Protection of Vulnerable Groups FAQs

Updated April 2025

What are our legal requirements?

It will be a legal requirement for individuals to be a member of the PVG Scheme when carrying out a regulated role with children, protected adults, or both. The University therefore must ensure that individuals who are to carry out a regulated role (paid or voluntary) have PVG scheme membership from 1 April 2025 onwards.

From this date, 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 1 April 2025. Examples include hypnotherapists and certain hospital or hospice-based roles.

To help assess the criteria for regulated roles, please refer to the following to help decide the PVG schemes required:

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

When is the PVG scheme grace period?

There will be a short grace period of three months after the PVG scheme becomes a legal requirement on 1 April 2025. This will ensure individuals, and the University do not immediately commit an offence if there are individuals who are not yet PVG scheme members but are currently working in regulated roles.

Neither the University nor an individual will commit an offence if the individual who is carrying out a regulated role has, before the 1 July 2025, made an application to join the PVG Scheme, even if Disclosure Scotland has not issued the result.

From 1 July 2025 onwards, two new offences will come into force. It will become an offence for:

  • anyone carrying out a regulated role to do so whilst not a member of the PVG scheme
  • the University to offer any type of regulated role to an individual unless a PVG scheme disclosure has been received.

This adds to the existing offences under the PVG Act. For example, it will continue to be an offence for an individual to seek, agree to do or carry out a regulated role if the individual is barred from working with children, protected adults or both. Similarly, the University must also not offer a regulated role to someone who is barred from that type of regulated role.

Disclosure Scotland will report individuals and the University to the police if they believe that any of these offences may have taken place. The penalty for these offences is up to five years imprisonment, a fine up to the statutory maximum, or both.

When does the 5-year membership start?

Disclosure Scotland will provide information on this in due course. This will be implemented from April 2026 onwards.

What is the age for a child and protected adult?

If you currently process PVG Scheme membership for regulated work with protected adults and you provide a service to people aged 16 and over as part of their normal duties, you may now require PVG scheme membership for regulated roles with children also.

Children Under 16 Years of Age in Regulated Roles

Children aged under 16 years of age generally cannot become a member of the PVG scheme.  

Individuals carrying out activities equivalent to a regulated role are only legally required to become a PVG scheme member from their 16th birthday.  

Where a child aged 15 years and 8 months or above (the minimum school leaving age in Scotland) is carrying out activities amounting to a regulated role and is anticipated to continue doing so beyond their 16th birthday, s/he can apply for PVG membership.

Are there examples of new regulated roles?

Yes, please read the regulated roles guidance published by Disclosure Scotland.

Examples of new regulated roles are:

  • sports and talent agents or scouts who work with children (under 18s) and represent children in future recruitment, training or employment with sports clubs or other organisations.
  • non-clinical hospital or hospice staff or volunteers who have unsupervised contact with children and/or protected adults.
  • Organisations providing a service to people aged 18 or over who are homeless (within the meaning of section 24 of the Housing (Scotland) Act 1987) and in receipt of counselling, therapy, advice, guidance or advocacy support in relation to health or wellbeing.
  • Organisations providing a service to people aged 18 or over who have experience, are experiencing or are at risk of experiencing domestic abuse and in receipt of counselling, therapy, advice, guidance or advocacy support in relation to health or wellbeing.

What are the new disclosure levels called?

From 1 April, the type of application you apply for will change:

  • PVG Scheme Disclosure (Join) - previously referred to as a Scheme Record to Join and an Existing Member Scheme Record. This will be required for new applicants joining the PVG scheme for the first time AND for those existing PVG scheme members adding a workforce they are not already a member for.
  • PVG Scheme Disclosure (Existing Members) - previously referred to as a Scheme Record Update. This will be required for those existing PVG scheme members who are updating their membership for a workforce they are already a member for.

The PVG scheme will be a legal requirement for individuals in a regulated role with children and/or protecting adults.

How long do applicants have to share their disclosure result?

On receipt of the online disclosure, the applicant has 14 days to share the result with the University.

Applicants will receive a reminder to share their disclosure result 5 and 12 days after the result is ready.

Will the applicant still be able to request a paper copy of the disclosure result?

The paper share option on the applicant’s online account will no longer be available from 1 April.

The University is open to the public for anyone to attend. Does this mean we need to request PVG schemes for both children and protected adults?

As the University is open to the public and not specifically targeted at children and/or protected adults, there is no requirement for the majority of colleagues at the University to obtain PVG membership as any children or protected adults who attend, would be considered as incidental contact.

If individuals are undertaking a regulated role, delivering online support from England to people in Scotland, will they require a PVG scheme disclosure?

No, as the individual carrying out the role will not be in Scotland this is not considered to be a regulated role.

If, however, the individual lives in Scotland and undertakes online support and/or attends the University to deliver either all or part of their role in-person, then s/he will require PVG scheme membership.