Table 2: Impact of Fair Trials’ recommendations on CCF Reform Area of reform Proposal Action 1. Composition and structure Divide CCF into three entities – Data Protection Office, Complaints Committee, Appeals Panel Divided CCF into two entities – Supervisory and Advisory Chamber and Requests Chamber Ensure sufficient expertise Improved requirements for CCF expertise 2. Funding Ensure adequate funding to implement reforms. CCF given more control over its budget and General Secretariat no longer has control 3. Unrepresented applicants Make more information available to the public Revised CCF website 4. Data access requests Presumption of disclosure when individuals know about the INTERPOL alert General presumption of disclosure subject to limitations introduced Introduce specific timeframes Deadlines for responding to requests introduced Introduce sanctions for NCBs which fail to comply No change Improve transparency Presumption of disclosure subject to limitations introduced Introduce specific timeframes Deadlines for responding to requests introduced Oral hearings where appropriate Oral hearings where necessary (rather than only in exceptional circumstances) 6. Complaints procedure Reasoned, binding and public decisions All introduced through CCF Statute 7. Appeals Introduce right to appeal No change 8. Remedies Interim remedies where NCBs do not comply with CCF directions No change Robust requirements for CCF to notify all NCBs of deletion No change Limitations on use of addenda in lieu of deletion No change Inclusion of addenda on public INTERPOL alerts No change 5. Complaints procedure 52 Verdict