How to Apply to the Commission for the Control of INTERPOL’s Files (CCF) for Access, Correction and Erasure?

What Is the CCF and What Powers Does It Have?

The CCF is an independent body that oversees the protection of personal data and the safeguarding of fundamental rights in INTERPOL’s international police cooperation. It has two separate chambers:

• Supervision and Advisory Chamber: Reviews INTERPOL’s personal data processing activities in general, works in coordination with the Data Protection Officer, and gives advisory opinions to the Organization.
• Requests Chamber: Examines and decides on requests from individuals or legal entities for access to data, correction or erasure of data, and reconsideration of a decision.

Under the CCF Statute, decisions of the Requests Chamber are final and binding on the INTERPOL General Secretariat and on the National Central Bureaus (NCBs) of member countries.

For the general framework of INTERPOL notices, CCF review and the extradition process, see our guide INTERPOL and Red Notices: What Are They?.

The Limits of the CCF’s Powers and How It Differs from Courts

The CCF is neither an international criminal court nor a human rights court. Accordingly, the CCF:

• Does not conduct criminal investigations, establish the material facts or hear witnesses.
• Cannot annul, on procedural or substantive grounds, an arrest or detention order issued by a national judicial authority.
• Cannot order the physical release of a person held in custody.
• Cannot stop an extradition by examining an asylum claim of the person sought.
• Cannot award material or non-pecuniary damages for an unjustified registration.
• Cannot provide persons with a travel document valid internationally or a substitute for a passport.

The central question before the CCF is this: Is the processing and circulation of the relevant data in the INTERPOL Information System lawful under the INTERPOL Constitution (in particular Articles 2 and 3) and the INTERPOL Rules on the Processing of Data (RPD)?

Categories of Data Subject to CCF Review

The review is not limited to publicly visible Red Notices. All of the following may be subject to CCF examination:

• Red Notice: Requests to locate persons wanted for extradition or for arrest.
• Wanted Person Diffusion (diffusion for arrest): Rapid search requests circulated directly between countries or through INTERPOL channels.
• Blue Notice: Records aimed at collecting information on a person’s identity, location or connection with a criminal investigation.
• Green Notice: Warning records on the basis that a person may pose a threat to public safety.
• Yellow / Black / Orange Notices: Missing persons, unidentified bodies or security threats.
• Stolen and Lost Travel Documents (SLTD): Database records of stolen and lost travel documents.
• Associated police data: Identity details, passport details, fingerprints, DNA data and linked person or company registrations.

Important Warning: The absence of your name from the search engine on INTERPOL’s public website does not mean that there is no Red Notice or Diffusion concerning you. Most Red Notices, and all Diffusions, are processed in the closed police network.

The Limit on Direct NCB-to-NCB Information Sharing

Under the INTERPOL legal framework, intelligence shared directly and bilaterally between the National Central Bureaus (NCBs) of member countries, without using the INTERPOL infrastructure, is as a rule outside the CCF’s supervisory powers.

However, if a bilateral data exchange seriously violates the principles of Article 3 of the INTERPOL Constitution (political, military, religious or racial character) or Article 2 (human rights), and the matter reaches the INTERPOL Information System (WIS) through the General Secretariat or the Notices and Diffusions Task Force (NDTF), the CCF may intervene.

CCF Application Types and Strategic Choice

Application Method: The 26 March 2026 Online Portal Procedure

As of 10:00 CET on 26 March 2026, new CCF applications by e-mail, fax or post are no longer accepted. All applications are submitted digitally through the CCF Secure Online Portal.

Portal Operation and Record Security

The process conducted through the portal follows these standard steps:

1. Account and Verification: The applicant or their representative creates a portal account with a secure e-mail address that has two-factor authentication (2FA).
2. Data and Document Upload: The form steps are completed, and identity documents, the power of attorney and evidence are uploaded to the system.
3. Dossier Reference: As soon as the submission is confirmed, the system automatically generates a dossier reference number for tracking.
4. Case Tracking and Correspondence: Requests for further information from the CCF Secretariat, admissibility decisions and final decisions are notified through the portal dashboard.

In exceptional cases, where the portal is technically unavailable, the use of alternative means of submission under Article 25(2) of the CCF Operating Rules is subject to the prior approval of the CCF Secretariat.

Form and Admissibility Requirements of a CCF Application

The CCF Requests Chamber first examines the formal requirements of a file under strict rules before turning to the merits. Failure to meet any one of them leads to rejection for inadmissibility.

1. Identity and Clarity Requirement

• The applicant’s full name, place and date of birth, nationality and a valid copy of the passport must be provided in full.
• Variations in names (different spellings in Cyrillic, Arabic and Latin scripts), surnames changed through marriage or divorce, and travel documents issued on the basis of refugee status must be expressly stated. The identity document must be unredacted and in high resolution.

2. Language Requirement

• The application and the supporting explanations must be prepared in one of INTERPOL’s official working languages: English, French, Spanish or Arabic.
• Turkish court decisions and official documents must be translated into a working language by a certified translator, and the original and the translation must be matched.

3. Power of Attorney and Right of Representation

• Where the application is made through a lawyer or another authorized representative, a CCF Special Power of Attorney must be attached.
• The power of attorney must clearly state the representative’s full identity, the applicant’s wet or secure electronic signature, authority to act before the CCF, and the “authority to receive and access personal data held in the INTERPOL Information System”.
• Representatives may apply on behalf of minors with a parent or guardian, or on behalf of persons under guardianship with a court decision appointing a guardian. For legal persons, the application must include the registration certificate, the trade registry gazette and a signature circular showing authority to represent the legal person.

4. The 10-Page Statement of Reasons and the Index of Annexes (2026 Rule)

Under the CCF Operating Rules that entered into force on 26 March 2026:

• The legal statement of reasons in a correction, erasure or reconsideration application may not exceed 10 pages (in standard font and size).
• All evidence submitted with the application must be listed in an “Index of Annexes”, and each legal claim in the statement of reasons must refer to the relevant annex number.

5. Accepted File Formats

The portal supports only PDF, DOC, DOCX, XLS, XLSX, CSV, TXT, RTF, HTML, JPG, JPEG, PNG and GIF files. Audio and video files are not accepted. Audio or video evidence must be uploaded as a transcript prepared by an expert or as an approved text.

6. Prohibition on Direct Contact with Commission Members

Attempting to reach CCF members or the Secretariat individually by e-mail, letter or telephone is prohibited. Such attempts may be treated as an abuse of process (abuse of process) and may lead to the application being rejected.

Legal Reasoning and Core Grounds

CCF erasure applications must be matched directly to INTERPOL’s norms and principles of international law, not to abstract claims.

                          ┌─────────────────────────────────────────┐
                          │   INTERPOL LEGAL REVIEW FRAMEWORK       │
                          └────────────────────┬────────────────────┘
                                               │
         ┌─────────────────────────────────────┼─────────────────────────────────────┐
         ▼                                     ▼                                     ▼
┌──────────────────┐                  ┌──────────────────┐                  ┌──────────────────┐
│  CONSTITUTION    │                  │  CONSTITUTION    │                  │  DATA QUALITY    │
│  ART. 3          │                  │  ART. 2          │                  │  Proportionality │
│  Political,      │                  │  Human rights &  │                  │  & valid decision│
│  military, re-   │                  │  refugee rights  │                  │                  │
│  ligious, racial │                  │                  │                  │                  │
└────────┬─────────┘                  └────────┬─────────┘                  └────────┬─────────┘
         │                                     │                                     │
         ▼                                     ▼                                     ▼
- Dissident profile                    - Risk of torture                    - No arrest warrant
- Criminalising a commercial dispute   - Refugee status (non-refoulement)   - Acquittal / limitation
- Ordinary crime vs. political test    - Breach of fair trial               - Extradition impossible

1. INTERPOL Constitution Article 3 (Prohibition of Political, Military, Religious and Racial Activity)

Article 3 of the INTERPOL Constitution strictly prohibits the Organization from undertaking any intervention or activity of a political, military, religious or racial character.

• Ordinary Crime – Political Element Test (Dominant Character Test): Even where the alleged act is apparently an ordinary criminal offence (for example fraud, tax evasion or forgery of documents), the CCF examines the “dominant character” of the act if the background to the investigation includes political motives, the person’s dissident identity, an aim of seizing a businessperson’s assets, or a clash with the government.
• CCF Decision Example (Excerpt No. 4/2023): The Commission examined the temporal connection between the applicant’s membership of an opposition party, media statements criticising the government and the sudden emergence of the charge. It found that the registration was contrary to Article 3 of the Constitution and ordered its erasure.

2. INTERPOL Constitution Article 2 and Human Rights Violations

Article 2 requires that INTERPOL’s activities be carried out in the spirit of the Universal Declaration of Human Rights.

• Refugee Status and the Principle of Non-Refoulement: Under the 1951 Geneva Convention, a red notice issued by the country of origin in order to have a person with refugee status or subsidiary protection returned by the country of refuge is prohibited under the INTERPOL Rules on the Processing of Data (RPD, Article 53).
• Risk of Torture and Unfair Trial: Where the requesting country has systematic torture, inhuman prison conditions or no independent judiciary, the registration becomes unlawful.

3. Data Accuracy, Currency and Proportionality Principles (RPD Articles 12 and 34)

• No Valid National Arrest Warrant: A Red Notice must be based on a current arrest warrant issued by a competent court of the member country. Where that warrant is annulled, withdrawn or has become time-barred, the data must be erased without delay.
• Acquittal and Non-Prosecution: Where an acquittal, a decision of non-prosecution (KYOK) or a discontinuance of the case has been issued in the source country or in another country and has not been recorded in the INTERPOL system, the registration becomes unlawful.
• Purpose and Proportionality: Where the source country knows where the person sought is located (for example, the person lives at a known residential address and is in contact with administrative authorities), and the source country has not made an extradition request or taken any action for years, this shows that the Red Notice has lost its legitimate purpose of police cooperation.

Precedents and Legal Effects

In CCF applications, decisions of international and national judicial bodies form the backbone of the legal argument. Their characterization and status are set out below:

1. Court of Justice of the European Union (CJEU) Decision

• CJEU Grand Chamber, WS v. Bundesrepublik Deutschland, C-505/19 (12 May 2021):
  • Characterization: A binding decision under EU law and Article 54 of the Convention Implementing the Schengen Agreement.
  • Legal Effect: Where a person has a final judicial decision in one Schengen member state for the same act (or the sentence has been served or pardoned), other Schengen countries may not, under the ne bis in idem principle (no one may be tried twice for the same act), arrest the person even temporarily on the basis of that Red Notice. The CJEU decision is the strongest ground for showing in a CCF application that the record is ineffective across the entire Schengen area and must be erased.

2. European Court of Human Rights (ECtHR) Decisions

• ECtHR, Liu v. Poland, App. No. 37610/18 (6 October 2022):
  • Legal Effect: The applicant, arrested in Poland at the request of China on the basis of a Red Notice, was found to face a violation of Article 3 ECHR (prohibition of torture) if returned to China. The Court held that a Red Notice does not remove the obligations of the states parties under the human rights conventions to which they are bound, and that the requested state is obliged to examine the risk of ill-treatment independently.
• ECtHR, M.C. v. Türkiye, App. No. 31592/18 (4 June 2024):
  • Legal Effect: The Court emphasised that arrests and detentions based on Red Notices must be foreseeable under Article 5 ECHR (right to liberty and security), must take place within a reasonable time, and must be subject to effective judicial review. Automatic arrest by national authorities based solely on a Red Notice record would constitute a violation of the Convention.

3. Constitutional Court (AYM) Individual Application Decisions

• AYM General Assembly, S.K., Application No. 2018/24280 (17 March 2021):
  • Legal Effect: This decision sets the constitutional limits (Article 19 of the Constitution) on deprivation of liberty for the purpose of extradition. It states that the period a person is held in custody during extradition proceedings must be proportionate, that the concrete evidence in the extradition file must be reviewed, and that detention must be lifted immediately where extradition has become impossible.
• AYM, Oktay Şener, Application No. 2020/9407 (3 March 2022):
  • Legal Effect: It holds that in provisional detention and administrative measures aimed at extradition, based on a diffusion message, the person must be granted an effective right of application (Articles 40 and 19(8) of the Constitution), and that national authorities may not act without reviewing the legal basis of the diffusion record.

4. Turkish Administrative Justice and Council of State (Danıştay) Precedents

• Council of State (Danıştay) 10th Chamber, established precedents (administrative review of NCB records in Türkiye):
  • Legal Effect: Records entered into the national system by the Interpol Department of the NCB at the General Directorate of Security of the Ministry of Interior concerning Turkish citizens or foreign nationals, along with restriction notes and administrative measures, are administrative acts with executory effect (icrai idari işlem). According to the settled case law of the Council of State 10th Chamber, where an application to the General Directorate of Security for deletion of administrative records based on an international notice or diffusion is rejected, an action for annulment may be brought before the administrative courts. Once a CCF erasure decision has been taken, judicial review of the administrative process is necessary if the records within the General Directorate of Security are not erased.

CCF Review Periods and Process Map

In CCF applications, the start of the time periods must not be confused. The one-month admissibility period runs from the date on which the application is received by the portal, while the periods for the substantive decision run from the date on which the application is declared admissible.

[Portal Application]
        │
        ▼
[1 Month: Admissibility Review]
        │
        ├── Refusal ───► [File Closed (Inadmissible)]
        │
        └── Accepted ──► [Merits Review Begins]
                            │
                            ├──► [45 Days: NDTF / GS Data Report]
                            ├──► [4 Months: Access Decision]
                            └──► [9 Months: Correction or Erasure Decision]
                                        │
                                        ▼
                     [1 Month: Transmission to General Secretariat]
                                        │
                                        ▼
            [1 Month: Daily/Weekly Erasure Notice to National NCBs]

Urgent Applications and the Provisional Measures Mechanism

Where the applicant faces a concrete and imminent risk of arrest, extradition, deportation or a health risk, a provisional measure may be requested from the CCF.

• Conditions for a Provisional Measure: The risk of an upcoming journey alone does not amount to urgency. A flight ticket, notice of a hearing date, an administrative detention order or extradition court documents must be submitted.
• Content of a Provisional Measure: Pending the review, the CCF may impose a restriction on access to the applicant’s record (blocking). Once this restriction is imposed, member countries cannot see the record on their search screens.

Legal Limit: A provisional measure issued by the CCF does not automatically suspend an arrest order issued by a court in the country where the person is located, or an extradition case. For this reason, a provisional measure decision must be submitted to the court in the national proceedings, and release or interim measures must be requested there.

Enforcement of CCF Decisions and Administrative and Judicial Follow-up

A CCF decision to erase or correct data does not end the process automatically. The decision must be followed up at several levels:

1. Erasure from INTERPOL Databases and Certification

The General Secretariat erases the record from the main database in accordance with the CCF decision. The National Central Bureaus of member countries are informed through daily updates. At the applicant’s request, the INTERPOL Legal Affairs Directorate issues an official Certificate confirming that the person is not sought in the INTERPOL system.

2. Cleaning National Records (EGM NCB) and Regional Databases

A CCF decision does not automatically remove the national arrest warrant of the source country or its entries in the Schengen Information System (SIS II).

• EGM NCB Procedures: In Türkiye, an administrative application must be made to update the records held by the Interpol Department of the General Directorate of Security. If it is rejected, an action must be brought before the administrative court in line with Council of State case law.
• Bank and Compliance Records: To correct the perception of a Red Notice in financial screening systems such as World-Check and LexisNexis, the CCF erasure decision and certificate must be submitted to the relevant institutions.

Common Application Mistakes

1. Treating the CCF as a criminal court: Only asserting that one is innocent, without showing that INTERPOL’s rules have been breached.
2. Exceeding the 10-page limit: Submitting scattered text across pages, contrary to the 2026 rule.
3. Failing to prepare an index of annexes: Uploading exhibits to the system without numbering them and matching them to the statement of reasons.
4. Confusing a residence permit with refugee status: Assuming that a residence permit has the same legal effect as refugee status under the Geneva Convention.
5. Submitting summaries of court decisions: Providing only the first page of a court decision instead of the full reasoned text and the certificate of finality.
6. Applying outside the portal: Losing time by sending applications by e-mail or post.
7. Relying solely on the CCF decision: Neglecting arrest and extradition proceedings in the country where the person is located and failing to use the local legal remedies.

Güneş & Güneş Law Firm CCF Application Protocol

Güneş & Güneş Law Firm handles INTERPOL CCF applications not merely as a form-filling exercise, but as a defence strategy integrating international law, extradition law and administrative law:

• Risk and Record Identification: Preliminary research to determine the nature of the record (Red Notice, Diffusion, SLTD) and the travel risks.
• Legal Reasoning: Preparation of a 10-page statement of reasons compliant with INTERPOL Constitution Articles 2 and 3 and the RPD, together with the Index of Annexes.
• Portal Management: Submission through the CCF Secure Portal in accordance with the 26 March 2026 procedure, and tracking of the dossier reference.
• Integration of Precedents: Directly linking the decisions of the CJEU, ECtHR, AYM and Council of State to the concrete case and incorporating them into the file.
• National Follow-up After Erasure: Carrying out the administrative and judicial processes needed to clear EGM NCB records, passport restrictions and national databases after an erasure decision.

Operating from Antalya since 1999, our firm represents clients in disputes arising from international police cooperation and data protection law, in Turkish, English, German and Russian.

Frequently Asked Questions

Is a CCF application subject to fees or charges?

No. An application to the CCF is entirely free of charge. However, lawyers’ fees, legal translation, apostille and certification costs are borne by the applicant.

Is there a right of appeal against a CCF decision?

CCF decisions are final and binding; there is no classic appellate body. However, if a new fact emerges after the decision that may affect the outcome, a Reconsideration application may be made within 6 months.

If my name does not appear on the public list, am I not being sought?

No. Most Red Notices and all Diffusions are processed in a closed system. The absence of your name from the website does not prove that there is no record about you.

Does a CCF application stop the extradition or arrest process in my case?

No. A CCF application does not automatically stop the arrest or extradition process before the national court. In urgent cases, a Provisional Measure should be requested from the CCF, and this should be notified to the extradition court.

If I am acquitted, is my Red Notice deleted automatically?

No, it is not deleted automatically. The acquittal must be notified to INTERPOL by the NCB of the source country and the record updated. If this has not been done, a correction or erasure application should be submitted to the CCF.

Sources and legal bases

INTERPOL and CCF Official Legislation

• CCF Secure Online Portal (current application channel)
• Statute of the Commission for the Control of INTERPOL's Files
• CCF Operating Rules — 26 March 2026 Edition
• Constitution of the ICPO-INTERPOL (Articles 2 and 3)
• Rules on the Processing of Data (RPD)

Court Decisions

• CJEU Grand Chamber, WS v. Bundesrepublik Deutschland, C-505/19, 12.05.2021
• ECtHR, Liu v. Poland, App. No. 37610/18, 06.10.2022
• ECtHR, M.C. v. Türkiye, App. No. 31592/18, 04.06.2024
• AYM General Assembly, S.K., Application No. 2018/24280, 17.03.2021
• AYM, Oktay Şener, Application No. 2020/9407, 03.03.2022