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).
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 email@example.com giving full details of the role and why you think it may require a PVG check.