Candidates Announced for Election to Commission for the Control of INTERPOL’s Files (CCF)
INTERPOL has released the list of candidates deemed eligible by the INTERPOL Executive Committee to be elected to the Commission for the Control of INTERPOL’s Files (CCF).
The CCF is charged with three primary duties and is divided into two chambers. Its overall job is to ensure “all personal data processed through INTERPOL’s channels conforms to the rules of the Organization.” The Supervisory and Advisory Chamber, which has three members, is inward-facing: it reviews and advises on INTERPOL’s data processing. The Requests Chamber, which has five members, is outward-facing: it examines requests from individuals who seek to access, correct, or delete information held by INTERPOL. While both Chambers play an important role, the Requests Chamber examines and potentially deletes abusive Red Notices, making it the Chamber of the widest interest.
The CCF has seven members, with a chair who heads both Chambers. The current chair is Teresa McHenry of the United States. The other members of the Supervisory and Advisory Chamber are from Belgium and Tunisia; the other members of the Requests Chamber are from Lebanon, Morocco, the U.K., and France. All members of the CCF serve a five-year term, renewable for one three-year term. The current members of the CCF were elected in 2022; hence, all their terms expire in 2027, and elections will be held to fill their positions in 2026, at the General Assembly to be held in Hong Kong from November 30 to December 3, 2026.
The CCF has a challenging job. Because it has the duty – on occasion – of telling INTERPOL’s member states that they have broken its rules, it is not universally popular. It suffers from serious delays, and is currently undergoing a review of its Statute, a review that bears on INTERPOL’s legal immunities and which has already resulted in several amendments to the CCF Statute, not all of which were desirable. But it is also important to note that the quality of CCF decisions and the efficiency of the CCF itself have risen dramatically under Chair McHenry’s leadership and that – unlike in previous eras – the integrity of the current CCF has not been questioned.
INTERPOL’s transparency in announcing the approved slate of candidates to fill the CCF positions and the information it has provided in a supplementary note about the election process is commendable. INTERPOL often – and fairly – takes heat for a lack of transparency, but its treatment of the CCF elections is a step in the right direction. It would be preferable if INTERPOL gave some indication – a numerical one, as it is likely unwilling to name names – of the number of potential candidates rejected by INTERPOL’s Executive Committee: this selection process is one of the aspects of INTERPOL’s control of the CCF that in practice reduces the CCF’s independence. But even so, INTERPOL has done a better job this time around on providing information about the CCF elections than it has ever done in the past.
Of the 20 candidates, five – including Chair McHenry – already sit on the Commission. The job requirements of positions on the Chambers, and the limits on national representation – no nation can have more than one of its nationals on the CCF – mean that some candidates have better odds of being elected than others: there are, for example, only two potential members with data protection expertise to be selected for a single position, whereas there are six lawyers who have held “a senior judicial or prosecutorial position” competing just one job. Unlike INTERPOL’s Executive Committee, which mandates wide geographical representation, the CCF’s requirements focus on qualifications and expertise. Finally, while not all the approved candidates are from nations with a strong rule of law, there are no candidates from nations – like Russia or Belarus – that are currently under INTERPOL corrective measures.
The election of the new (or returning) CCF members is of vital importance. The CCF Statute review is also central, but no system can work absent qualified and dedicated members of high integrity. The CCF is vital to INTERPOL’s own legal standing, as well as to the individuals that Grossman Young & Hammond advocates for who are facing persecution through INTERPOL. The CCF elections will be one of the most important – if not the single most important – parts of the next General Assembly, and Grossman Young & Hammond, like everyone with an interest in INTERPOL and INTERPOL reform, will follow them closely.
