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Points to Consider in Deletion, Correction and Access Requests

The effectiveness of an application to the CCF depends on submitting a consistent and well-structured file that demonstrates the principle of political neutrality through concrete evidence. In this section, we briefly explain how to build arguments focused on Article 3, how to strengthen the necessity and proportionality analysis, and how to prepare the evidence set in line with reliability and confidentiality criteria.

Points to Consider in Deletion, Correction and Access Requests

In applications to the CCF, the most fundamental point is to connect the grounds of the request concretely with Article 3 of INTERPOL’s Constitution, which prohibits the processing of matters of a political, military, religious or racial character. This provision should not be presented merely as a labelled allegation; a strong framework should be built on the basis of documents and objective indicators.

How Can Political Nature Be Demonstrated Under Article 3?

The following are strong elements supporting the argument that a case is political in nature:

examples showing that civil society activities or acts that do not constitute offences have been transformed into serious accusations such as “membership of an organisation”;

international reports concerning the lack of judicial independence and impartiality;

the applicant’s international protection or refugee status;

evidence showing that the investigation or prosecution is selective, arbitrary or retaliatory in nature.

Do Not Overlook the Necessity and Proportionality Analysis

The application should also explain, through concrete examples and documents, whether the processing of data:

goes beyond its legitimate purpose;

causes disproportionate restrictions on freedom of travel;

produces disproportionate consequences for professional reputation, income and family life;

creates practical obstacles that disrupt the ordinary course of daily life.

In the CCF’s assessment, this analysis is as important as the argument concerning political nature.

Reliability and Consistency of Evidence

A successful CCF application requires a consistent and verifiable evidence file.

For this reason, the following should be coherent with one another:

proof of identity;

the timeline of events;

official judicial documents, court decisions and prosecutorial acts;

reports of international organisations;

documents concerning asylum or protection status.

They should also not contradict statements previously made by the applicant before other institutions.

Confidentiality: Disclose Only What Is Necessary

CCF applications often contain sensitive personal information. For this reason:

the principle of “disclosure only to the extent necessary” should be followed;

only information that serves the purpose of the application should be submitted;

data that may reveal the situation of third parties should, where necessary, be protected through partial redaction;

where documents are in a foreign language, accurate and complete translations should be provided, and a translation verification note should be added for important documents.

This approach both strengthens the legal quality of the application and helps meet the evidentiary threshold required by the CCF.