Interpol CCF Lawyer

The Commission for the Control of Files (CCF) is Interpol’s independent oversight body, established under Article 36 of Interpol’s Constitution. It operates entirely separately from Interpol’s General Secretariat and from member states. Its mandate is to ensure that all of Interpol’s data processing activities comply with Interpol’s own rules — most importantly, the Rules on the Processing of Data (RPD).

The CCF has two chambers. The Supervisory and Advisory Chamber oversees Interpol’s general data governance and provides policy guidance. The Requests Chamber deals with individual complaints from people who believe that data held by Interpol about them is unlawful, incorrect, or otherwise violates Interpol’s rules. The Requests Chamber is where most of our clients’ cases are resolved — either through access requests, deletion requests, or appeals from earlier decisions.

The CCF operates independently and has the authority to order Interpol’s General Secretariat to delete or modify any notice or record. Its decisions are binding on Interpol. This makes it the most important legal venue for anyone seeking to challenge a Red Notice, Diffusion, or other Interpol record — and the most important reason to have specialist legal representation from the outset.

Interpol’s Rules on the Processing of Data set out strict requirements that every notice must satisfy. The CCF will order deletion where the notice fails to comply. The most common grounds we rely on are:

Article 3 violation: Interpol’s Constitution prohibits all activities of a political, military, religious, or racial character. Where the requesting state is using Interpol as a tool of political persecution — a pattern particularly associated with notices from Russia, Belarus, Kazakhstan, Azerbaijan, Ukraine, and Turkey — the CCF can refuse or delete the notice on this basis.

Failure to meet RPD requirements: Every notice must meet minimum standards of factual basis, legal validity, and proportionality. Notices that lack a proper arrest warrant, fail the seriousness threshold, or are issued without adequate supporting documentation can be challenged on procedural grounds.

Human rights concerns: Where there is a real risk that the individual would face torture, inhuman treatment, or an unfair trial in the requesting state, the CCF takes human rights compliance into account as a mandatory consideration.

Ne bis in idem: If the person has already been tried and acquitted for the same offence in another jurisdiction, this constitutes a bar to Interpol processing under the double jeopardy principle.

Refugee or protected status: The CCF is required to consider whether the subject holds refugee status, subsidiary protection, or other international protection. Such status is a strong indicator of a political motivation behind the notice.

The CCF process typically unfolds over several stages. We begin with a thorough case assessment — analysing the notice, the underlying domestic proceedings, and the client’s personal situation to identify the strongest legal arguments. We then gather supporting evidence: court documents, asylum decisions, country condition reports, and expert opinions.

Once we have assembled the file, we prepare a comprehensive legal memorial for submission to the CCF Requests Chamber. This sets out the facts, the legal grounds, and the relief sought in full. Where the situation is urgent, we request provisional measures asking the CCF to suspend enforcement of the notice while the review is pending.

The CCF then reviews the file, puts questions to Interpol’s General Secretariat, and may seek responses from the member state that issued the notice. We respond to all requests for additional information on the client’s behalf. A decision typically follows in 6–18 months for deletion requests, or 3–6 months for access and preventive requests. If the CCF issues a favourable decision, Interpol is required to delete or modify the notice promptly.