We have been made aware of a data breach affecting Access Personal Checking Services Ltd (APCS), a company who carry out DBS checks for a wide range of organisations, including some Church of England bodies. Up until March this year, the Diocese of Derby used APCS to process its DBS check processing, which means that some of our clergy, lay leaders, church volunteers and the Parish Support Team are affected.
Affected data includes name, date of birth, email, address, place of birth, gender, National Insurance number, passport details, driving licence details. The data is text data only. It does not include images or documents. It does not include medical information, information on any disclosures, information about protected characteristics, such as ethnicity, disability, sexual orientation, marital status.
APCS believe the data compromised involves applications from 1 December 2024 to May 2025.
We have emailed all PCCs who we believe are directly affected by this data breach via their PCC secretary, clergy and the designated person who coordinates the DBS checks in those parishes.
We have also outlined the steps that each affected PCC needs to take, as data controllers, to report this breach of personal information to the Information Commissioners Office and the Charity Commission.
What can I do?
While there is no guarantee that the information exposed in this breach won't be misused, most people affected by data breaches do not experience any problems. However, if you are affected by this breach, there are some steps you can take to remain vigilant about how your data could be used:
- Stay alert to unexpected emails, calls, or letters that mention personal details about you
- Never give personal information to unsolicited callers, even if they seem to know details about you
- Verify any unexpected contact by calling the organisation directly using their official number
- Monitor for new applications made in your name:
- Check your credit report
- Look for any new accounts, credit searches, or applications you didn't make
- For general advice, contact:
- Citizens Advice: 0808 223 1133
- Action Fraud: 0300 123 2040
As always, stay alert for any suspicious activity via email, SMS, or phone calls. Responsible organisations will not contact you and ask you to provide them with personal account information such as your username and password. If you are unsure about anyone you are in communication with, online or over the phone, make sure you verify their identity independently before engaging with them further.
What support is available?
There is specific support available to the individuals named in the data breach which will be communicated directly to them.
We have set up an email address databreachsupport@derby.anglican.org for people who have any questions or concerns that they wish to share with us about this data breach and our response to it.
What do churches and PCCs need to do?
Each PCC is a separate legal entity and data controller, and needs to report a breach to the Information Commissioners Office (ICO) within 72 hours of being made aware of it.
Template guidance for how to report a data breach to the ICO can be found here.
As of Thursday 28 August, there is no longer a requirement for PCCs to refer this incident to the Charity Commission. If PCCs decide that they still wish to report this as a serious incident, the following links may be helpful.
Template guidance for how to submit a referral to the Charity Commission can be found here.
We are actively monitoring this incident and will regularly update this page as new advice or guidance becomes available.
Frequently asked questions
About the breach
What has happened?
We have been notified that one of their suppliers Access Personal Checking Services Ltd (APCS) has been subject to a significant data breach. ACPS carries out Data and Barring Services (DBS) checks on behalf of the National Church Institutions (NCIs), some Dioceses and Parochial Church Council (PCCs). The breach has affected clergy, lay ministers, volunteers, and staff.
Who has it affected?
This breach has impacted people across the Church who have been subject to a recent DBS check. APCS carries out DBS checks on behalf of some Dioceses and PCCs, and the NCIs.
Who are APCS and what do they do?
APCS specialise in processing disclosures for individuals and small business owners, large public and private sector companies, organisations, and recruitment agencies.
Does thr Diocese of Derby use APCS for their DBS checks?
No, not anymore, but we have done in the past which is why people in our diocese are affected. The Diocese of Derby stopped using APCS for DBS checks in March 2025, but the data that has been leaked is from before that date.
When did the data breach happen?
APCS have stated that their external software supplier, Intradev, notified them on 17 August that their system had been compromised between the 31 July 2025 and 15 August 2025, and certain files containing personal details were copied. APCS were provided with copies of the compromised data on Monday 18 August. APCS’ own network and servers were not compromised. From initial assessments made by APCS, the data that is affected is from 1 December 2024 to 9 May 2025.
Have other organisations outside of the C of E been affected?
Yes. APCS provides Data and Barring Services (DBS) to many organisations. This breach also impacts those bodies.
How confident are we that only those notified have been affected?
APCS have started the process of notifying those individuals affected by the breach. APCS have said that the breach only affects those individuals who were subject to a DBS check between the 1 December 2024 to 9 May 2025, but this is a moving situation, and we will keep you updated as we receive more information.
What personal information has been leaked?
We are waiting for more details from APCS. We understand that the breach may have affected some or all the following information:
- Name, phone number, date of birth, email address, address, place of birth, National Insurance number, passport number, driving licence number.
It does not include:
- Medical information, information on any disclosures, information about your protected characteristics e.g., ethnicity, disability, sexual orientation, marital status.
The information that was accessed was in text format only. No documents, images, passwords, or financial details were affected.
What is the Diocese of Derby doing in response?
- People affected by the data breach have been contacted with advice and support.
- Support includes 12 months free access to a credit checking and monitoring service from Experian.
- This incident has been reported to the Information Commissioner's Office (ICO) and to the Charity Commission
Reporting the breach and data protection
Do PCCs need to report the incident to the ICO?
Yes. PCCs should report separately to the ICO if they have directly accessed the service i.e. if they have been uploading data to APCS themselves this makes them the data controller. If the DBF have been doing this on their behalf, then the DBF should report as the data controller. You can assess this by checking who APCS is corresponding with i.e. if they have contacted the PCC directly, then it is likely that the PCC is the controller and therefore must report.
Whether the PCC is part of the national deal is not the issue for reporting to the ICO, the key issue is who the controller is, so if the PCC have their own contract with APCS and have been contacted, they must report it.
Who is responsible for reporting a breach to the ICO?
Only the data controller is responsible for reporting a high-risk data breach to the ICO. A high-risk data breach is one which has a significant effect on the rights and freedoms of data subjects. All parties are accountable for taking steps to mitigate the effects of the breach where possible.
If the data breach is caused by the processor, the processor must implement technical and organisational measures to assist the controller to deal with the breach but is responsible for their own failures or those of their sub-processors. However, the ICO can investigate all parties involved to ensure they have met their obligations appropriately.
Do we need to report this incident to the Charity Commission?
The Charity Commission have informed the National Church Institutions that due to the large number of Serious Incident Reports they have received on this, trustees in PCCs and diocesan boards of finance do not need to report to the Charity Commission "if in substance they simply wish to report the same incident in materially similar terms".
Is the 72-hour deadline for reporting the incident to the ICO based on when an email notifying the breach was sent, or when the email was seen?
The 72-hour window is based on when your organisation became aware of the data breach (i.e. when the email sent from APCS was seen). If you have missed the 72-hour deadline, you can explain that the reason for the delay is because you were fact finding, but it is best if you can do this as close to the 72-hour window as possible.
I would like to request that any data held by APCS on me is deleted under GDPR. How do I go about this?
If you wish to make an erasure request, you can contact APCS via email to enquiries@accesspcs.co.uk or by phone on 0845 6431145. The APCS Privacy policy is available here: www.onlinecrbcheck.co.uk/docs/privacypolicy.pdf
What’s the difference between a data controller and a data processor?
A data controller is the organisation responsible for making the key decisions about how and why data is collected, stored, and used and is responsible for complying with all GDPR obligations. Where the controller uses an external supplier who will be processing personal data for the controller (data processor), the overall responsibly for data protection compliance remains with the data controller.
A controller is responsible for ensuring that the processors have provided sufficient assurance that they are GDPR compliant, and for putting in place a suitable contract which should include instructions on how a data breach will be managed.
In the APCS situation the controller would be the organisation responsible for uploading data to the APCS system, for example the Church of England Central Services, a Diocesan Board of Finance, or Parochial Church Council.
A data processor is responsible for processing personal data solely on behalf of the controller adhering strictly to the controller's documented instructions. They are responsible for complying with their own GDPR obligations, including putting in place a suitable contract which provides an equivalent level of data protection as the contract with the controller. with any of their sub-processors
The processor must immediately inform the controller of any data breaches. In this case APCS is the data processor.
A sub-processor is a supplier providing processing services to the primary data processor. They are responsible for processing personal data on behalf of the primary data processor, under a suitable contract. This includes implementing appropriate security measures to protect the data, complying with relevant GDPR obligations and assisting the primary processor and controller to meet their data protection obligations. In this case Intradev is the sub processor.
Why are parishes being asked to submit a report to the ICO?
In the event of a data breach, the data controller is responsible for submitting a report to the ICO. In this instance, the “controller” is the organisation responsible for uploading data to the APCS system, for example, the PCC.
Support for people affected
What support is available for those who have been affected?
Access to a credit checking and monitoring service from Experian is being made available for 12 months for those affected. If you have been affected by this data breach and you have not received a code to access your Experian Identity Plus account, please contact [insert local details]. More information about the service available from Experian is contained within these FAQs.
Advice about what additional steps you can take, and the resources available to help protect you from fraud, are also included in these FAQs.
Who can I contact about the data breach?
We have set up a dedicated email address for enquiries relating to the data breach. Please email databreachsupport@derby.anglican.org
What support will I be offered if my data is used maliciously through this breach? For instance if someone uses the data to create a new payment from my bank account or creates a credit agreement that negatively affects my credit file?
We are encouraging people who are potentially affected by this to sign up to the Experian service. This service, provided for 12 months, will help you to keep an eye out for any changes that suggest someone is using your data improperly – for instance, you will get an alert if someone sets up a new credit agreement. If you become the victim of fraud, you will be offered help through Experian’s caseworker service to get back on track and sort out your credit file.
In addition, you should look out for any unwanted calls, emails or contact to you directly, including monitoring your bank account. You might find it helpful to talk to your bank now to let them know of the situation. Some are able to put in place additional identification verification checks for making/setting up payments, to help keep your money safe.
What can I do to protect myself from fraud?
- Stay alert to unexpected emails, calls, or letters that mention personal details about you
- Never give personal information to unsolicited callers, even if they seem to know details about you
- Verify any unexpected contact by calling the organisation directly using their official number
- Monitor for new applications made in your name:
- Check your credit report – see below for information about the service that will be available to you from Experian shortly.
- Look for any new accounts, credit searches, or applications you did not make.
- Inform your bank, building society and credit card company of any unusual transactions on your statement.
Links and contact numbers
Action Fraud
The government has put together this checklist to help on the steps to take to repair your identity and prevent re-victimisation.
The National Fraud and Cyber Crime Reporting Centre has a wealth of advice and resources on the Action Fraud website.
- www.actionfraud.police.uk
- Call Action Fraud on 0300 123 2040
GOV.UK
- Advice from GOV.UK on the actions you should take if you have shared personal information
Financial Ombudsman Service
If you have lost money because of fraud or a scam – and you are unhappy with how your bank or payment service provider handled things – The Financial Ombudsman Service may be able to help.
General advice
- www.citizensadvice.org.uk
- Call Citizens Advice on 0808 223 1133
To report the theft or loss of post
- Royal Mail website: www.royalmail.com/report-a-crime
- Or call Royal Mail on 08457 740 740
Experian Identity Plus
Who can I speak to about getting an access code for the credit check and web monitoring service from Experian?
We are contacting people affected by this breach via PCC secretaries, and will share details about how to claim an access code via those channels. If you would like to contact someone at the dicoese about this please email databreachsupport@anglican.org
What does the Experian Identity Plus account provide?
Features of the Experian Identity Plus account includes:
- Daily Experian Fraud Report
If you log in, you can get your daily Experian Fraud Report. This details key information from your Experian Credit Report that may help you identify fraudulent activity on your credit report.
- Alerts provided as part of the service
Alerts will be provided by email and/or SMS, depending on your settings and features availability.
- Experian fraud alerts
Get alerts by email and/or text message about certain changes to your Experian Fraud Report. Alerts relate to when accounts are opened or closed, or when your credit report is searched. Some of our credit alerts may be sent in real-time to notify of certain changes when they happen, others are sent weekly.
- Experian CreditLock alerts
Experian will let you know when your Experian credit file is searched and if your credit file was locked. For any applications that are blocked you will be sent a message by email and/or text to make you aware.
- CreditLock
Experian CreditLock is designed to reduce fraudulent credit applications. Locking your Experian Credit Report will help to block new fraudulent credit applications made in your name, using your information from the Experian Credit Bureau.
- Web monitoring
Experian will help you better protect your identity by scanning certain internet sites and locations for selected personal and financial details and alerting you by email or text message if anything looks wrong or fraudulent. Alerts are sent every day that we find suspicious information. Web monitoring is designed to work alongside taking a cautious approach to your sharing of data and use of the internet and other digital services.
Read this guide to Identity Plus for more details
How do I read my credit report? I have never had one before
If you are not sure where to start, take a look at this guide from Experian: www.experian.co.uk/consumer/experian-credit-report.html
Your credit report has different sections. For instance, it will show information about you, any credit agreements you have (e.g. your mortgage or with a phone company), your financial connections (e.g. spouses/partners), and details of any missed/overdue payments on credit agreements.
What happens beyond 12 months with the Experian service?
At the end of the 12-month period the individuals will get an email to say their subscription is coming to an end and the options available to them.
How up to date is Experian? For instance, if someone set up a credit agreement today, would they tell me today?
Through your Experian Identity Plus subscription*, you will be offered daily alerts as to whether something has changed within your credit report. The subscription also allows you to lock your Experian credit report to help stop fraudsters taking out agreements in your name.
I have been advised to use CIFAS as well. Is this necessary?
Experian is a member of CIFAS (Credit Industry Fraud Avoidance System) and can access data related to confirmed fraud cases. CIFAS focuses on fraud prevention; Experian offers identity verification and fraud prevention.
I already have an Experian account, or I have used Experian in the past. What should I do?
If when you log into Experian using the code we have given you, and you are using your personal email address, you may be told that you already have an account under that username. In this case either continue to use your existing account if you are still paying for it and let us know that you do not need the code or create a new account using a different email address.
If you need further assistance, please call the Experian support line on 03444 818182.
