Objection to CIS registration can be relevant when you believe that data in the CIS database has been processed incorrectly or incompletely. The CIS database is intended for participating insurers and authorized agents and is used in, among other things, claim and risk/acceptance assessments. This article explains how you first request access and then can submit a reasoned correction request.
What is a CIS registration?
Stichting Centraal Informatie Systeem (CIS) is a foundation for insurers and authorized agents working in the Netherlands. CIS manages data for participating parties that may be relevant to claims and insurance acceptance. An insurer can register data when you submit a claim and can consult the database during an insurance application or claim. CIS is not a central register of collection agencies for general debts or credit arrears. See Stichting CIS: your data and CIS.
Registrations in the CIS database are placed by participating insurers and authorized agents, and for certain categories by other participants. The participating insurer is responsible for the content and accuracy of the registration. The retention period depends on the registration type; a uniform period for all registrations does not exist. See Stichting CIS: frequently asked questions.
When can you object to a CIS registration?
A correction request is appropriate when, after inspection, you believe that a CIS registration is incorrect, incomplete, outdated, or linked to the wrong person. The relevant question is always which registration type is visible, which insurer placed the registration, and which concrete data you believe is incorrect.
For substantive questions or correction, please contact the handler or insurer listed under the registration. That party is responsible for the content. Keep the registration, the reference number, and the documents that substantiate your request. See Stichting CIS: frequently asked questions.
How do you submit an objection to CIS registration?
When you believe that a CIS registration is incorrect, first request access from CIS. For substantive questions or a correction, contact the handler or insurer listed under the registration. The insurer is responsible for the content. Keep the registration, the reference number, and the documents with which you substantiate your request.
After inspection, you can submit a correction request within the period specified by CIS; CIS submits this to the insurer involved, who decides on a possible correction. If a correction request is rejected, you can first follow the complaints procedure with the insurer involved and then, depending on the situation, approach Kifid (Financial Services Complaints Tribunal) or the court. See the official CIS explanation on correction requests.
If the objection is not honored, you can submit a complaint to the Financial Services Complaints Tribunal (Kifid) or engage the court. It is advisable to engage the help of a specialized lawyer for this.
Consequences of a CIS registration for you
A registration in the CIS database can be relevant to an insurance application or claim assessment. The official CIS information emphasizes that a registration in itself is no reason to refuse insurance: every insurer assesses acceptance according to its own policy.
- an insurer can involve the registration in the assessment of an application or claim;
- you can ask the insurer involved for an explanation in case of questions about acceptance;
- incorrect data can be submitted to the responsible insurer via inspection and a reasoned correction request.
When you believe after inspection that data is incorrect, a concrete correction request to the responsible insurer is the appropriate first step. An outcome regarding acceptance or premium does not automatically follow from the registration; ask the insurer for an explanation of its own acceptance policy.
Burden of proof and documentation in case of objection
When you object to a CIS registration, it is essential to substantiate your position well. Therefore, collect all relevant documents, such as proof of payment, correspondence with creditors, and confirmations of repayments. This helps to demonstrate that the registration is unjustified.
The processing of personal data in the CIS database falls under the GDPR (AVG in Dutch). CIS explains that data can be used for carefully determined purposes, including fraud prevention, claim handling, and in certain cases the execution of an insurance contract. The insurer involved remains responsible for the accuracy and completeness of the registration.
The role of Arslan & Arslan Lawyers in objecting to CIS registration
A correction request regarding a CIS registration can be complex, especially when the responsible insurer does not follow your substantiation. Arslan & Arslan Lawyers can legally assess the registration, the correspondence, and the possible next steps.
We can support you in organizing documents, formulating a reasoned request and, if necessary, assessing a complaint or procedural step. The outcome always depends on the registration, the data, and the circumstances of the file.
Difference between CIS and EVR registration
CIS and EVR must be carefully distinguished from each other. The official CIS categories include claim reports, guarantee fund reports, denials of driving privileges, confidential communications, and the External Referral Register (EVR). Which category is involved in an individual file follows from the registration and the insurer involved; do not generalize this as a collection register.
Both registrations can have adverse consequences, but the procedures for objection differ. For more insight, you can read our blog on EVR registration: difference with CIS explained.
Frequently asked questions
What is the maximum period that a CIS registration may remain?
The retention period in the CIS database depends on the type of registration. Claim and guarantee fund reports are in principle removed after five years; confidential communications about financial contractual obligations after three years; EVR remains visible until the end date with a maximum of eight years. Check the official CIS information and the data of the insurer involved for a concrete registration.
Can I also have a CIS registration removed if I cannot pay the debt?
Whether a registration can be corrected or removed depends on the registration type, the accuracy of the data, and the assessment by the responsible insurer. Payment alone does not automatically determine that a CIS registration disappears. Request access, check the registration, and address a reasoned correction request to the insurer involved when you believe data is incorrect.
Must I always engage legal help when objecting to CIS registration?
It is not mandatory, but engaging a specialized lawyer can significantly facilitate the process and increase your chances of success, especially when the collection agency does not cooperate.
Read also
- CIS registration: what is it and how do you remove it?
- EVR registration: difference with CIS explained
- Incident register: how do you get in and what can you do?
Need help?
Are you dealing with an unjustified CIS registration or do you doubt whether your registration is correct? At Arslan & Arslan Lawyers we are happy to help you protect your rights. Contact us for a free initial consultation and discover how we can support you in objecting to CIS registration.
Need help? Our BKR lawyer is happy to help you further. Contact us without obligation for a free initial consultation.
