b. Funding: INTERPOL should provide adequate funding to ensure the effective implementation of any reforms to the CCF and that consideration should be given to the use of video conferencing technology, for example, as a mechanism for making cost savings. c. Unrepresented applicants: The CCF should do more to ensure that people without legal representation are able to access the remedies which the CCF provides. More information about the procedures for making data access requests and complaints should be made publicly available, as well as template documents which unrepresented individuals could make use of. The CCF should use simpler language in its correspondence so that it is more easily understood by people who do not have legal training. d. Data access requests: The presumption of secrecy which governs the CCF’s procedures and which prevents even people who have good reasons to believe that they are subject to an INTERPOL alert from accessing the data on INTERPOL’s files, should be replaced by a presumption of disclosure of information about the existence of an INTERPOL alert. Data access requests should be subject to tighter deadlines, with data being blocked or deleted whenever such deadlines are not complied with. e. Complaints procedures: The CCF’s procedures for requesting the deletion or amendment of information should be made more transparent, and should enable NCBs and individuals to exchange arguments more openly and effectively. There should be a presumption of disclosure of arguments and evidence submitted by both the 40 NCB and the individual, subject to limited exceptions, and specific deadlines should be introduced to govern the complaints procedure. In order to facilitate the shift to a more open and transparent procedure, oral hearings should be made available with the use of video-conferencing technology where appropriate. f. Decisions: The CCF’s decisions should be fully reasoned, including a description of the facts of the case, a summary of the arguments put forward by both parties, and references to specific provisions of INTERPOL’s rules. Decisions should also be made publicly available, subject to redactions, so that both NCBs and individual applicants would be able to gain an improved understanding of how the CCF interprets INTERPOL’s rules. CCF decisions should be binding on the General Secretariat. g. Appeals: The CCF’s decisions in response to data access requests and complaints should be accompanied by a right to appeal to an Appeals Panel which are able to address any issues relating to the interpretation of INTERPOL’s rules and the evidence provided by NCBs and applicants. The appeals procedure should be adversarial, enabling an effective exchange of arguments between the parties, and subject to specific timeframes. h. Remedies: There should be three types of remedies: i) Interim remedies: The CCF should be able to add caveats to existing alerts to notify users of its systems that the data is subject to review, and it should block alerts in cases where NCBs fail to comply with its direction in the context of data access requests and complaints.