People & Organisational Development

The Protecting Vulnerable Groups (PVG) (Scotland) Act 2007 came into being as a response to the Bichard Inquiry report that called for a registration scheme to be set up for all those who work with children and protected adults.

Following the amendment to the Disclosure (Scotland) Act 2020, which focused on protecting the public whilst balancing the need for people to move on from offending and simplified the process for disclosing criminal history information, the changes to the PVG Scheme which took effect from April 2025, gave new powers to Disclosure Scotland.

From April 2025, it became a legal requirement for individuals to become a member of the PVG Scheme when carrying out a regulated role with children, protected adults, or both.

In 2025, ‘regulated work’ was replaced with ‘regulated role’.  Roles which were included under regulated work, became regulated roles and ‘work’ which was deemed to be regulated, remained regulated.  However, the introduction of the ‘regulated role’ brought new roles into the PVG scheme which were not previously defined as regulated work.

The PVG scheme is a Scotland-wide scheme for Scottish employers and does not extend to the rest of the UK. However, it should be noted that it does cover and include conviction information from the whole of the UK and overseas.

To require PVG scheme membership the individual must be undertaking a ‘regulated’ role with children/and or protected adults.  It is against the law to request PVG scheme membership if the role the individual will be employed in does not fall into the definition of a regulated role. Advice should be sought from your local People & Organisational Development team, usually at the point of grading a job description, to determine whether the roles requires PVG membership.

Normal Duties & the Incidental Rule

The role being undertaken must be part of an individual’s “normal” duties and not be incidental. The concept of normal duties is extremely important in limiting the scope within a regulated role.

• Normal duties can be considered as something the individual might be expected to do as part of their role on an ongoing basis. Normal duties exclude one-off occurrences and unforeseeable events.
• If the contact with children or protected adults is incidental to the role and not part of the person’s normal duties, they do not require PVG scheme membership.

Critically, Higher Education establishments are educational establishments whose target audience is adults. Therefore, it is considered incidental that a small number of students may be under the age of 18. Therefore, individuals who are employed to conduct activities for all students are not deemed to be in regulated roles in relation to work with children.

Regulated Roles

Only University employees who are specifically employed for the majority of their time in caring for, supervising and advising children and/or Protected Adults will require Scheme membership.

Those roles which require individuals to provide a “welfare service” i.e. a service which provides support, assistance, advice or counselling to individuals with particular needs, will be considered as regulated roles.

The service must be a service that:

• Is provided in the course of work to one or more persons aged 18 or over
• Is delivered on behalf of the University
• Requires training to be undertaken by the person delivering the service
• Has a frequency and formality attached to the service
• Is personalised to an individual adult’s needs OR requires a contract to be signed between the service provider and the recipient of the service prior to the service being carried out.

It should be noted that an individual is only a Protected Adult at the time they receive the service.

Roles within the University which are deemed to be regulated roles include:

Roles with Children

• Staff who may be involved in events organised for children or school visits
• Sports Attendants involved in delivering activities provided for children
• Staff or students who are required to work in schools

Roles with Protected Adults

• Disability Advisers (if providing a welfare service)
• Occupational Health Practitioners (if providing a welfare service)
• Counsellors (if providing a welfare service)
• Chaplaincy staff (if providing welfare service)

Roles with Children and Protected Adults

• Clinical Academic staff and students who undertake clinical duties
• Research Nurses with unsupervised one-to-one contact with Children and/or Protected Adults and/or who undertake clinical duties.

It should be noted that this list is provided for illustrative purposes only and is not intended to be exhaustive. Further advice and guidance is available from People & Organisational Development.

PVG applications are now online. The application is initiated by a countersignatory in People & Organisational Development then the applicant will receive an email that invites them to complete their details.

New members of staff who are already registered with the PVG scheme (through their previous employer) will be asked to complete a PVG Existing Member application which will register the University as their employer.

If a current member of staff is transferring internally within the University and is already registered with the PVG scheme (for the required list, whether Children, Protected Adults or both lists), then they do not need to complete an Existing Member application. The University will already be registered as their employer and will therefore be notified if there are any changes in the person's PVG scheme record.

The University must notify Disclosure Scotland when a PVG scheme member is no longer an employee, or where their membership is no longer required, and will be removed as an interested party in relation to the individual.

The Scheme has been designed to be quick and easy to use, streamlining administration as well as reducing costs. The Scheme is ‘live’ at all times with any new or relevant vetting information being added to the record so that the record is always active and up to date. In addition, the Scheme is portable allowing the member to change jobs or types of role within Scotland without the need to re-register.