INTERPOL's CCF: An Appellate Court?

As a specialised legal body within the International Criminal Police Organization, the Commission for the Control of INTERPOL’s Files (CCF) plays an essential yet often misunderstood role. Unlike judicial entities, the CCF is not an appellate body but a regulatory one, tasked with ensuring that INTERPOL's data processing meets stringent internal standards.

First, the CCF’s core function under Article 31 of its statute is to monitor and ensure that INTERPOL's processing of personal information adheres to its strict regulations. This includes overseeing correction, deletion, and access to data within the INTERPOL Information System, such as red notices. Notably, the CCF does not assess guilt or adjudicate criminal matters.

Second, the CCF does not revisit or overturn lower courts' findings; its role is strictly regulatory. It ensures that all data handled by INTERPOL is processed according to the organization’s internal legal framework. This is crucial for maintaining the integrity and reliability of international law enforcement collaborations.

Third, while the CCF can conduct limited fact-finding to verify compliance with INTERPOL’s rules, it does not engage in extensive investigations or determine the merits of cases. This constrained role helps maintain focus on procedural legality without stepping into the realms of criminal investigation or judgment.

Fourth, requests for data correction or deletion are processed strictly within the boundaries of established legal protocols. When data processing exceeds these boundaries (ultra vires), it is immediately considered null and void. This strict adherence to legal standards prevents overreach and protects against potential data misuse within INTERPOL’s vast network.

Thus, the CCF’s role is regulatory, not judicial. Its decisions to delete data, like red notices, are procedural and do not impact criminal responsibility at the national level. Criminal adjudication remains under national jurisdictions, independent of CCF actions, preserving the integrity of local legal processes within global law enforcement frameworks.