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PVG – Disclosure Act 2020

The Disclosure (Scotland) Act 2020 Protection of Vulnerable Groups (PVG)

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The Disclosure (Scotland) Act went live on 1st April 2025. Here’s a quick reminder of what you need to know:

  • Membership of the PVG scheme is now a legal requirement for those carrying out a regulated role.
  • Replacing the concept of ‘regulated work’ with ‘regulated roles’.
  • Simplified disclosure products, and people having more control over their information.
  • An individualised approach to the disclosure of childhood offending and rights of review for convictions disclosed, to enhance fairness and proportionality.
  • The ability for Disclosure Scotland to impose conditions on PVG scheme members who are under consideration for listing.

There are also mandatory policies that you must have in place, these are:

  • Secure Handling Policy
  • Making a Referral Policy

Templates for these policies can be found on Volunteer Scotland Disclosure Services website via the following link: https://www.volunteerscotland.net/disclosure-services/guidance-and-resources#Regulated-Role-Guidance

Regulated Roles

From 1st April 2025, ‘regulated work’ will be replaced by ‘regulated roles’. It is expected that roles which were included under regulated work, will also be regulated roles. However, the introduction of ‘regulated roles’ will also bring new roles into the PVG scheme that were not eligible before the 1st April 2025. Examples include, football agents, talent scouts, hypnotherapists and certain hospital or hospice-based roles.

To help you assess the criteria for regulated roles, you can review the following documents on the Volunteer Scotland Website to help you decide the PVG schemes required:

If you are in a regulated role, you must become a member of the PVG scheme.

To check out if roles in your organisation / group need to be members of the PVG and for more information, guidance and support please click on the links below for Volunteer Scotland and Disclosure Scotland:

Keep your data up to date:

To ensure compliance with data protection legislation, organisations should notify Disclosure Scotland when a PVG scheme member stops doing regulated work with them. This will prevent organisations receiving information to which you are no longer entitled.

To do this, please email dsupdate@disclosurescotland.gov.scot with:

  • the individual’s name
  • date of birth
  • PVG number

Disclosure Scotland will then remove your organisation’s interest in the individual.

Your organisation should have records of PVG scheme members you are linked with. If you don’t, Disclosure Scotland can provide your organisation with a list of PVG scheme members that your organisation is linked to. Please request this by contacting our dedicated team at dsupdate@disclosurescotland.gov.scot and provide your counter signatory and registered body codes in your request.

By law, PVG scheme members need to tell Disclosure Scotland if their personal details have changed. By informing them, you will ensure that Disclosure Scotland holds accurate address and contact information for PVG scheme members. For information on how to update your PVG details, timescales and legal requirements please visit their website. Organisations can highlight this requirement to their employees and volunteers.

If you require any help to set up the process or need help to see if this is something that you need to do please contact Ann Wilson on 01294 443044 or email: ann@tact.scot.