In the greenhouses along the Poeldijkseweg in Naaldwijk, an insurer suddenly refuses to renew the liability policy for seasonal workers. The reason? A CIS listing of which the grower was never notified.
What data does the CIS contain exactly?
The Central Information System contains three types of registrations. The External Referral Register (EVR) records proven or strongly suspected fraud and remains in place for a maximum of eight years. The Incidents Register records elevated risks without hard evidence, usually for five years. The Risk Register contains general data on claims history or living and working environment.
Who consults the register with every application?
Practically every Dutch non-life, health and liability insurer is affiliated. A new application for a greenhouse or lorry is automatically checked. A hit almost always leads to refusal or significantly increased premiums.
Concrete problems caused by a CIS listing
- Policy refused by virtually all insurers
- Higher premiums in the event of exceptional acceptance
- Mortgage stalled because the buildings insurance for the greenhouse cannot be arranged
- Existing cover terminated at transport companies
- Credit application hampered when banks also consult financial registers
How do you check whether you are registered?
You have the right of access under the AVG. Send a written request to Stichting CIS, Antwoordnummer 4860, 3500 ZL Utrecht. Identify yourself with a certified copy of your ID. You will receive an overview within one month. Access is free of charge.
Step-by-step removal of an incorrect registration
The procedure consists of four steps.
Step 1: request the file
Request the complete file from the insurer that made the notification. They must state exactly on which facts the registration is based.
Step 2: submit a reasoned objection
Send a notice of objection with your explanation, supporting documents and a request for removal. The insurer must respond within four weeks.
Step 3: involve Kifid
If rejected, you can turn to Kifid. The procedure takes six to twelve months and costs fifty euros.
Step 4: Rechtbank Den Haag
In complex or serious cases, you initiate summary or ordinary proceedings before the Rechtbank Den Haag. You can also contact the Juridisch Loket Den Haag for an initial assessment.
Compensation for an unjustified CIS notification
The Hoge Raad has ruled that an insurer is liable for damage resulting from an unjustified registration. Missed policies, higher premiums and legal costs can lead to compensation ranging from several thousand to tens of thousands of euros.
Important time limits
- Limitation period: five years from the moment you became aware of the registration
- Maximum duration EVR: eight years, after which automatic removal
- Kifid time limit: within one year after written rejection of your objection
Practical advice from Arslan Advocaten
Call 070-4500300 immediately or visit Verdilaan 30 in Naaldwijk. Many Westland entrepreneurs in horticulture and transport discover only late that a mistake or one-sided assessment has restricted them for years. A swift correction prevents unnecessary financial damage.