Ali Yildiz has joined a coalition of prominent international lawyers in responding to a call for contributions by the Committee on the Processing of Data (CPD), a standing committee of INTERPOL’s General Assembly. The submission concerns draft amendments to Articles 28, 33, 37, and 40 of the Statute of the Commission for the Control of INTERPOL’s Files (CCF).

Together with Nicola Canestrini, Michelle Estlund, Vladimir Hrle, William Julié, Yuriy Nemets, Anna Oehmichen, and Bruce Zagaris — all members of the working group Lawyers Against Transnational Repression — Ali Yildiz has raised serious concerns about the implications of the proposed changes.

Defending the Integrity of INTERPOL’s Redress Mechanism

The joint submission warns that if adopted, the amendments would:

• Undermine the independence of the CCF, making its ability to review complaints conditional on the actions — or inaction — of the General Secretariat.

• Create legal uncertainty and delays by introducing the undefined concept of a “final compliance decision,” without requiring the General Secretariat to act within any deadlines.

• Reduce transparency, limiting individuals’ ability to understand why their data is retained or deleted and offering no insight into the legal rationale behind decisions.

• Fail to address government abuse, as the draft does not empower the Commission to delete or block data in cases of misconduct by a government.

• Introduce unclear sanctions for applicants and their representatives without providing adequate definitions of “abusive” or “bad faith” conduct.

A Call to Preserve Justice and Human Rights

Yildiz and his colleagues argue that the proposed changes would reverse progress made in recent years to prevent transnational repression through INTERPOL. In particular, they stress that reforms to the redress mechanism — aimed at ensuring fairness and legal safeguards — are now at risk of being undone.

“The Commission for the Control of INTERPOL’s Files must remain independent, accessible, and effective. Its role is not merely administrative, but a vital safeguard for individuals who are often targeted by politically motivated prosecutions,” said Ali Yildiz.

Full submission is available here: https://www.latrint.org/our-work/lawyers-against-transnational-repression-responds-to-the-call-for-contributions-of-the-committee-on-the-processing-of-data-cpd-concerning-draft-amendments-to-articles-28-33-37-and-40-of-the-statute-of-the-commission-for-the-control-of-interpols-files