What are the CIFAS filing principles?

CIFAS members must follow a set of principles when recording fraud markers on the National Fraud Database. These principles are the rules that govern when and how markers can be filed. If a member breaches these principles, the marker may be challengeable.

The filing principles exist to ensure that markers are only placed where there is genuine evidence of fraud or financial crime, that the process is fair, and that individuals are treated properly.

The key filing requirements

• Evidence of fraud or dishonesty — the member must have evidence, not just suspicion
• Standard of proof — the evidence must meet the CIFAS standard, which is higher than mere suspicion but lower than criminal proof
• Proportionality — the marker must be proportionate to the circumstances and the evidence
• Investigation — the member must have conducted a proper investigation before filing
• Notification — the individual should be informed that a marker has been placed, though many institutions fail to do this
• Accuracy — the data recorded must be accurate and relate to the correct individual

How filing principles support your complaint

Every CIFAS filing principle maps directly to a data protection obligation under UK GDPR. When a member breaches filing standards, they are also breaching data protection law. This is why the most effective complaints combine CIFAS filing standard challenges with UK GDPR accuracy arguments.

For example, if a member filed a marker without proper investigation, they have breached both the CIFAS investigation requirement and the UK GDPR obligation to ensure personal data is accurate (Article 5(1)(d)).