GYH Contributes to CCF Statute Review
By, Dr. Ted R. Bromund
The INTERPOL Committee on the Processing of Data (CPD) is currently engaged in a review of the Statute of the Commission for the Control of INTERPOL’s Files (CCF). The Statute is the CCF’s governing legal document, and the CCF is INTERPOL’s appellate body, responsible for ensuring that personal data processed through INTERPOL complies with its rules.
As of early April 2026, the CPD has made three requests for public contributions to the CCF Statute Review. This is a sign of INTERPOL’s increasing readiness to engage with practitioners. INTERPOL is sometimes criticized for a lack of transparency, but the CCF Statute Review has had a welcome willingness to seek different perspectives.
Four representatives of GYH – Sandra Grossman Esq., Ariel Rawls Esq., Charlie Magri Esq., and Dr. Ted R. Bromund – responded to the CPD’s third request for contributions. This request focused on two articles in the CCF Statute. First, Article 34, on “Consultations.” The request posed the question of whether a revised Article 34 should expressly include applicants among those from whom the CCF may seek additional information when examining requests.
The GYH team supported the addition of applicants to Article 34 in order to formalize a practice the CCF already employs. But it emphasized that the participation of applicants should be voluntary, that confidentiality protections for applicants must be clear and consistently upheld, and that the primary responsible for providing underlying information should remain with the source country that created the data.
Second, the CPD sought input on Article 35, “Communication of Information,” asking whether the Article should be maintained, adjusted, or elaborated upon. The GYH team brought its substantial experience with the CCF to bear on this important question. One of the most frustrating aspects that clients – and attorneys – confront when applying to the CCF for relief from abusive Red Notices are the lengthy delays that have to come to characterize the process.
The GYH team pointed out that about 60 percent of now cases involve restrictions imposed by nations on communications with applicants. The lengthy back and forth around these restrictions often causes delays. The GYH team recommended that limits on these restrictions should be tighter and that a national failure to respond to inquiries from the CCF should be treated as tacit authorization to disclose information to applicants.
Finally, the GYH team argued that the CCF should not allow refusals to disclose information on grounds of national security or confidential prosecutions: the former takes INTERPOL beyond cooperation against ordinary crime to which it is limited, and the latter are forbidden under the Universal Declaration of Human Rights, which INTERPOL is bound to respect.
The GYH team was glad to be notified by the INTERPOL General Secretariat that its submission, included here, has been accepted by the CPD. GYH looks forward to continuing to contribute its expertise with the CCF to improving it for the benefit of clients who seek relief from persecutory and unjust actions through INTERPOL.
