g e xs d: st r i n g .
# WHY: R a t i on a le ( R E Q1 )
eol : Re a s o n a r df s :C l a ss, owl: C l a ss,
sk o s : C o n c e p t ;
rdf s :l a b e l " Re a son " @en ;
sk os :d ef in it i o n " Jus t if ic a t ion for a
Pol ic y , Rule, or Acti o n . " @ e n ;
sk o s: no t e " Pro v id e s co n te xt , e. g . , for
in f or mi n g a DPO . " @en .
eol: h a sRe a s o n a rdf :P ro pe rt y,
ow l: O b j e c tP ro p e r t y , sk os : C o n c e p t ;
rdf s :l a b e l " h a sRe a son " @en ;
sk os :d ef in it i o n " Li nks a P ol i cy , R u le,
or Act i on to i t s re a son . " @ e n ;
rd f s: d om a in odr l: R u l e ;
rdf s :r a n g e eol :Re a s o n .
# HOW: De l et i on Me tho d ( REQ2 )
eo l: d e s t r uc t i o n M et ho d a rdf :P ro pe rt y,
od rl :L ef t O p e r a nd, sk o s : C o n c ep t ;
rd fs :i sD e f i n e d B y e o l : ;
rdf s :l a b e l " Des tr uc t i o n Me t hod " @ e n ;
sk os :d ef in it i o n " Spe c i f ie s d at a d el e ti on
met h od or des tr uc t i o n lev e l . " @en ;
sk o s: no t e " E .g . , r e cycle d , delete d ,
w iped , p h ysi c a lly de stro y e d , a n
a l go r it hm like Gutm a nn meth o d . " @ e n .
Listing 2: Formal Definition of the EoL ODRL Extension
Vocabulary in RDF/Turtle.
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