CIS, IVR and EVR: what is the difference?

CIS, IVR and EVR: what is the difference?

Anyone looking for the difference CIS IVR EVR will quickly encounter terms that are often mentioned in the same breath, but do not mean the same thing. CIS is a database for data from participating insurers. IVR stands for Intern Verwijzingsregister (Internal Referral Register) and has an internal function within a financial institution or group. EVR stands for Extern Verwijzingsregister (External Referral Register) and is an external warning within the Protocol Incidentenwaarschuwingssysteem Financiële Instellingen, also referred to as PIFI.

It is important not to mix up the terms. A CIS registration is not automatically a fraud registration or an EVR registration. An IVR registration is not the same as a credit registration. And EVR does not mean that an old registration has expired or been removed: it is specifically an external referral registration that can be consulted under strict conditions.

Brief overview

What is CIS?

Stichting Centraal Informatie Systeem, usually called CIS, manages a database for participating insurers and authorised agents. Different types of registrations, originating from participating insurers, may be included in that database. Which data are recorded depends on the specific registration category and the circumstances.

Stichting CIS lists, among other things, claim notifications, Guarantee Fund notifications, disqualifications from driving, confidential communications and EVR registrations as categories in the CIS database. A claim notification means, for example, that a claim on insurance cover has been made. That is not the same as the conclusion that someone has committed fraud or that a claim is justified or unjustified.1

There is therefore no general rule of thumb for CIS that every registration is a negative fraud or non-payment registration. Anyone encountering the difference CIS IVR EVR in a letter or policy context must first establish which specific registration category, responsible insurer and data are at issue.

What is IVR?

IVR stands for Intern Verwijzingsregister (Internal Referral Register). The IVR is linked to the internal incident registration of a financial institution. The Nederlandse Vereniging van Banken (Dutch Banking Association) explains that an institution may place limited identifying data in its own internal referral register when someone has been involved in an incident. Other financial institutions cannot consult this internal register.2

Kifid also distinguishes an internal Events Administration (Gebeurtenissenadministratie) and the linked Intern Verwijzingsregister. An internal registration may concern an occurrence that, in the institution’s view, requires attention or poses a risk. The conditions and consequences differ from an external registration. An IVR is therefore not a general credit register, but an internal register within the financial institution concerned.

What is EVR?

EVR stands for Extern Verwijzingsregister (External Referral Register). The EVR is not a historical overview of expired or deleted registrations. It is an external referral register within the external warning system of financial institutions.

In serious incidents, referral data can be recorded not only internally but also externally. The Nederlandse Vereniging van Banken describes that other financial institutions can consult the identifying data from the EVR. Kifid explains that the Incident Register and the EVR together constitute the external warning system.2

An EVR entry can have far-reaching consequences. That is why strict conditions apply under the PIFI. Kifid notes, among other things, that a stronger suspicion is required for inclusion in the external warning system than a reasonable suspicion of guilt. In addition, the financial institution concerned must take into account proportionality, subsidiarity and the personal circumstances of the data subject.3

The maximum registration duration is not automatically the correct duration in every file. The institution must be able to substantiate the chosen duration. For an insurance EVR, Stichting CIS states that the registration falls under the PIFI and can last up to eight years; the insurer concerned remains responsible for the content of that registration.1

The difference between IVR and EVR

The most important difference is the scope. An IVR registration has an internal function at the financial institution or group. An EVR registration has external effect within the warning system: other participating financial institutions can consult the referral data under the applicable rules.

That is why an EVR registration is generally more far-reaching than an IVR registration. That does not mean that every EVR entry is by definition unlawful, or that every IVR entry can have no consequences. The factual basis, the reasoning, the duration and the balancing of interests must be assessed for each file.

Is an EVR registration always in CIS?

Not necessarily. Stichting CIS states that EVR registrations by insurers can be included in the CIS database. At the same time, Stichting CIS states that its database does not contain EVR or EVA registrations concerning banking and mortgage products. For those subjects CIS refers to the relevant banking or mortgage fraud organisations.1

It is therefore not correct to describe all EVR registrations as a single CIS registration. Always ask which institution has registered, which register is involved, on which data the registration is based and which period has been applied.

How do you request access or correction?

For data in the CIS database, you can submit an access request to Stichting CIS. Stichting CIS offers a WebApp and a route by post for this. If you suspect an error, the participating insurer that recorded the data is responsible for its accuracy and completeness.4

With an IVR or EVR registration, it is wise first to keep the letter or communication from the registering financial institution. Request in writing the specific basis, the data recorded, the start and end date, the balancing of interests and how you can present your position. For an insurance EVR, Stichting CIS points out that a correction request must be addressed to the responsible insurer.1

An objection or correction request carries the most weight when it is specific. Describe which data you believe are factually incorrect, which documents support that, and why the registration or duration is, in your view, not appropriate. General objections without substantiation are usually less useful.

Which steps can you take carefully?

1. Keep the letter, emails and all documents about the registration.
2. Request access to the data, the basis, the category and the registration duration.
3. Check whether it concerns CIS, IVR, EVR, the Incident Register or another registration.
4. Respond in writing and specifically to factual inaccuracies or to the substantiation of the registration.
5. Explain personal circumstances and the concrete detriment if you request a reassessment of the duration.
6. First follow the complaints procedure of the financial institution if you cannot resolve the matter.

For a complaint about a financial product or a financial service, Kifid may in many cases be a possible route. Whether Kifid will handle your complaint depends on the current rules and the circumstances. Check the Kifid quick test in advance.6

Frequently asked questions

Is EVR a register of expired or deleted registrations?

No. EVR stands for Extern Verwijzingsregister (External Referral Register). It is not an archive of expired registrations. An EVR entry is an external referral registration within the PIFI and can, under conditions, be consulted by other participating financial institutions.

What does IVR stand for?

IVR stands for Intern Verwijzingsregister (Internal Referral Register). It has an internal function within a financial institution or group and is not the same as a general credit register.

Is every CIS registration a fraud registration?

No. The CIS database has different registration categories. A claim notification, for example, is not the same as a fraud registration. If in doubt, request access to your specific data and the type of registration.

Can I have an EVR registration removed?

The right question first is which institution made the registration, on what basis and for what period. For an insurance EVR, the registering insurer is responsible for the content. You can request access, correction or reassessment from that insurer in writing and substantiate your request specifically.

Can I see at CIS whether I am listed in IVR or EVR?

A CIS access request concerns data in the CIS database. Not all banking or mortgage EVR or EVA registrations are in that database. Therefore, always ask which institution and which register are at issue in your specific situation.

Official sources

• Stichting CIS — Types of registrations
• Stichting CIS — Access to your registrations
• Stichting CIS — Your data & CIS
• Nederlandse Vereniging van Banken — Warning registers of banks
• Nederlandse Vereniging van Banken — Protocol Incidentenwaarschuwingssysteem Financiële Instellingen
• Kifid — Help, the bank or insurer places me in a warning register

Conclusion: first correctly identify the difference CIS IVR EVR

The name of the register, the scope of the registration and the responsible institution make a difference in every file. By not confusing CIS, IVR and EVR, you can more effectively request access, an explanation or a reassessment.

Need help?

Have you received a letter about a CIS, IVR or EVR registration and do you want to understand which data and steps are relevant in your file? Then contact Arslan Advocaten. We can discuss with you which documents and questions require attention.

Sources for the key passages

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