Step 1: Get your CIFAS report

Before you can challenge a marker, you need to know exactly what has been recorded. Submit a Subject Access Request to CIFAS to obtain your NFD record. This will tell you the marker type, the filing organisation, and the date it was placed.

At the same time, submit a SAR to the institution that placed the marker. This requests all data they hold about you, including the evidence they relied on when filing the marker.

Step 2: Understand the marker

Identify the marker type and understand what it alleges. Each type requires different arguments. Review the institution's correspondence and your own records to understand the basis for the marker.

Step 3: Prepare your complaint

Your complaint should be structured, evidence-led, and include the right legal arguments for your marker type. This typically includes challenging the standard of proof, the evidence of dishonesty, the proportionality of the marker, and the data accuracy under UK GDPR.

Step 4: Submit to the issuer

Send your complaint directly to the organisation that placed the marker. They have up to 8 weeks to investigate and respond. Keep proof of submission including the date and method.

Step 5: Escalate if needed

If the issuer rejects your complaint or fails to respond within 8 weeks, you can escalate to CIFAS (about member conduct) and the Financial Ombudsman simultaneously. If the DPO failed to respond to your SAR, you can also file an ICO complaint. If all else fails, the court route applies actual law and can order removal plus damages.