A change in Interpol's data-retention approach

Every week a notice remains on file, the data it contains becomes more entrenched. As of mid-2025, practitioners before the Commission for the Control of INTERPOL's Files (CCF) are observing a discernible shift in how INTERPOL approaches the retention and periodic review of personal data held within its systems. If your name appears in those systems, this development is directly relevant to your position.

A change in INTERPOL's data-retention approach means that the conditions under which data is kept – and the triggers that prompt its review – are being applied with greater consistency. The RPD's data-accuracy and retention requirements have always obliged INTERPOL to assess whether data remains necessary and proportionate. What practitioners are now seeing is that standard applied more rigorously in practice, which cuts both ways: it can accelerate deletion where the underlying file is weak, but it can also entrench data where the file appears substantiated.

Below: what has changed, who is most affected, and the practical steps that follow.

What has changed in INTERPOL's data-retention practice?

The RPD's retention branch has always required that data be kept only for as long as it remains necessary for the purpose for which it was recorded. What is shifting is the operational weight given to that requirement. In our CCF practice, we are seeing more frequent periodic-review triggers, with national bureaux being asked to reconfirm the currency and accuracy of underlying files. Where a bureau does not respond or cannot substantiate the original request, the data becomes vulnerable to deletion.

This is not a formal rule change announced by a single decision. It is a consolidation of the RPD's data-quality obligations into more consistent enforcement. The distinction matters. There is no single document to point to; the change is visible in the pattern of outcomes and in the requests being made of submitting bureaux.

For individuals under a Red Notice or a diffusion, the practical effect is that the file does not simply age quietly. It is periodically tested against the standards it was meant to meet at the outset.

Who is most affected by this development?

The individuals most exposed are those whose notices originate from states with prosecutorial systems that tend to issue charges for purposes other than legitimate criminal enforcement. Where the underlying prosecution is politically motivated, where the charges have since been dropped or amended, or where the individual has been granted asylum or refugee status in a third state, the periodic-review mechanism creates a genuine opening.

A diffusion – an alert circulated directly by a national bureau, outside the formal notice system – is equally subject to the RPD's data-accuracy requirements and can also be challenged before the CCF. Individuals who are aware only of a diffusion, and not a formal Red Notice, are not exempt from this analysis.

You cannot simply wait for a notice to expire on its own. The RPD does not set a universal fixed expiry date that operates automatically; retention review is procedural and requires engagement. Every week the notice stands, the underlying file hardens and the argument that data is no longer necessary becomes harder to make if it is not actively pressed.

What should you do now?

The immediate priority is to understand what INTERPOL actually holds about you. An access request to the CCF – to be answered, under the applicable rules, within four months of admissibility – reveals what data is processed and under which national bureau's authority. Without that information, any challenge is built on assumption.

Once the file is known, the question is whether the data meets the RPD's accuracy and necessity standards, and whether Article 3 of INTERPOL's Constitution – which bars processing linked to offences of a political, military, religious or racial character – or Article 2, which requires respect for human rights, provides a substantive ground. If it does, a deletion request can be filed. Under the CCF's applicable rules, a deletion request is to be decided within nine months of being found admissible. There is no appeal against a CCF decision, which is why the quality of the initial file is not a detail to be optimised later.

The steps that follow the access request are sequencing decisions. Building the argument before filing – not after – is the discipline that separates a file that succeeds from one that fails and closes the door on a later review.

The steps above are the general picture. Your position turns on the specific data held, the requesting state, and the timing of any prior submissions – which is precisely what a confidential first assessment looks at. To understand your exposure before you act, contact us at info@northlarkfirm.com.

Related

• Red Notice removal – build the CCF file and press for deletion at source
• CCF review – where a first request produced a refusal, identify new grounds
• Monitoring – track changes to the data INTERPOL holds about you

Frequently asked questions

What are my options from here?

The principal options are an access request – to confirm what data INTERPOL holds – followed, where grounds exist, by a deletion or correction request before the CCF. Where a notice interacts with extradition proceedings, a parallel track in the country of detention may be necessary. The right sequence depends on what the file contains, the requesting state's position, and whether any prior CCF submissions have been made. Each route is assessed on the specific facts before any submission is filed.

How long might this take?

An access request is to be answered within four months of admissibility; a deletion request within nine months. In practice, delays occur – particularly at the admissibility stage and during bureau exchanges. The overall timeline from initial submission to a CCF outcome commonly extends beyond the procedural target, and any parallel extradition track runs to its own national timetable. We give realistic timeframe assessments as part of an initial review, not standardised projections.

What decides the outcome?

The quality of the initial file is the single most significant variable. A weak first submission lowers the prospects on any subsequent review, and there is no appeal against a CCF decision. What works is evidence, not assertion: documented political character in the prosecution, a verifiable data defect, refugee or asylum status, ne bis in idem, or lack of dual criminality where extradition is also in question. The RPD's data-accuracy requirements give the CCF the tools to act; the file gives them the reason to.

About NORTHLARK

NORTHLARK is an independent international boutique focused on INTERPOL Red Notice and diffusion challenges before the CCF and in related extradition proceedings. We are fully independent – with no affiliation to any network or parent firm – which matters particularly where a notice originates from a state whose legal system is itself under scrutiny. We work in the language of the file and of the requesting state, and our practice spans clients across multiple jurisdictions. We act only on lawful mandates and do not assist anyone seeking to evade legitimate justice; we take on a matter only where we see genuine grounds.

The first assessment is confidential. Our enquiry form does not require your real name, and you can reach us through a secure channel – Signal, Telegram or WhatsApp. To discuss your position honestly and without obligation, write to info@northlarkfirm.com.