The implementation of the Disclosure (Scotland) Act 2020 on 1st April 2025 has brought significant changes to the Protecting Vulnerable Groups (PVG) scheme.
We hope the following FAQs will help answer questions that leaders may have at the moment. If you have any questions that you don’t feel are answered here please contact support@boys-brigade.org.uk or 0300 303 4454.
What has changed?
The main changes that have come into effect from 1st April are:
- Membership of the PVG scheme is now a legal requirement for those carrying out a ‘regulated role’.
- The concept of ‘regulated work’ has been replaced with ‘regulated roles’.
- There is a three-month grace period from 1st April to 30th June for PVG scheme applications to be submitted for individuals who are currently in a regulated role.
What are ‘regulated roles’?
‘Regulated roles’ has replaced the concept of ‘regulated work’. For a role to be regulated, these activities must be a regular and expected part of the role – not incidental.
The introduction of regulated roles means that new roles have been brought into the PVG scheme – those in positions of responsibility, such as Trustees, will require PVG membership if their role involves power or influence over children/young people or vulnerable adults.
What does this change mean for me and my BB Company?
A regulated role includes ALL volunteering roles with children and young in The Boys’ Brigade.
The Act should have no significant impact on your BB Company if you are already following the Brigade’s Safer Recruitment policies and procedures and all your leaders are fully registered (and therefore PVG checked for their role).
If I have adults volunteering in my Company not currently registered what should I do?
Any adults not fully registered, and therefore not PVG checked for their role, MUST NOT attend any BB activities. It is now a criminal offence if they do. Find out more about how to register a new leader here.
How long will my PVG membership last?
The ‘lifetime’ PVG membership will end and be replaced by a (renewable) five-year membership from 1st April 2026.
Do I require separate PVG updates for different roles I have within the BB?
No, your PVG membership through BB will be sufficient for all your roles carried out within the BB.
What should we do if a parent/carer comes along to the Company to observe a session with consideration to become a leader?
A parent/carer can come along to observe one session if they are interested in becoming a leader. They must not be involved in any care or supervision of children young people. At least two registered BB leaders should be present in line with polices and procedures. If they would then like to become a leader they cannot attend until the Safer Recruitment process has been fully completed.
What should we do if a child or young person requires the support of a parent/carer to be present during a session linked to additional support needs or a disability?
Where the parent/carer is an immediate relative of the child/young person and is solely responsible of the child/young person they do not require a PVG. They must not be involved in any care or supervision of any children or young people in the Company.
Is our Company Treasurer a regulated role and now requiring PVG membership?
It depends how this role is being fulfilled in practice. If the individual is for example only involved in book-keeping and has no contact with children and young people then they would not require PVG membership. However if they are also a Trustee, part of this role will include decision making and having power or influence over children and young people and therefore would require PVG membership.
I don’t work directly with children and young people in my role. Why am I now being asked to become a PVG scheme member?
The Disclosure (Scotland) Act has introduced additional regulated roles where PVG Scheme membership is now required. This includes those responsible for decision making, and those having power and influence in an organisation that benefits children and young people.
Is our Battalion Treasurer a regulated role and now requiring PVG membership?
Yes, as the Battalion Treasurer is an Office Bearer and part of their role will include decision making and having power and influence over children and young people.
If we are taking our children/young people to an activity run by an external provider (e.g. go karting) what should we do?
The external provider of the activity is responsible for ensuring that their employees or volunteers have the correct PVG membership. In advance of any visit and as part of you risk assessment process for the activity you should ask for information about the provider’s safeguarding policy and procedures.
If we have a young person from our Company volunteering within another organisation as part of their Major Awards what should we do?
If their volunteering involves working with children/young people (those under 18) and/or vulnerable adults they must become a member of the PVG scheme following their 16th birthday with that organisation.
If you have a young person from your Company volunteering within the Company (e.g. with Anchors age group) as part of their Major Awards they do not require PVG membership for this role.
What about a young person coming into volunteer within my Company as part of the Duke of Edinburgh’s Award (DofE)?
Young people aged 16+ who are coming into the organisation specifically to volunteer (e.g. as part of their voluntary service for DofE), and who are not already a member of the organisation, must be registered as a Young Leader/Youth Volunteer and have PVG membership for that role from the date of their 16th birthday.
What does this mean for visitors coming into our Company?
If you have a visitor coming in to the Company to give a presentation or lead an activity from a recognisable organisation (e.g. Guide Dogs for the Blind, or RNLI) their staff and/or volunteers are preforming a regulated role and they should have the correct PVG membership. You should ask for information about the organisation’s safeguarding policy and procedures to satisfy yourself. They will still be required to be under the supervision of registered leaders.
If someone is visiting the Company as a one-off (e.g. a member of the local community coming in to give a talk/presentation) then this would be incidental, not a regulated role and would not require PVG membership. However if an individual is coming into lead a series of sessions, this is no longer incidental, and they would need to be registered and have PVG membership for that role.