Review of CCF Statute – Call for Contributions

The Commission for the Control of INTERPOL’s Files (CCF) is an independent body that ensures that personal data processed through INTERPOL’S channels conform to the rules of the Organization.

The Committee on the Processing of Data (CPD) is responsible for reviewing and making recommendations on INTERPOL’s processing of data to promote international police cooperation and prevent and suppress ordinary law crimes, in accordance with the “spirit of the Universal Declaration of Human Rights”, pursuant to Article 2 of the Organization’s Constitution. It is a standing committee of INTERPOL’s General Assembly and meets at least once a year.

The CPD has recently launched a process to review the legal framework governing the work of the CCF. To that end, the CPD is seeking contributions from civil society concerning selected topics related to the CCF and its legal framework.

Topics

Interested parties are invited to submit contributions on one or both of the following two areas currently being considered by the CPD:

1. The procedure for the examination of new requests;
2. The right to access, correct and delete data – misuse of CCF proceedings.

The above topics are currently the only ones for which members of civil society are invited contribute. Further background information about these two topics can be found below.

 Calls for additional contributions on other topics related to the work of CCF and its legal framework, including new topics that may be proposed by civil society, will be launched in the future.

Criteria and process for submitting a contribution

Contributions are welcomed from interested parties, except from individuals who currently have pending application before the CCF [Note: lawyers representing such individuals before the CCF may submit contributions).

Interested individuals representing national agencies, ministries or any other governmental entities should submit their contribution through their country’s National Central Bureau.

Contributions should be made using the Contribution form below and can be submitted in one of our official languages: English, French, Spanish or Arabic.

The submission of a contribution will not confer any status, whether participatory or consultative, on the contributor vis-à-vis INTERPOL.

Contributions should not exceed 10,000 characters per topic with only one contribution per topic per contributor. They should not mention specific cases or countries, nor any political statements, and should not contain inappropriate language.

The deadline for submissions is 6 April 2025.

The form should be sent to the email indicated in it. It should not contain any other attachments.

Any contribution that does not meet the required criteria will not be taken into consideration.

How input will be used

Relevant contributions will be first reviewed by INTERPOL’s General Secretariat, and shared with the CCF. If the General Secretariat deems that the submissions meet the criteria and are relevant, they will be shared with the CPD for its consideration. INTERPOL is not obliged to accept any suggestion put forward in any contribution received. The contributions will not be published on INTERPOL’s website and only an acknowledgment of receipt will be sent. No further engagement or dialogue with INTERPOL should be expected, although INTERPOL will strive to provide at a later stage an update on relevant developments concerning the topics to which contributions were submitted.

Neutrality of INTERPOL

INTERPOL's Constitution explicitly forbids INTERPOL from engaging in matters of political, military, religious and racial character. Any contributions that would require INTERPOL to engage in such matters will be excluded.

PRESENTATION OF SELECTED TOPICS

Topic 1: Procedure for the examination of new requests

The CPD has been considering draft amendments for the procedure for the examination of new requests (Article 33(2) of the CCF Statute) for the purpose of clarifying the respective roles of the General Secretariat and of the CCF in the process of review. Notably, these include the General Secretariat’s role in first reviewing and taking final decisions on data compliance with INTERPOL’s Rules before an examination by the CCF, as the supervisory body overseeing the General Secretariat’s decisions, is conducted. This notion as well as the procedure where no data are being processed at the time a request is examined by the CCF, are reflected in the draft amendments of Article 33 of the CCF Statute. Corresponding modifications on provisional measures and timeframes are reflected in Articles 37 and 40 of the Statute.

The draft amendments to the CCF Statute, currently under discussion by the CPD, are presented below in bold.

Article 33: Examination of requests

1. The Requests Chamber shall examine an admissible request only after the General Secretariat has taken a final compliance decision on the data concerned.
2. When a request is considered admissible, the Requests Chamber shall determine whether data concerning the applicant are being processed in the INTERPOL Information System.
3. If no data concerning the applicant are being processed at the time the request is examined, the Requests Chamber may decide on appropriate measures, taking into consideration confidentiality requirements. The Requests Chamber shall make the information contained in the request available to the General Secretariat so that it may be considered in any future compliance review conducted by the General Secretariat should data be later processed in the INTERPOL Information System.
4. If data concerning the applicant are being processed in the INTERPOL Information System, and if the request is for correction or deletion, the Requests Chamber shall examine the compliance of the processing of the data with INTERPOL’s rules. If the request only concerns access to the data, the Requests Chamber may nonetheless decide to examine the compliance of the processing of those data with INTERPOL’s rules. The scope of review of a request shall be limited to examining the compliance of the processing of data with INTERPOL’s rules.

Article 37: Provisional measures

1. At any time during the examination of a request, the Requests Chamber may decide on provisional measures to be taken by the Organization in relation to the processing of the data concerned.
2. The Requests Chamber shall not decide on provisional measures before the notification by the General Secretariat of its final compliance decision on the data concerned.
3. Provisional measures shall be implemented in accordance with the procedure specified in Article 41 of the present Statute.

Article 40: Timeframe for decisions

1. The Requests Chamber shall decide on a request for access to data within four months from the date on which the request was declared admissible, or the date of notification by the General Secretariat of its final compliance decision, whichever is the later.
2. The Requests Chamber shall decide on a request for correction and/or deletion of data within nine months from the date on which the request was declared admissible, or the date of notification by the General Secretariat of its final compliance decision, whichever is the later.

Topic 2: Right to access, correct and delete data – misuse of CCF proceedings

(Articles 28 and 29 of the CCF Statute)

The CPD requested the General Secretariat to present draft amendments to the CCF Statute aiming to codify the CCF’s practices and policies that address cases of misuse of CCF proceedings such as submission of forged or fraudulent documentation; submission of knowingly false information on decisive matters; submission of repetitive requests to circumvent a CCF decision; improper disclosure of information in violation of the CCF’s rules on confidentiality; attempt to exert influence or pressure on the CCF, its members or Secretariat; or attempt to exert influence or pressure, or punish, an individual for approaching or contributing in any capacity to the submissions before the CCF.

The draft amendments to the CCF Statute, currently under discussion by the CPD, are presented below in bold.

Article 28: Powers of the Requests Chamber

(3)    To perform its functions, the Requests Chamber shall have the power to decide on appropriate measures to address abusive, improper, or bad faith conduct by an applicant, a duly authorized representative or the source of the data, including:

(a)    dismiss the request, the application, or a written submission where it considers that there has been an abuse of its proceedings;
(b)    report substantiated suspicions of misconduct to the Organization and the relevant authorities, including law enforcement or licensing bodies, where such misconduct is sanctionable by law;
(c)    decide, on its own initiative or at the request of an individual or National Central Bureau, to take appropriate measures to record and bring the attention of the Organization reported acts of intimidation, coercion, or reprisal in connection to a request or to an application.