Unlearning at Scale: Implementing the Right to be Forgotten in Large Language Models

Abstract

We study the right to be forgotten (GDPR Art. 17) for large language models and frame unlearning as a reproducible systems problem. Our approach treats training as a deterministic program and logs a minimal per-microbatch record (ordered ID hash, RNG seed, learning-rate value, optimizer-step counter, and accumulation boundary). Under a pinned stack and deterministic kernels, replaying the training tail while filtering only the forget closure yields the same parameters as training on the retain set (bit-identical in the training dtype) when preconditions hold. To meet latency and availability constraints, we add complementary paths: (i) exact reverts of recent steps via micro-checkpoints or dense per-step deltas, (ii) cohort-scoped adapter deletion when the base is frozen, and (iii) a curvature-guided anti-update followed by a short retain-tune, audit-gated with escalation to exact replay. We report storage/latency budgets and a toy artifact validating mechanics; in a controlled run that satisfies the preconditions we demonstrate byte-identical equality of model and optimizer states.