Commission for the Control of INTERPOL’s Files (CCF) published its 2021 activity report.

CCF’s functions are laid down in Article 36 of INTERPOL’s Constitution and in Article 3 of the Commission’s Statute. It consists of two chambers namely (i) the Supervisory and Advisory Chamber, and (ii) the Requests Chamber. The Requests Chamber is responsible for processing requests for access to data, and/or for the correction or deletion of data processed in the Interpol Information System.

CCF’s modus operandi

The CCF of INTERPOL holds four sessions every year: In January, April, June/July and October, though there could be changes in its calendar.
When removal or correction or access to the (personal) data request is submitted, the CCF first makes an admissibility examination. The applicant or his/her representative is informed about the outcome of the admissibility examination. It should be done no later than one month from the receipt of the concerned request.
From 2018 on, The CCF is required to render a decision within 9 months on removal requests, and within 4 months on access to data requests. These periods began on the date of the admissibility decision.

According to the report, in 2021, the CCF finalised the processing of 1,597 cases:

• In 1,396 cases, CCF finalised the case by reaching a conclusion,
• In 89 cases the contested data was deleted by the General Secretariat or the sources of data (respective National Contact Bureau) before the CCF reached a conclusion,
• 112 cases have been found inadmissible.

Of finalised 1,597 cases,

• 759 were requests for access to data,
• 651 were complaints (requests for deletion or correction of data),
• 63 were revision requests,
• 124 were others.

Statistics about complaints

According to the report, of the 651 complaints processed in 2021, 478 concerned admissible requests from applicants who were the subjects of data recorded in INTERPOL’s files.

In 133 complaints, the CCF established that the data challenged met the required legal conditions for their retention in INTERPOL’s files and were therefore considered compliant. On the other hand, in 296 cases, the Commission established that the challenged data did not meet legal requirements and should therefore be deleted from INTERPOL’s files as they did not comply with INTERPOL’s rules. In 50 cases, data were deleted because their sources did not answer at all to the questions raised by the Commission. In 49 other cases, either the INTERPOL General Secretariat or the National Central Bureau at the source of the challenged data decided to delete them from the INTERPOL Information System before the Commission had taken a decision.

Provisional measures

In 311 of the admissible complaints, access to data recorded in INTERPOL’s files concerning the applicants was blocked as a precautionary measure, pending the finalisation of the cases, from the moment serious doubts arose over their compliance with INTERPOL’s rules.