Disclosures FAQs

31 October 2020

We've answered some of your Disclosures Frequently Asked Questions. Contact us if you have any further questions.

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  • What roles need a PVG?

    In brief, work or volunteering which involves certain activities with children (under 18) or protected adults (aged 16 or over) which is regular and the person’s normal duties, qualifies for a PVG check. Some of the types of activities are teaching, training, instructing, supervising, caring for, being in sole charge, giving advice and guidance in relation to health and wellbeing.

    For protected adults, we also have to consider both the service you’re providing and who it’s provided to, which is a little more detailed. The organisation needs to be either a Welfare, Care, Health or Social Care organisation and the adults you provide your service to need to have particular needs. A particular need is a specific requirement an individual may have arising from physical or mental illness or disability which may disadvantage that person when compared to the rest of society.

    We have checklists for both children and protected adults which list the full range of activities (including determining if your adult service meets the criteria) to help you decide if someone is doing regulated work which qualifies for a PVG check. Check out the Resources section of our website.

  • What roles don’t need a PVG?

    There has been a rapid increase in 'community volunteering' in response to local needs. Many organisations are concerned that until a PVG has been accessed, they will be unable to utilise new volunteers, increase their capacity or introduce new services such as telephone befriending and community transport.

    While many of these activities may be considered a regulated work activity, we need to give further consideration to whether (at this time) the new volunteers will be carrying out their role regularly and as part of their normal duties. We also need to consider whether the activities are being directed at children or protected adults, or more generally to the community, as not every person in self-isolation will have symptoms of the virus (e.g. they may be self-isolating as someone else in their household has symptoms, they may have an underlying condition which puts them at greater risk or they may be self-isolating due to Government advice based on their age).

    In order to qualify for a PVG check, new volunteers would need to be carrying out a regulated work activity with children or protected adults regularly and as part of their normal duties with an organisation. As we are in the very early stages of self-isolation, it’s currently not possible to determine if the activities will be regular or normal duties. Your organisation may also consider that the new services or increased provision is in response to a crisis / emergency situation (which would not require a PVG). 

    There are several support activities which definitely do not require a PVG check such as shopping, cash handling, having access to people's details and dog walking. Each organisation has to risk assess these activities and consider whether there is a need for any further safeguarding such as supervising new volunteers more closely.

  • Can PVGs be transferred?

    No.  A PVG certificate is issued in relation to a specific role and workgroup(s) within a named organisation. When an organisation accesses a PVG check, they registered their interest in the applicant so that they are notified if the members status changes to either 'barred' or 'considered for listing'. This is why scheme members still need to complete another form when they move to another organisation. It is also worth bearing in mind that the scheme member will also have a copy of their PVG which they can share if they choose to.

  • Can organisations share PVG information?

    Yes, section 80 of the Disclosure Scotland Code of Practice gives guidance on this. Care must be taken to ensure the organisation information is being shared with, is entitled to PVG information for the role in question and the scheme member must give you written consent to share their information. You should retain this permission in case there are any queries about sharing PVG information in the future. It is also worth bearing in mind that the scheme member will also have a copy of their PVG which they can share if they choose to. 

    Section 86 and 87 of the Code of Practice allow for information to be shared in relation to health and education transport services. The Code allows information to be shared with specific bodies (e.g. a school, college or health body). Please refer to the Code for full details of this exemption. The Code of Practice can be found on Disclosure Scotland’s website.

  • How do we undertake an appropriate identification check on a PVG applicant?

    At the current time as we all practice social distancing how do we undertake an appropriate identification check on a PVG applicant? 

    As a group that is accessing disclosures it is your decision as to what pieces of identification documentation you check and how you see them to ascertain that the applicant is the person whose documentation you are seeing.

    These are some of the options available to you in practicing social distancing but still being able to submit a disclosure-

    1. They scan/photograph the documentation and send them to you as attachments via email or text message.
    2. Copies of the documentation are sent through the post.
    3. Using video via phone, webcam or similar to check the identification documentation. They show it to you via the camera and you can note relevant information as required.
    4. Information is dropped off to you via your letterbox and then returned to the applicant once it’s been checked.
    5. As a last resort face to face identification can be undertaken but please remember to follow the guidelines on social distancing.
  • Can I order paper PVG applications?

    No. We are currently unable to send paper forms to organisations as our office is closed. We will not action any requests which we receive during the period our office is closed. Please refrain from submitting any requests for paper applications until our office is open again.

    In the meantime you can however submit your PVG application via the Digital Routine Application here or a COVID-19 Response Application (process and forms linked above). This is an efficient service which allows the process of applying for a PVG to continue.

  • Do I need a PVG check for new roles, new staff/volunteers, change of duties in response to Covid 19?

    We've had some queries around eligibility for PVG for staff and volunteers in organisations who are being moved into a regulated work role temporarily to help out in critical areas, and whether it is their normal duties. 

    We have also been asked whether PVG would be required in relation to new staff and volunteers taking up a variety of roles in response to the ongoing covid-19 virus and self-isolation. 

    In order to be entitled to access a PVG check, the role must involve at least one of the regulated work activities (see our children and adult checklists in the resources section of our website), must be the applicants normal duties and for roles with adults, the organisation must also meet the definition of a care, welfare, health or community care organisation (see our adult checklist).

    Normal duties

    The PVG Explanatory Guide does allow for unforeseen circumstances to be excepted from PVG (meaning that no PVG is required).  If the activity is a one-off or someone is placed into a role as emergency cover for a very short duration, then it is unlikely to meet the “normal duties” test. 

    However, as the covid-19 situation is likely to go on for some time, if the organisation is anticipating that those staff/volunteers will move into the regulated work roles for as long as required, then that could become their “new normal duties”, even though it is temporary.  Therefore they would be eligible for PVG, and it would be an offence for an organisation to place someone who's barred into a role with a group (children or adults) they are barred from. It would also be an offence for a barred person to apply for or carry out a role with a group they are barred from working with.  

    It is for the employer to decide whether the placement is temporarily someone’s “normal duties” or not.

    Community volunteering/telephone befriending

    The normal rules around welfare service and targeting adults with particular needs (the definition of a welfare service and particular needs are detailed below) still must be met before these posts would be eligible for PVG.  Delivering shopping, having access to cash, having access to peoples details or giving someone a cheery phone call are unlikely to be a regulated activity during the Covid restrictions any more than it would be outwith these circumstances.

    For those roles which do meet the criteria for a PVG check, please refer to the information on priority processing of applications for essential care, welfare and support roles which can be found in the covid-19 section of our website. 

    If you are still unsure whether you need to access a PVG check, please email disclosures@volunteerscotland.org.uk giving full details of the role and why you think it may require a PVG check.

  • Who do I email my completed forms to?

    All applications, Digital Routine Applications and COVID-19 Response Applications, must be returned to disclosures@volunteerscotland.org.uk

    Please ensure you do not email your forms directly to a member of the VSDS team. This will cause a delay in your application process.

    Full detailed step by step processes are available on the following pages: