The Commission for the Control of Interpol’s Files (CCF) is the independent supervisory body responsible for ensuring that data stored in Interpol’s information systems complies with Interpol’s rules. It is the only official mechanism through which individuals can challenge the lawfulness of an Interpol notice, diffusion or data entry — and it is the primary route for securing the deletion or correction of unlawful records. If you are the subject of an Interpol Red Notice or other Interpol record, understanding how the CCF works and how to use it effectively is essential.
What Is the CCF?
The CCF was established under Interpol’s Constitution and Rules on the Processing of Data (RPD) as an autonomous body, independent of the Interpol General Secretariat. It has three functions: monitoring Interpol’s compliance with its own data protection rules; receiving and processing individual requests for access, correction or deletion of Interpol data; and advising on requests submitted by individuals who believe their data is being processed in violation of Interpol’s rules.
The CCF operates from Interpol’s headquarters in Lyon, France, but exercises its functions independently. Its decisions are binding on the Interpol General Secretariat. When the CCF orders the deletion of a Red Notice, Interpol must act on that decision — member countries are then notified, and the notice ceases to exist in Interpol’s database.
CCF Proceedings: The Two-Stage Process
CCF proceedings consist of two distinct stages, each governed by specific procedural rules.
Stage 1 — Access Request (Article 36)
The first stage is the access request under Article 36 of Interpol’s RPD. The purpose is to determine whether Interpol holds any data about the requesting individual, and if so, to obtain information about the nature of that data. An access request does not in itself challenge or delete a notice — it is the procedural gateway through which a substantive challenge is initiated.
The CCF typically processes access requests within four months, though this timeline can be extended in complex cases. Upon completion of Stage 1, the CCF informs the individual whether data exists in Interpol’s systems and provides a reference number for the Stage 2 challenge. Importantly, the access request phase is conducted confidentially — Interpol does not routinely notify the issuing country that a request has been made at this stage.
Stage 2 — Substantive Review (Article 37)
Stage 2 is the substantive review under Article 37. This is where the CCF examines the lawfulness of the data and considers whether it should be deleted or corrected. The individual — through their legal representatives — submits a detailed memorial setting out the grounds for deletion, supported by documentary evidence. The CCF then communicates with the source country (the country that issued the notice) and may request a response. The full Stage 2 process takes between one and two years in complex cases.
The CCF can order one of several outcomes: deletion of the data; restriction of access; correction of the data; or continuation of processing. Where deletion is ordered, the source country is notified and Interpol removes the record from its database. The individual is informed of the decision, though the precise reasoning is not always disclosed in full.
Grounds for CCF Deletion
The CCF can order deletion on a number of distinct grounds. Experienced CCF lawyers will identify and pursue the strongest available arguments based on the specific facts of each case.
Political motivation: Article 3 of Interpol’s Constitution prohibits Interpol from undertaking any intervention or activities of a political, military, religious or racial character. Where a notice has been issued in connection with conduct that is, in substance, politically motivated — including cases of business disputes, asset seizures or whistleblowing dressed up as criminal charges — the CCF can order deletion on this basis. This is one of the most significant grounds for challenge, particularly in cases originating from states with poor rule-of-law records.
Violations of fair trial rights: Interpol’s rules require that notices relate to genuine criminal proceedings conducted in accordance with internationally recognised fair trial standards. Where proceedings are manifestly unfair — including cases where charges are based on fabricated evidence, where the individual was prosecuted in absentia without proper notice, or where confessions were obtained through coercion — the CCF may find that maintaining the data violates Interpol’s rules.
Refugee or asylum status: Interpol’s own rules specify that data should not be processed where the individual has been granted refugee status by UNHCR or asylum in a third country. A grant of asylum reflects a finding by a competent authority that the individual faces persecution in the requesting state. The CCF treats this as a strong indicator that the notice serves political rather than law enforcement purposes.
Double jeopardy: Where the individual has already been acquitted of the relevant charges, or where proceedings have been definitively discontinued, maintaining a notice may not be justified under Interpol’s rules.
Technical non-compliance: Notices must meet specific technical requirements under Interpol’s RPD — including requirements relating to the nature of the offence, the minimum penalty and the completeness of the information provided. Where a notice fails to meet these requirements, deletion can be sought on purely technical grounds.
Why Legal Representation Is Critical in CCF Proceedings
CCF proceedings are quasi-judicial in nature. The Commission applies a body of law — Interpol’s Constitution, the RPD, and the CCF’s own procedural rules — that is not well known outside a narrow group of international criminal law specialists. The CCF itself has noted that the quality of submissions varies significantly, and that poorly prepared requests are less likely to succeed.
Effective CCF representation requires more than familiarity with Interpol’s rules. It requires the ability to construct a compelling legal memorial, to gather and present documentary evidence in a format that the CCF will find persuasive, and to anticipate the arguments that the source country is likely to make in response. In many cases, it also requires understanding the domestic law of the issuing country — both to demonstrate the political motivation for the charges and to rebut the source country’s submissions.
Our lawyers have represented clients from across the world in CCF proceedings, including cases originating from Russia, Ukraine, Azerbaijan, Kazakhstan, China, the UAE and various other jurisdictions. We have developed a structured approach to CCF cases that maximises the prospect of a successful outcome — from the initial access request through to the full substantive challenge.
Interim Measures and Provisional Deletion
In exceptional cases, the CCF can order provisional (interim) deletion of a Red Notice while the full Stage 2 review is pending. This mechanism is available where the individual can demonstrate that continued processing of the data is causing immediate, serious harm — for example, where the notice is preventing the individual from travelling for urgent medical treatment, or where it is causing severe financial hardship.
Interim measures applications are difficult to succeed on, but they are a valuable tool in the right cases. Our lawyers have experience in identifying when interim measures are appropriate and in presenting the strongest possible case for provisional relief.
CCF and National Court Proceedings
CCF proceedings operate in parallel with, not instead of, any domestic legal challenge in the issuing or executing country. In many cases, a multi-jurisdictional strategy is most effective: pursuing CCF deletion at the Interpol level while simultaneously challenging the underlying proceedings in the issuing country or resisting extradition in the country where the individual is located.
Our firm coordinates CCF proceedings with any parallel domestic or extradition defence, ensuring that submissions are consistent and mutually reinforcing across jurisdictions.
Frequently Asked Questions
How long does a CCF application take?
Stage 1 (access request) typically takes three to four months. Stage 2 (substantive review) takes between six months and two years, depending on the complexity of the case and the responsiveness of the source country. Urgent cases where interim measures are sought can be addressed more quickly.
Can I apply to the CCF myself without a lawyer?
Yes, individuals can apply directly. However, the procedural requirements are technical and the substantive law is specialised. In practice, self-represented applicants rarely succeed in Stage 2 proceedings. The quality of the Stage 2 memorial is often the decisive factor in the outcome.
Will the issuing country know I have filed a CCF request?
During Stage 1, the CCF generally does not notify the source country. In Stage 2, the CCF communicates with the source country as part of its review process and typically gives it an opportunity to respond to the individual’s submissions. Your lawyers will take this into account when preparing submissions.
What happens if the CCF orders deletion?
If the CCF orders deletion, the Interpol General Secretariat removes the data from its systems and notifies Interpol’s member countries. The Red Notice ceases to exist. The individual will no longer be at risk of arrest based on that notice when crossing international borders. There may be a short period before all national databases are updated.
Does a CCF deletion affect criminal proceedings in the issuing country?
A CCF deletion does not affect domestic criminal proceedings in the issuing country — it removes Interpol’s involvement, but the underlying charges remain. However, a CCF finding that a notice was politically motivated or violated Interpol’s rules can be used as supporting evidence in domestic and extradition proceedings.
If you are the subject of an Interpol Red Notice, diffusion or other Interpol record and wish to challenge it through the CCF, contact our team for a confidential assessment. We advise on the merits of a CCF application, prepare all procedural and substantive submissions, and represent clients throughout the full CCF process.