Deletion of data from INTERPOL’s information system does not automatically remove related information from commercial screening databases used by banks and other organisations. This Observatoire ARGA report examines what happens to such information following a decision of the Commission for the Control of INTERPOL’s Files (CCF) and which legal tools can be used to address outdated or incorrectly presented status information.

The central problem arises when past and present are conflated. A statement that an INTERPOL notice once existed may remain historically accurate. However, a claim that a person is currently wanted through INTERPOL requires up-to-date substantiation. Even a factually accurate historical entry may become incomplete or misleading for current screening if the commercial profile fails to reflect the subsequent deletion of the notice.

The report examines the rights available under the GDPR, including access to personal data, rectification of inaccuracies, completion of incomplete information, erasure where the relevant grounds exist, restriction of processing during verification, objection to certain processing and notification of recipients following corrections. It explains why a demand to “erase everything” is not always the most effective approach: in many cases, identifying the specific inaccurate field, documenting the changed status and requesting a precise correction provides a stronger legal position.

Separate sections analyse World-Check and WorldCompliance, their publicly stated procedures and the allocation of responsibility between screening providers and banks. Correction of a provider’s profile does not establish that a bank has updated its own copy or reconsidered its decision. Each level of the information chain therefore requires separate verification.

ARGA proposes assessing the outcome at four levels: whether the underlying INTERPOL status has changed, whether the commercial profile has been corrected, whether relevant recipients have been notified, and whether the record held by the organisation actually using the information has been reviewed.

The report’s central conclusion is that a CCF decision is important evidence of a changed information situation, but it is not a universal instruction requiring all information about an individual to disappear. Meaningful correction requires a documented and targeted process across each level at which the information is stored and used.