What Is a CIFAS Marker and How Do You Get One Removed?

What Is CIFAS and the National Fraud Database?

CIFAS as an organisation

CIFAS is a UK not-for-profit organisation that helps businesses prevent and detect fraud. It has operated for more than 35 years, providing a secure and legally governed framework for the real-time sharing of fraud risk data and intelligence across sectors. CIFAS does not investigate fraud on behalf of its members and does not make decisions about individual applications or accounts. Those decisions remain with the organisations using its services.

Its members include banks, lenders, insurers, retailers and telecommunications companies.

The National Fraud Database and the Internal Fraud Database

CIFAS operates two main fraud prevention databases. 

The National Fraud Database allows member organisations to share details of applications considered to be fraudulent, inconsistent or suspicious; information about accounts and services being misused; and details of insurance or other claims considered fraudulent or suspicious. The Internal Fraud Database relates to fraud committed by employees and is a separate system. 

This article focuses on the National Fraud Database, which is the database most likely to affect a person applying for financial products or services.

How membership works

CIFAS members must follow the National Fraud Database Principles, which govern how fraud-related information is recorded, shared and retained. The organisation that investigates the suspected fraud is responsible for recording the marker.

For example, if a bank believes an account has been used for fraudulent transactions, the bank may record a CIFAS marker if the evidence meets the required standard. CIFAS manages the database and its rules, but the member organisation remains responsible for the information it submits.

Why Might a CIFAS Marker Be Recorded?

The filing standard

A bank, lender or other member organisation must have sufficient evidence before recording a CIFAS marker.

CIFAS requires evidence that is clear, relevant and rigorous, with reasonable grounds to believe that fraud or financial crime has been committed or attempted. The conduct must also meet the requirements of a recognised marker category.

Suspicion alone is not enough to justify recording an adverse CIFAS marker. However, the organisation does not need to obtain a criminal conviction before making a filing. A marker reflects the member’s assessment of the evidence, not a finding of guilt by a court.

Common triggers for a CIFAS marker

CIFAS markers may be recorded following suspicious transactions, inconsistencies in application information or concerns about identity documents.

For example, a bank may investigate an account that received money linked to reported fraud. A lender may also investigate an application containing inaccurate employment or income information. In some cases, the account holder may have been unaware that their account was being used for fraudulent activity.

The circumstances and available evidence are therefore important when deciding whether a marker was properly recorded.

When a CIFAS marker may be unlawful

A CIFAS marker may be open to challenge if the organisation relied on assumptions rather than sufficient evidence, recorded inaccurate information or failed to follow the relevant rules.

The National Fraud Database Principles also require members to retain information only for as long as necessary. If the evidence does not support the marker, or continued retention is no longer justified, removal may be appropriate. This means a CIFAS marker does not always have to remain in place for its maximum permitted period.

The Main Types of CIFAS Markers

Adverse fraud markers

Adverse CIFAS markers are recorded where an organisation has evidence of suspected fraud or financial dishonesty.

There are several recognised categories, depending on the conduct involved.

• Application Fraud is recorded when an individual applies for credit or a product using false details, such as incorrect employment, salary or address information, or falsified documents. This CIFAS marker can be held for up to six years.
• First-Party Fraud is recorded when a customer fails to repay for goods or services they have received, with no intention of repayment from the outset. This marker can also be held for up to six years.
• Insurance Claim Fraud is applied when false or misleading information is provided during an insurance claim process. This too carries a maximum retention period of up to six years.

Other categories include:

• Facility Takeover covers situations where an unauthorised individual gains control of another person’s bank account or financial facility. 
• Asset Conversion relates to the sale of goods that remain subject to a finance agreement. 
• Misuse of Facility is recorded where an account or product is used to facilitate fraud. The precise retention periods for these three categories should be confirmed against current CIFAS guidance.

The applicable retention period and filing requirements depend on the marker category.

Protective and victim records

Not every CIFAS record indicates suspected wrongdoing by the person named. Some records are designed to protect people who have experienced identity fraud or are at risk of it.

• Victim of Impersonation record may be added where someone has used another person’s identity without permission.
• Protective Registration allows eligible individuals to request additional checks when their personal details are used to apply for products or services.

These records are intended to reduce the risk of further fraud rather than suggest that the individual has acted dishonestly. They also have different retention arrangements from adverse fraud markers.

How to Find Out If You Have a CIFAS Marker

Making a free CIFAS data subject access request

You can request information held about you on the National Fraud Database by making a data subject access request (DSAR) directly to CIFAS. CIFAS normally responds within one calendar month of receiving a completed request and the necessary supporting documents.

You will need to provide your full name, date of birth, contact details and address history for the previous six years. CIFAS may also request documents confirming your identity and address, such as a passport, driving licence, bank statement or utility bill.

CIFAS also advises caution when dealing with businesses claiming they can guarantee the removal of a marker.

What will a data subject access request tell you?

A data subject access request can confirm whether CIFAS holds information about you and provide details of any relevant records. For an adverse marker, the information may include its category and details of the recorded allegation.

However, the response may not contain every document or piece of evidence relied upon by the organisation that recorded it. You may therefore need to request further information directly from that organisation.

Requesting information from the filing organisation

If a CIFAS marker has been recorded against you, contact the organisation responsible for the filing. You can make a separate subject access request asking for personal information relating to its investigation and the decision to record the marker.

This may include relevant account records, communications and information explaining the concerns raised.

However, some material may be withheld where a lawful data protection exemption applies. These records can help you understand whether the evidence met the required standard and identify any information you believe is inaccurate.

How can you challenge the marker?

If you believe the CIFAS marker is incorrect or unsupported, the first step is to complain directly to the organisation that recorded it. Explain why you dispute the marker and provide any documents supporting your position.

If the organisation agrees that the filing was incorrect, it can arrange for the marker to be removed. If your complaint is rejected, request its final response. You can then ask CIFAS to review the complaint independently.

If the dispute remains unresolved, further options may include the relevant financial complaints scheme or data protection regulator, depending on the circumstances.

How a CIFAS Marker Can Affect Your Everyday Life

Banking and financial services

Banks and other CIFAS members may check the National Fraud Database when assessing applications for financial products or services.

A CIFAS marker does not automatically mean an application must be refused. However, it may lead to additional checks, rejected applications, account restrictions or account closure.

For example, someone with an adverse marker may experience difficulties opening a new current account or obtaining a loan. Each organisation makes its own decision based on the available information and its assessment of the risk.

A CIFAS marker does not directly reduce your credit score, although difficulties accessing financial services may have other practical consequences.

Employment

Certain employers may check fraud prevention databases during recruitment, particularly for roles involving money, financial responsibility or regulated services. An adverse CIFAS marker may therefore affect employment opportunities in some industries.

However, not every employer carries out these checks, and a marker does not automatically prevent someone from being employed. The outcome depends on the role, the information available and the employer’s assessment.

Insurance and other services

Insurers that belong to CIFAS may check the database when reviewing applications or claims. A CIFAS marker may lead to further enquiries or affect whether a policy is offered or renewed. However, the decision rests with the insurer rather than being determined automatically by Cifas.

How Long Does a CIFAS Marker Last?

Retention periods by record type

Retention periods vary depending on the type of CIFAS marker recorded. Adverse fraud markers such as Application Fraud, First-Party Fraud and Insurance Claim Fraud can be held for up to six years from the date of filing. Other marker types carry different maximum retention periods, and protective and victim records have their own durations. Anyone with a CIFAS marker should verify the specific period applicable to their category against current CIFAS guidance.

Early deletion of a CIFAS marker

A CIFAS marker does not automatically run to its maximum retention period.  CIFAS rules require members to delete information once it has served its purpose. A successful challenge may therefore result in earlier removal.

For example, if the evidence relied upon by a bank does not support the allegation, the bank may be required to correct or remove the record. Removal may also be appropriate where continued retention is no longer justified.

However, a request for early deletion does not guarantee that the marker will be removed. The decision depends on the evidence, the reason for the filing and the applicable data protection requirements.

Is a CIFAS Marker a Criminal Record?

A CIFAS marker is not a criminal conviction

A CIFAS marker is a civil fraud prevention record. It is not a prosecution, a caution or a criminal conviction. Recording a CIFAS marker does not mean that the person has been charged with or found guilty of any criminal offence.

The marker does not appear on a standard or enhanced DBS certificate in the same way that a conviction or caution would.

DBS checks and separately held police information

An enhanced DBS check may include relevant information held by a local police force, even where no charge or conviction resulted from an investigation. If a fraud report was made to the police in connection with the same incident that triggered the CIFAS marker, that police information may appear on an enhanced DBS check through a separate route, entirely independently of the marker itself. The two systems are distinct and should not be conflated.

Where a criminal investigation may overlap with a CIFAS marker

Sometimes, the conduct that led to a CIFAS marker may also be the subject of a police investigation. For example, an account linked to suspected fraudulent transfers may prompt both a bank investigation and enquiries by police.

If you believe criminal proceedings may follow, obtaining legal advice before giving a detailed explanation of the transactions can help you understand your position. This does not mean ignoring correspondence or missing complaint deadlines.

A solicitor can advise on responding appropriately while considering any related criminal allegations.

Speak to a Solicitor About Your CIFAS Marker

If you have discovered a CIFAS marker or believe one has been recorded incorrectly, a solicitor can explain your options and help assess the evidence supporting the filing.

They can advise on obtaining relevant records, challenging inaccurate information and following the appropriate complaints process. Where a criminal fraud investigation is also involved, a solicitor can consider how the two matters may affect each other.

Speak to our Fraud and Financial Crime solicitor for advice about your circumstances and the next steps.