confirm whether the information on the
Greek system was still valid. The letters
which the CCF is now routinely providing
should go some way to resolving such
situations for people whose data lingers
on national databases following deletion
by INTERPOL.
CCF Reforms
87. In November 2016, the General Assembly
adopted a resolution74 which approved
a new Statute of the Commission for the
Control of INTERPOL’s Files75 and introduced
amendments to INTERPOL’s Rules on the
Processing of Data, both of which came
into force in March 2017. These reforms
were supplemented by the revised CCF
Operating Rules which were adopted later
in the same month. 76
Greater independence and influence of the CCF
88. The CCF Statute now states clearly that
the CCF is to be independent in the
performance of its functions.77 There are now
clearer protections of the independence of
the CCF from the influence of the General
Secretariat, but also the independence of
CCF members from other external influences.
89. The role of the General Secretariat in the
procedures of the CCF has been significantly
reduced, with its residual role being
limited to issues relating to the disclosure
of information and to receiving information
about extensions of deadlines.78 The CCF’s
42
independence from the General Secretariat
is further entrenched by the codification in
the CCF Statute of the binding nature of
its decisions.79 In addition, the recent
reforms enable the CCF to submit a
budget proposal, following which the
General Assembly will allocate “the annual
budget necessary to perform its functions”.
The General Secretariat, previously
responsible for setting the CCF’s budget,
no longer plays any part in the process.80
90. Article 11 of the CCF Statute which deals
specifically with the independence of the
CCF requires INTERPOL and its Member
States to “abstain from any action which
might influence the members of the
Commission or its Secretariat, or be
prejudicial to the discharge of their
functions”81 and makes the Chairperson
of the CCF responsible for ensuring that
“the rules on the independence of the
Commission and its members are
respected”.82 The General Secretariat is no
longer responsible for appointing the CCF
Secretariat, which is now appointed and
supervised exclusively by the CCF itself.83
91. As for the independence of CCF members
from external influence, Article 11(2) of
the CCF Statute requires that Commission
members must “remain free from external
influence, whether direct or indirect, and
neither solicit nor accept instructions from
any person, body or government”, and
CCF members should withdraw themselves
74
INTERPOL, Resolution No. 6, AG-2016-RES-06, ‘INTERPOL’s supervisory mechanisms for the processing of data in the INTERPOL Information System’
(November 2016)
75
II.E/RCIA/GA/2016 (‘CCF Statute’) Available at:https://www.interpol.int/content/download/33754/446865/version/10/file/OLA-STATUTE%20CCF-AGEN-nov2016-02.pdf
76
Commission for the Control of INTERPOL’s Files – Operating Rules, CCF/100/d488 (Adopted 24 March 2017) (‘Operating Rules’)
77
CCF Statute, Article 4.
78
CCF Statute, Articles 21, 34(1), 35(3) and 40(3).
79
CCF Statute, Article 3(2)(c) and Article 38(1).
80
CCF Statute, Article 24; cf. RCI Article 8
81
CCF Statute, Article 11(4).
82
CCF Statute, Article 11(5).
83
CCF Statute, Article 15
Select target paragraph3
Connect to a paragraph
Connect to an entity
Disable highlights
Add to table of contents