The ECBA and Lawyers Against Transnational Repression (LATR) have submitted a joint response to INTERPOL’s Committee on the Processing of Data (CPD) regarding proposed amendments to the CCF Statute.

We urge INTERPOL to prioritise procedural fairness and equality of arms for individuals over new obligations for applicants.

Key Recommendations:

  • Require Specific Justifications: Member states must explain precisely why disclosure would cause harm, not rely on vague grounds.
  • Ensure Timely Disclosure: Require that evidence be shared at a stage that allows applicants to respond before a final decision is made.
  • Restore Access Rights: Reinstate pre-2017 standards allowing individuals to verify their inclusion in INTERPOL’s systems.

This submission builds on the ECBA’s February 2026 report, Safeguarding INTERPOL’s Systems: Recommendations for Reform.