Policy
Protection of Vulnerable Groups Scheme policy
Our commitment to providing a safe and protected environment for its staff and students in compliance with the relevant legislation and statutory guidance
Updated on 16 March 2026
In line with updates from Disclosure Scotland this policy has been reviewed to reflect the changes taken effect as of 1st April 2025.
- ‘Regulated Work’ is now classed as ‘Regulated Roles’. If an individual is in a Regulated Role, then they are legally required to become a member of the PVG scheme.
- Both the University and the individual will be responsible for ensuring PVG Membership, if their role is classed as a ‘Regulated Role’.
- PVG checks are mandatory, and a legal requirement when working or agree to carry out, any type of regulated role (i.e. with children, protected adults or both) unless the individual already is a PVG scheme member for that type of regulated role.
- In addition, the individual is also deemed to be in a regulated role if they are a day-to-day supervisor or manager of someone doing related work. This means that if you are the manager of someone who requires PVG for their role, you will be required to have a PVG membership too.
More on these changes can be found here in our Policy Guide (SharePoint).
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Policy Statement
The Protecting Vulnerable Groups Scheme (PVG Scheme) is the membership scheme which was introduced to replace and improve upon the disclosure arrangements for anyone who work with vulnerable groups.
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Scope
The Protecting Vulnerable Groups Scheme (PVG Scheme), as outlined in the Protection of Vulnerable Groups (PVG) (Scotland) 2007 Act is intended to:
- to ensure that those who have regular contact with children and protected adults, through paid and unpaid work, do not have a known history of harmful behaviour
- providing protection and robust regulation making it easier for employers to determine who should be checked to protect their client group
- scheme membership applies to all staff classed in a ‘Regulated Role’
However, the definition of the PVG Scheme expects only a very small minority of HE staff to be doing regulated work and these are likely to be in quite specific positions (link to guide).
The information below and the PVG Scheme Policy provide information and guidance for managers and staff regarding the arrangements for undertaking disclosure checks at the University of Dundee.
Both the University and the individual will be responsible for ensuring they have the right PVG membership while working in a ‘Regulated Role’. If this is not in place, both parties can face legal consequences.
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Definitions
- Protection of Vulnerable Groups: mandatory membership scheme for anyone working with vulnerable groups
- Vulnerable groups:
- Children an individual aged under 18 years of age
- or Protected adults an individual aged 16 or over in receipt of one or more of:
- registered care services
- health services
- community care services
- welfare services
- Regulated Role: this has been changed from ‘regulated work’ and means an activity that has contact with children or protected adults.
- HE: Higher Education
- Incidental Activity: This relates to a regulated role where the activity is occurring incidentally to working with individuals, who may be classed as vulnerable.
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Roles and Responsibilities
Employees
- Ensure they understand whether their position is classed as a Regulated Role under the PVG Scheme
- Complete PVG membership application promptly if their role requires it
- Maintain active PVG membership for the duration of their employment in a regulated role
- Inform their manager and People immediately if there is any change in their PVG status
Managers
- Identify roles within their team that meet the criteria for Regulated Roles
- Ensure staff in regulated roles have PVG membership before commencing duties
- If managing someone in a regulated role, obtain PVG membership themselves as required by law
People Team
- Provide guidance to managers and staff on PVG requirements
- Facilitate the application process
- Oversee the PVG application process and liaise with Disclosure Scotland where necessary
- Ensure secure storage and confidentiality of PVG-related documentation
- Support managers in identifying regulated roles
The University
- The University is committed to providing a safe and protected environment for its staff and students at all times.
- We comply fully with the relevant legislation and statutory guidance, to ensure that where relevant, applicants and employees are members of the Protection of Vulnerable Groups Scheme (the PVG Scheme) which has been introduced by the Protection of Vulnerable Groups (Scotland) Act 2007 (the 2007 Act).
- We are committed to equality of opportunity for all and to providing an environment that is free from unfair and unlawful discrimination.
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Additional Support
- Disclosure Scotland & Protection of Vulnerable Groups (PVG) Scheme - Guide
- Disclosure Scotland PVG Scheme Membership Tool
- Disclosure Scotland PVG Scheme – Regulated Roles Guidance
- Disclosure Scotland PVG Scheme – Regulated Roles (video)
| Policy Name | Protection of Vulnerable Groups Scheme Policy |
| Owner | People Directorate |
| Approved by | |
| Implemented | |
| Last reviewed | 2026 |
| Review date | 2029 |
People Support team
[email protected]