Dismantling the
Tools ofreport
Oppression
INTERPOL
2018
Recommendations: Effective avenue of redress
The CCF should clarify and publish how NCB’s
refusal to disclose data without justification
affects its own decisions.
INTERPOL and the CCF should develop more
robust mechanisms for ensuring that NCBs
comply with instructions to delete data from
national databases following a CCF decision.
The CCF Statute should be amended to grant
to individuals and NCBs the right to appeal
against a decision of the CCF.
The CCF should limit the use of addenda in
lieu of deletion, and where addenda are used,
they should be made visible on the public Red
Notices to which they apply.
The CCF should collect and publish data that
would illustrate the effectiveness and efficiency
of its complaints procedures.127
INTERPOL, acting through the General
Assembly, should ensure that the CCF is given
a sufficient budget to implement the new CCF
Statute effectively.
Member States should support the work
of the CCF by ensuring that the CCF is
adequately funded, including by provided
ring-fenced funding to make sure that the
CCF is sufficiently staffed and resourced.
Member States should comply with requests
from the CCF as much as possible and respect
its decisions.
These could include: (i) the total number of requests for (a) access for data, and (b) deletion of INTERPOL Alerts; (ii) the number of requests for (a) access for
data, and (b) deletion of INTERPOL Alerts which are successful; (iii) the number of requests for access for data which are unsuccessful and the reasons provided;
(iv) the number of requests for deletion in which disclosure to information to the applicant is refused and the reasons provided; (v) the average length of time
between submission of a request to access data and the date of the decision; (vi) the average length of time between submission of a request for deletion of
data and the date of the decision; (vii) the number of CCF cases each year in which oral hearings are (a) requested, and (b) granted; and (viii) the number of CCF
cases each year in which the CCF consults external experts.
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