Commission for the Control of INTERPOL’s Files (CCF)

What it does?

The Commission for the Control of INTERPOL’s Files (CCF) functions as an independent body with the primary responsibility of ensuring that all personal data processed through INTERPOL’s channels complies with the Organisation’s rules.

Individuals have the right to request access to data held about them in INTERPOL’s files. INTERPOL processes substantial amounts of personal data through its notices and databases on criminals and crimes, including names, photos, identifying features, and fingerprints.

The CCF's mandate includes three core functions as defined by INTERPOL’s Constitution: supervisory, advisory, and processing (Articles 36-38).

1. Supervisory Function: Oversees compliance with data processing rules.
2. Advisory Function: Provides guidance on data protection matters.
3. Processing Function: Addresses individual requests for access, correction, or deletion of data within the INTERPOL Information System.

Despite its independent status, the CCF collaborates with other governing bodies and members of the Organisation. This involves direct consultation with the INTERPOL General Secretariat, National Central Bureaus, and other relevant entities to fulfil its duties within the established legal framework.

What it does NOT?

The mandate of the CCF is subject to strict limitations.

Judicial Authority: The CCF is not a substitute for judicial authorities. It does not determine innocence or guilt, nor does it conduct investigations. It verifies whether requests for international police cooperation via INTERPOL channels adhere to the Organisation’s regulations.

1. Extradition Procedures: The CCF does not render assessments or opinions on extradition procedures and outcomes. It has no authority to halt proceedings under bilateral legal cooperation agreements.
2. Arrest Warrants: The CCF cannot command any country to revoke an arrest warrant. It holds no power to dictate actions within sovereign territories.
3. Victim Assistance: The CCF does not assist victims of crimes, facilitate contact with national authorities, aid in visa applications, issue certificates of good conduct, or involve itself in other administrative matters.

What process does CCF follow?

• Preliminary Study: Upon receiving an individual's request for access, the Commission initiates a preliminary study to determine if the request falls within its jurisdiction (Article 5, Operating Rules). If the request is valid, the Commission may ask the General Secretariat to undertake a "preliminary study" of the request.
• Legality of the Data: The General Secretariat, responsible for upholding the organisation's databases and overseeing its data processing activities, reports to the Commission on the legality of the data processing and any corrective steps taken. If the Commission disagrees with the preliminary study, it can conduct a further review and request additional information from the applicant, the data source, or the General Secretariat. While the General Secretariat can explain how data was processed, the Commission cannot release any information to the applicant without the data source's consent.
• Conclusions and Recommendations: Once the Commission has sufficient information, it draws conclusions and issues recommendations to the General Secretariat, which generally needs the data source's consent to amend or delete data. However, if there is any doubt about the data's proper processing, the General Secretariat can take steps to ensure compliance.
• Disagreements and Further Actions: The General Secretariat may decide not to follow the Commission's recommendations but must explain this decision and take appropriate steps to ensure compliance with INTERPOL's data processing rules. The General Assembly recognises the potential for disagreement between the Commission and the General Secretariat. If the Commission disagrees with the Secretariat's decision, it may inform the Executive Committee, which is not obligated to act but may direct the General Secretariat to implement the Commission's recommendations. While the Commission plays a crucial role in ensuring compliance, the General Assembly allows for its overruling.

Communication from the CCF After Submitting a Request

Once you submit a request, the CCF follows a systematic communication procedure:

• Acknowledgement: You will receive an acknowledgement of receipt of your initial request.
• Admissibility and Procedure Information: The CCF will inform you about the admissibility of your request and the applicable procedures.
• Results: You will be notified of the results of the processing of your request.

Depending on the nature of the request, additional communications may include:

• Requests for further information, if necessary
• Possible interim replies to inform you about the status of your request or any procedural changes
• Notices indicating that your case will be studied at the Commission’s next session

Decision Timeline

According to its Statute, the CCF will decide on a request for access within 4 months of its admissibility. For requests involving correction and/or deletion, a decision will be made within 9 months of admissibility. If the request pertains to correction or deletion, the INTERPOL General Secretariat has 1 month to comment on the CCF’s conclusions. Once a decision becomes final, the CCF notifies the applicant within 1 month. Applicants should wait at least 3 months after the session that examined the request before enquiring about the outcome.

Publication of Decisions

The CCF produces an annual report, which is published on INTERPOL’s website. It may also make public statements. The CCF does not publish decisions containing personal information nor systematically publish all its decisions. However, it may publish excerpts of anonymised decisions that raise issues of public interest, helping the general public understand the Commission's working methods and the assessment of INTERPOL’s rules. These decisions are available on the Sessions and reports page.

Appealing a CCF Decision

Applications for the revision of a CCF decision can only be made by the applicant and must be based on the discovery of a fact that would likely have led to a different conclusion if known at the time of processing. Applications for revision must be submitted within six months of discovering such a fact and must include a brief statement of these facts and their potential impact on the original decision. A Revision form is available on the How to submit a request page.