Call for contributions from Civil Society to the Committee on the Processing of Data

For the review of the statute of the commission for the control of INTERPOL’s files (Lyon, France, 20 July 2026)

Deadline for submissions: 16 August 2026

The Commission for the Control of INTERPOL’s Files (CCF) is an independent body that ensures that the processing of all personal data through INTERPOL’s channels complies with the rules of the Organization.

The Committee on the Processing of Data (CPD) is responsible for reviewing and making recommendations on how INTERPOL processes data for the purposes of promoting international police cooperation and preventing and suppressing ordinary law crimes, in accordance with Article 2 of the INTERPOL Constitution. It is a standing committee of the INTERPOL General Assembly and meets at least once a year.

In 2024, the CPD launched a process to review the Statute of the CCF, the set of rules that define its work. To that end, the CPD has been seeking contributions from civil society concerning selected topics related to the work of the CCF and its Statute. During past meetings, the expertise and diverse perspectives of external stakeholders have enriched and added depth to the discussions.

Thus, in preparation for its next meeting in September 2026, the CPD is launching a new call for contributions from civil society on the topic below.

This fourth call for contributions is addressed to interested representatives of intergovernmental and non-governmental organizations, academia, and the legal sector in INTERPOL’s member countries with existing working relationships with the CCF or recognized expertise in CCF-related matters.

They are invited to submit their input on the following topic, which will be discussed in September by the CPD:

Nature and content of decisions (Article 38 of the Statute)

Article 38 of the Statute establishes that decisions issued by the Requests Chamber must be reasoned and communicated to both the applicant and the source of the data, subject to confidentiality requirements and restrictions.

Some member countries noted that the provision of decisions being “subject to confidentiality requirements and restrictions”, under Article 38(3) of the Statute, may pose certain challenges. While decisions are shared with data sources, confidentiality constraints may prevent them from accessing the full reasoning behind decisions that directly impact them. For example, this may hinder their assessment of whether a revision request under Article 42 of the Statute should be considered.

As a reminder, the grounds on which a data source may request the communication of information to be restricted are enumerated in Article 35(3) of the Statute, namely:

- To protect public or national security or to prevent crime
- To protect the confidentiality of an investigation or prosecution
- To protect the rights and freedoms of the applicant or third parties
- To enable the Commission or the Organization to properly discharge their duties.

Contributors are invited to address the following question:

How can the CCF reconcile the confidentiality requirements and restrictions under Article 35(3) of the Statute with the requirement to provide a reasoned decision to the parties (i.e. applicant and source of data) under Article 38(3)?

Stakeholders are encouraged to submit their views on potential solutions or adjustments to ensure both transparency and the protection of sensitive information.

How inputs will be used

Relevant contributions will first be reviewed by the INTERPOL General Secretariat. If they meet the submission criteria and are deemed relevant, they will then be shared with the CPD for its consideration. INTERPOL retains full discretion on whether to share contributions with the CPD. INTERPOL is not obliged to accept any suggestion put forward in the contributions received.

Neutrality of INTERPOL

Article 3 of the INTERPOL Constitution explicitly forbids the Organization from engaging in matters of a political, military, religious, or racial character. Any contributions that contain such elements will be automatically excluded from consideration.

Submit your contribution