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Before an organisation can register with Disclosure Scotland, it must decide which members of staff will be responsible for handling its disclosure checks.

One person will be its 'registered person' and 'lead signatory'. They'll be the main person responsible for making sure any private information the organisation receives is handled properly.

Your lead signatory should be a senior figure in the organisation with at least enough responsibility to have authority over any other 'countersignatories'.

Disclosure Scotland vets both lead signatories and countersignatories. The lead signatory will also be given a personal ID number to use when they countersign a disclosure application.


The lead signatory doesn't have to be the person who signs all the disclosure applications. There can also be a number of 'countersignatories'.

These are other staff members who can also be responsible for asking for employees' Scheme Records.

Countersignatories don't automatically become PVG Scheme members, get a certificate, or get Standard/Enhanced disclosure, (but may become a member separately if their main role requires it).

Disclosure Scotland regularly vets countersignatories to make sure they don't have convictions or other information that would make them unsuitable to receive sensitive personal information. If something happens that means they're no longer suitable to handle private information about employees, they may lose their right to countersign.

Countersignatories are given their own personal ID number. This is used when they countersign disclosure applications.

Help for signatories

Lead and countersignatories can get more advice from the following Disclosure Scotland guidance documents:

PVG Scheme guidance

A Countersignatory's guide to checking and completing an application to join the PVG Scheme

A Countersignatory's guide to checking and completing an existing PVG Scheme member application

Standard and Enhanced Disclosure guidance

A Countersignatory's guide to checking and completing a Police Act Disclosure application

Registered body tracking document for disclosure applications

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