uses the data collected which can identify the subjects for display in its search engine function. From that angle but for the fact of the Ordinance not applicable to Google LLC by reason of the jurisdictional issue, Google LLC would have been a data user under the Ordinance. K . 85. Whether Google LLC Acted in Breach of DPP 2 or Section 26 By reason of the Board's conclusion on the issue of extra-territorial effect of the Ordinance, it is strictly not necessary for the Board to express any views on whether Google LLC acted in contravention of DPP2 or in breach of section 26 of the Ordinance for failing to erase the personal data of the Appellant from the search engine upon his request. Furthermore, since any concrete conclusions on the above matters may affect the reputation of both the Appellant and Google LLC, there is more the reason for the Board to refrain from making any findings as a matter of dicta. However, since the parties have made full submissions on the issue, the Board will briefly address the legal issues of the "right to be forgotten" and application of the 13 criteria set out in the UK case of NT1 & NT2. 86. DPP 2(2) (under the title: “accuracy and duration of retention of " personal data ) in schedule 1 of the Ordinance provides that: “All practicable steps must be taken to ensure that personal data is not kept longer than is necessary for the fulfillment of the purpose (including any directly related purpose) for which the data is or is to be used;” 58