This paper contextualizes and analyzes the main emerging approaches to the un-derstanding of the right to be forgotten and its application in praxis, using leg-islation and judicial practice of the European Union and Ukraine as reference scales. By bridging the gap between positive and interpretative orders of law im-plementation, which were previously imperatively opposed and considered mutu-ally exclusive in the Ukrainian legal system, the paper supports the arguments that the process of mastering the protection of right to be forgotten requires a further mindset shift equally for-Internet providers and all involved law enforcers.