The Commission for the Control of INTERPOL’s files(CCF) has recently released its Annual Report for 2021. Notably discussed within the report was the processing of 1,579 cases, 651 of which were complaints. This series of posts will comprehensively review the 651 complaints processed in 2021. 

Among the 651 Complaints processed by the CCF:

  • 478 were complaints concerning admissible requests from applicants who were the subjects of data recorded in INTERPOL’s files. 
  • Among these complaints, 133 involved cases in which the CCF established that the data challenged met the required legal conditions for their retention in INTERPOL’s files and were therefore considered compliant. This means that the removal requests were denied and the subjects’ data remained in INTERPOL’s databases.
  • Compliance of data challenged with applicable rules was subject to updates in 20 cases in INTERPOL’s files to ensure the quality and accuracy of data, as required by Article 12 of the RPD. This could mean that the charges were improperly listed initially, or the status of the case had changed, or some development had occurred which required updating of the the data.
  • 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. This means that the subjects who requested that their names be removed from INTERPOL’s databases were successful in their requests.

NCBs’ failure to respond or to provide a sufficient response

  • For 50 the 478 complaints mentioned above, the Commission concluded that the data should be deleted because the National Central Bureau (NCB) of the requesting country did not answer the questions raised by the Commission. This information tells us that not all NCBs are interested in defending their Red Notice requests, or at least not for all cases.

NCBs removed data on their own

  • In 49 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.  In these cases, the subjects prevailed on their removal requests without the CCF having to render a decision.

Blocking of data

  • In 311 of the admissible complaints, access to data recorded in INTERPOL’s files concerning the applicants was blocked, a topic further examined in the Red Notice Law Journal’s previous post regarding blocking, as a precautionary measure, pending the finalization of the cases, from the moment serious doubts arose over their compliance with INTERPOL’s rules.

In the next post, we will look further into the CCF’s 2021 Annual Report.

As always, thoughts and comments are welcomed.