Protection of Vulnerable Groups Scheme

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1. Policy Statement

The University of Glasgow is committed to safeguarding children and protected adults by ensuring that individuals in regulated roles are appropriately vetted and monitored. This policy aligns with the Disclosure (Scotland) Act 2020 and reflects the legal requirements effective from 1 April 2025, including the mandatory PVG scheme membership for regulated roles.

This policy aims to:

  • Ensure compliance with the Disclosure (Scotland) Act 2020 and associated regulations.
  • Outline procedures for identifying regulated roles and managing PVG scheme membership.
  • Promote a safe environment for children and protected adults engaged with the University.

2. Scope

This policy applies to all University staff, students, volunteers, and contractors engaged in regulated roles involving children or protected adults. Regulated roles include, but are not limited to:

  • Teaching, supervising, or caring for children or protected adults.
  • Providing advice or guidance to children or protected adults.
  • Positions of trust or authority over children or protected adults.

Note: The term “regulated roles” replaces “regulated work” as per the 2020 Act.

3. Definitions

Child: An individual under 18 years of age.

Protected Adult: An individual aged 18 or over who receives certain types of care, support, or welfare services.

Regulated Role: A role involving specific activities with children or protected adults, as defined by the 2020 Act.

PVG Scheme: A membership scheme managed by Disclosure Scotland to ensure individuals are not barred from regulated roles.

4. Legal Requirement Effective 1 April 2025

Mandatory PVG Membership: Individuals must be PVG scheme members before commencing any regulated role.

Offences: From 1 July 2025, it is an offence for:

    • An individual to carry out a regulated role without PVG membership.
    • An organisation to offer a regulated role to someone without PVG membership.

Disclosure Levels: Introduction of Level 1 and Level 2 disclosures, replacing previous disclosure types.

Information Sharing: Applicants must share their disclosure results with the University or notify Disclosure Scotland of their intent to seek a review.

5. Principles

The University will carry out its obligations under the 2020 Act in accordance with the following principles:

  1. The University will request PVG membership only where it is necessary and required under the law;
  2. Processes will be workable, proportionate and consistent;
  3. Information will be processed and handled sensitively and confidentially in full compliance with the Data Protection Act 1998 and other relevant legislation (“data protection legislation”).
  4. We will adhere to the Code of Practice as issued by Scottish Ministers under Part V of the Police Act 1997.

Having a criminal record will not necessarily prevent employment with the University. This will depend upon the nature of the position, together with the circumstances and background of the offences

6. Normal Duties and the Incidental Rule

The work 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.

7. PVG Disclosure Levels

For the University, the PVG scheme now categorises disclosures into four distinct types:


1. Level 1 Disclosure

This has replaced the Basic Disclosure.

Anyone can apply for a Level 1 disclosure. It is most commonly used to share with employers, but individuals can apply for one for personal reasons.

Level 1 will show any unspent convictions.

 

2. Level 2 Disclosure

This has replaced the Standard Disclosure.

The Level 2 Disclosure is only used for specific roles and shows any unspent convictions and certain spent convictions.


3. PVG Scheme Disclosure (Join)

For individuals joining the PVG scheme to undertake regulated work with children and/or protected adults.

Includes:

  • Unspent convictions and certain spent convictions
  • Unspent cautions
  • Court orders and notification requirements
  • Other relevant information provided by the police
     

4. PVG Scheme Disclosure (Existing Members)

For current PVG members applying to work with a new vulnerable group (e.g., from children to protected adults).

Includes:

  • The same vetting information as the PVG Scheme record.

8. Recruitment Procedure

The further particulars for roles which require the postholder to undertake duties which fall within the scope of the Act will state that an offer of employment will be made on confirmation of a satisfactory PVG Scheme record check.

The University requires all relevant new employees, or those who transfer within the University to a new role which involves them undertaking duties which fall within the scope of the Act, to undertake a satisfactory PVG Scheme Disclosure check.

In some cases, individuals may already be members of the PVG Scheme if it has been required of them by another employer or for voluntary work they undertake.

9. PVG Scheme Record Application and Countersignature Process

The PVG Scheme application process is online. The application is initiated by either a countersignatory in People & Organisational Development (staff) or, a counsignatory in a College or School (student). 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 update. 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.

9.1 Responsibilities

  • The Designated PVG Countersignatory is responsible for assessing the need for PVG membership, guiding applicants, and countersigning applications on behalf of the University.
  • The University ensures that all countersignatories are registered and trained in accordance with Disclosure Scotland’s requirements.
  • When the application has been initiated, the Applicant is responsible for completing the PVG application process and providing accurate information.

9.2 Application Process

Step 1: Identification of Requirement

The need for PVG scheme membership is identified through course requirements, role responsibilities, or placement activities. Confirmation may come from an academic school, People & Organisational Development or a placement provider.

Step 2: Initial Contact and Guidance

The relevant PVG Countersignatory details will be shared with the applicant to begin the PVG application process. Guidance will be provided on how to complete the PVG online application.

Step 3: Completion of Application

The applicant completes the appropriate PVG application (new membership or existing member) and submits the form online along with the required identification documents.

Step 4:  Verification and Countersignature

The PVG Countersignatory verifies the applicant’s ID documents and ensures all information is complete and accurate. The application is then countersigned.

Step 5:  Submission to Disclosure Scotland

The completed and countersigned application is submitted to Disclosure Scotland for processing.

Step 6:  Outcome and Record Keeping

Once processed, the PVG scheme record is issued directly to the applicant to share with the University to progress recruitment or placement into a new role.

9.3 Timescales

Applicants are advised to begin the PVG process as early as possible, as processing times can vary. Delays in obtaining a PVG scheme record may impact the commencement date for a role or the ability to undertake placements or begin certain courses of study.

10. Existing Staff and Role Changes

Role Changes: Staff moving into regulated roles must obtain PVG membership before commencing new duties.

Notification of Changes: Schools/Services must inform People & OD when staff leave regulated roles to update Disclosure Scotland records.

11. Referrals to Disclosure Scotland

The University has a legal duty to refer individuals to Disclosure Scotland if:

  1. They have harmed a child or protected adult.
  2. The harm is serious enough to warrant removal from regulated roles.


Referrals must be made within three months of the criteria being met.

12. Data Protection and Confidentiality

All PVG-related information will be handled in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Access to such information is restricted to authorised personnel.

13. Useful Links

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Policy Name                    Protection of Vulnerable Groups Scheme
Last reviewed May 2025
Owner P&OD - Policy and Employee Relations