INTERPOL Dismantling Strengthening the Tools of Oppression Effective avenue of redress i) Moving in the direction of reform 80. A year after publication of Strengthening INTERPOL, we saw two key developments which signalled INTERPOL’s commitment to addressing our concerns regarding the deficiencies of the CCF as an avenue of redress. In September 2014, Nina Vajic, a former judge of the European Court of Human Rights, a professor of Human Rights Law at the University of Zagreb and an expert in international organisations law, was appointed as Chair of the CCF. Given that the lack of human rights expertise within the CCF was one of the issues which Fair Trials had hoped to see addressed by INTERPOL, we welcomed this as a positive step in the right direction. 81. Two months later, during INTERPOL’s General Assembly in November 2014, a Resolution was adopted which tasked an internal working group (Groupe de travail sur le traitement d’information or “GTI”) with conducting a comprehensive review of INTERPOL’s data processing at all levels, including the CCF, and tasking INTERPOL’s General Secretariat with conducting consultations to assist the GTI.68 The GTI met for the first time in July 2015, with over 60 participants from 30 countries, and Fair Trials welcomed the opportunity to make both written and oral representations at the meeting,69 we reiterated our concerns about the way in which the CCF operates and called for reforms to ensure an adversarial process which functions with greater transparency and efficiency. 82. During the July 2015 meeting of the GTI, it became clear that there was a genuine commitment to reforming the CCF but that there was a lack of clear vision within INTERPOL and on the part of its members of what precise reforms were required. We sought to inform further the GTI’s thinking on these issues, by submitting a more detailed proposal for CCF reform in advance of the working group’s second meeting which took place in December 2015.70 Drawing on good practice examples from other international organisations and comparable bodies, and emphasising that reforms were imperative in order to bring the CCF in line with the requirements of internal redress mechanisms established by the Court of Justice of the European Union in Kadi,71 we made the following proposals: a. Composition and structure: In order to address concerns about the CCF’s lack of the expertise needed to determine complaints, the CCF should be divided into three entities, each with specialist expertise, which meet with sufficient regularity to ensure that requests and complaints are processed within specified timeframes: i) Data Protection Office, which advises and monitors INTERPOL on data protection matters and processes requests for access to INTERPOL’s files; ii) Complaints Committee, which has expertise in human rights and extradition law, and is responsible for handling requests for the deletion or amendment of information on INTERPOL’s files; and iii) Appeals Panel, which hears appeals from the Data Protection Office and the Complaints Committee. INTERPOL, Resolution No. 19, AG-2014-RES-19, ‘INTERPOL’s supervisory mechanisms concerning the processing of data in the INTERPOL Information System’ (November 2014) Fair Trials, ‘Fair Trials makes recommendations to INTERPOL on Red Notice abuse’, (28 July 2015) Available at: https://www.fairtrials.org/fair-trials-make-recommendations-to-interpol-on-red-notice-abuse/ 70 Fair Trials, ‘Submission – Reform of the Commission for the Control of INTERPOL’s Files and itsdata processing procedures’ (10 December 2015) Available at: https://www.fairtrials.org/wp-content/uploads/Fair-Trials-Submission-to-GTI-Dec-2015.pdf?platform=hootsuite 71 Kadi (n 22); See also C-584/10 P, Commission and Others v Kadi [2010] ECR II 5177 (‘Kadi II’) 68 69 39