Updated on
May, 23 2024
Konstantina Zivla
Written by

INTERPOL’s CCF Data Compliance Challenges in 2022

1923-2023: A century of INTERPOL’s operations. INTERPOL (central bureau in Lyon, France) is revered globally for fostering international police cooperation. Yet, despite its vast network spanning 195 member countries, INTERPOL is called to address significant challenges in maintaining the integrity of its data—a cornerstone for effective international law enforcement.

In its Report for 2022, the Commission for the Control of INTERPOL’s Files (CCF), an independent body tasked with ensuring the legality and compliance of data, revealed statistics about the Organization’s struggles with data accuracy. Out of 470 admissible complaints reviewed, 271 cases were deemed non-compliant with INTERPOL’s rules after a thorough examination. This figure starkly contrasts with the 124 cases found compliant, raising questions about INTERPOL’s effectiveness in adhering to its legal framework, specifically under Article 83 of INTERPOL’s Rules on the Processing of Data (RPD), which mandates data accuracy.

Hence, what is the root cause of such a critical divergence in compliance? Is it a more profound, systemic issue within INTERPOL’s data management practices? The CCF’s report findings shed light on the fact that the non-cooperation of the NCBs complicated the matter, and 75 cases were closed due to such non-cooperation, undermining the validity of the proceedings. It also highlights the critical problem of Lyon’s reliance on local NCBs for data accuracy and validation. This highlights a crucial challenge: Lyon’s dependence on NCBs for data accuracy and verification. This credit and level of trust on the part of INTERPOL towards National Central Bureaus is not justified, meaning that Lyon should apply more rigorous scrutiny to the requests for Red Notices’ publication coming from the NCBs, not taking anything for granted.  

INTERPOL’s data quality issues are more than mere numbers; they are issues affecting real human lives and justice systems. Every non-compliant record equals a wrong listing, thus potentially unjustly restricting an individual’s freedom of international travel and tarnishing their reputation. INTERPOL Red Notice can also devastate career, relations with banks, and residence in a foreign country. Such consequences could have severe implications for the legitimacy and efficiency of international policing cooperation, which has been seriously exposed recently. 

Another notable conclusion from the CCF Report 2022 is the lack of international cooperation on the part of certain NCBs. As the Report indicates, “a total lack of cooperation from the NCB(s) source of the data” necessitated the dismissal of 75 cases. Closing such a high number of cases due to NCBs’ non-cooperation highlights a critical obstacle in international collaboration within INTERPOL’s system. Therefore, INTERPOL’s challenge in ensuring cohesive and effective law enforcement cooperation can result in substantial gaps in global justice and security operations.

How can INTERPOL fulfil its mission if national entities fail to support investigations adequately? 

This lack of cooperation is more than a mere bureaucratic hiccup; it reflects deeper systemic issues that can erode trust and efficiency within international law enforcement networks. When NCBs fail to confirm the validity of data proceedings for notices or diffusions, it forces the CCF to terminate the review and satisfy complaints for data removal without further examination of the applicant’s arguments, as seen with the 75 closed cases. 

Taken altogether, we conclude that as INTERPOL reached 100 years of its activity, it stands at a crossroads. Will it evolve in response to the challenges of modern data management, or will it continue to be hampered by systemic issues of non-compliance and cooperation? This examination concludes that the Organization must “comply with its own rules and also ensure that it does so in the spirit of human rights standards” to strike a delicate balance required of an organization that should effectively solve crime and has a deep respect for individual rights. The choice may define its influence and nature as powerful in global crime fighting.

The question then remains: how can INTERPOL do better? 

Ultimately, increasing transparency about the data handling process and enforcing accountability is crucial. Besides, evidence shows that strict compliance and a robust oversight mechanism are needed to ensure that countries comply with quality standards. In addition to the above-mentioned policies, INTERPOL should improve its technological infrastructure to handle vast amounts of data efficiently as the Organization approaches its centennial. Finally – more tedious scrutiny of the requests submitted by the NCBs is required on the part of Lyon, not to let the data be inappropriately disseminated via Interpol’s Information System in the first place if such data lacks the defined criteria, or a “crime” in question does not amount to be of interest for international police cooperation. 

  • Develop Predictive Analytics Tools: Proactively use predictive analytics to identify patterns that might highlight data integrity issues before they become systemic. This could also maintain the current high level of data accuracy. 
  • Establish a Data Integrity Role: Create new positions in all NCBs and in the CCF that will be solely responsible for data integrity and will constantly monitor and enhance data quality in their respective offices. 
    • Annual Compliance and Integrity Conference: Hosting an annual conference reporting on Data Compliance and Integrity would bring an interested group of professionals worldwide to discuss their achievements and the latest trends, innovations, and updates in this field. 
  • Enhanced Training and Standardization for NCBs: Develop and launch a comprehensive training program for NCBs on data compliance and integrity, focusing on the importance of appropriate data entry, maintenance, and compliance with INTERPOL’s legal framework. 
  • Develop a standard protocol for the data-entry process for each NCB and CCF to make the process streamlined and foolproof.
  • Strengthening Verification Process: A robust verification system can automatically run the auditing process on the data placed by the NCBs. However, technology can play a vital role in this regard if supported by professionals from the CCF. Grow a system of regular audits and quality checks on the data managed by NCBs to see the standard of compliance.
  • Fostering Better Cooperation and Accountability: Enact penalties and corrective measures for repeated non-compliance by NCBs and their responsible officers who are unwilling to verify the data compliance or fail to do so properly. Forge an avenue for NCBs to easily report their concern and let them know that their Report would be made available to those who matter. 
  • Regular Review and Update: Regularly review INTERPOL’s RPD to meet new challenges. Create an international forum for all NCBs and legal experts to have regular updates on the compliance standards and their observance. 
  • Public Transparency: Regularly release anonymised data of compliance statistics and audit results for public knowledge and trust. A civil, independent body of legal and human rights experts should be able to audit the Organization’s data-handling system and its efficiency. 

The path to improving INTERPOL’s operations demands bold and consistent actions: enforcement of data standards and unwavering accountability. 

Will INTERPOL fulfil its goal of upholding a legacy of effective international policing while safeguarding individual rights? 

The answer will shape its future influence and credibility.

Konstantina Zivla
Konstantina Zivla
Konstantina Zivla is a prominent legal professional, admitted to the Cyprus Bar Association.
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