118. Despite these examples of cases in which the Refugee Policy has been implemented to promising effect, the policy does present a number of challenges, both in terms of its implementation, and its scope. 119. The Refugee Policy is phrased as though it is intended to prevent the dissemination of INTERPOL alerts against refugees – “the processing of Red Notices and Diffusions against refugees will not be allowed if the following conditions are met…” - but in practice, this policy is most likely to be applied retrospectively as a ground for deletion of an INTERPOL alert. This is because INTERPOL is unlikely to have access to information on which people have been granted refugee status, and because of the lack of information available to individuals who benefit from this policy. This implies that in reality, many individuals with refugee status will have to suffer the impact of an INTERPOL alert – potentially facing arrest and extradition proceedings – before they have sufficient information and knowledge to challenge the existence of the alert in line with the Refugee Policy. 120. INTERPOL encourages Member States to share information about the grant of refugee status proactively, so that it can implement this policy effectively by identifying those who benefit from this policy. However, information regarding the grant of refugee status is rightly treated by many Member States as sensitive and confidential, and NCBs may rightly be reluctant to share this information INTERPOL, especially without the consent of the individual concerned. 121. The sensitivity of sharing this information systemically with INTERPOL is exacerbated by the fact that the General Secretariat includes staff seconded from Member States. We have been assured that 56 information about the grant of refugee status is handled confidentially, so that sensitive information does not end up in the wrong hands. However, many refugees may nevertheless have very understandable reservations about having information about them shared with a policing organisation whose role it is to share information between police forces, including those of the country they have fled. 122. We believe that even despite these challenges, INTERPOL and the CCF should take proactive steps to identify individuals who are already on INTERPOL’s databases that fall within the Refugee Policy. We recognise that given the constraints on INTERPOL’s resources, as well as challenges regarding confidentiality, this is no easy task. However, this is necessary because of the difficulties that individuals face in requesting INTERPOL to apply the Refugee Policy in their cases. 123. The Refugee Policy, which is included as an annex to this report, can be found in full on Fair Trials’ website, but it remains nowhere to be found in any of INTERPOL’s official publications or on its website. Fair Trials and various legal practitioners have tried to raise awareness of this policy, but it is unsatisfactory that individuals are only able to find confirmation that such a policy exists through secondary sources. The lack of adequate information about this policy prevents the vast majority of refugees subject to INTERPOL alerts from making use of this crucial policy that could significantly bolster their protection from persecution. 124. Despite the challenges in accessing information about the Refugee Policy, we are aware that some individuals with refugee status have been in touch with the General Secretariat or the CCF to notify the organisation of their status with the intention of preventing the dissemination

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