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Registered bodies have a number of responsibilities. They have to follow Disclosure Scotland's Code of Practice.


Registered bodies must:

  • handle, store and dispose of disclosure records securely
  • remove barred employees from regulated work
  • tell Disclosure Scotland if an employee causes harm or risk of harm to a child or protected adult
  • only use disclosure records for the reason they were originally requested
  • always have a lead signatory
  • keep countersignatory details up to date, including letting Disclosure Scotland know when signatories leave the organisation

Countersigning an application for a higher level of disclosure than you’re entitled to is an offence, so it’s important you know the right disclosure level to apply for.

Registered bodies also need to:

  • check PVG Scheme Records before allowing someone to do regulated work
  • use vetting information fairly when deciding whether to employ someone
  • get their own copy of a Scheme Record, even if the person is already a PVG member through another organisation 
  • tell Disclosure Scotland when a PVG member leaves the organisation
  • have a written policy describing how they manage disclosure information. There's sample policies to help
  • keep track of disclosure applications and certificates. There's a template spreadsheet to help
  • only share disclosure information with third parties if they have consent from the applicant or in other specific circumstances. For example, if countersigning on behalf of a third party as an umbrella body  
  • only keep disclosure certificates for as long as they need them

Registered bodies should not:

  • rely only on disclosure checks when deciding if someone is suitable for a post
  • ask applicants to tell them about all spent and unspent convictions

Asking about people's convictions

It’s against the law to ask applicants about all their convictions. They only have to declare ones relevant to the job they’re applying for.

For example, if the role only qualifies for a basic disclosure, organisations can only ask about unspent convictions. If the role qualifies for higher level disclosures, they can only ask about unspent convictions and relevant spent convictions.

There's guidance for basic disclosure or higher level disclosure, including advice on what applicants need to declare.

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