How to carry out PVG and disclosure checks

The Safer Recruitment Working Group agree which conviction check is most suitable for each job title taking into account Disclosure Scotland’s Regulated Roles lists in relation to PVG Scheme membership.

For posts that require PVG membership, person specifications should state “maintain PVG Scheme membership” and job profiles should include a statement under the demands section as follows: “This job requires contact with vulnerable groups, therefore you will require to gain/maintain PVG Scheme membership”.

For posts that require Disclosure checks, the person specifications should state “satisfactory disclosure check” in the essential criteria.

When recruiting to vacant posts requiring PVG/Disclosure, a screening question is included in the application form.  Candidates will also be advised at this stage of the payment arrangements.

Types of criminal records checks

Level 1 disclosure replaces the previous Basic disclosure.  Level 1 disclosure is available for any purpose, for example, employees working with cash. These will show:

  • unspent convictions
  • any notification requirements (instructions someone must follow if they're on the Sex Offenders Register)

Level 2 disclosure replaces most Standard disclosure checks which are required for roles such as solicitors and accountants.   All Level 2 checks will show:

  • unspent convictions and unspent cautions (but not a childhood caution)
  • certain spent convictions and certain spent childhood convictions and children’s hearings outcomes
  • any notification requirements (instructions someone must follow if they're on the Sex Offenders Register)
  • other relevant information held by the police

Level 2 with barred check replaces most enhanced disclosures which are required for roles which require additional checks to show if you're barred from working with children or protected adults but are not eligible for PVG scheme membership for example, other appointments involving access to children or protected adults other than through regulated work such as those living in a household with foster children. A Level 2 with barred list check will show the baseline information that's disclosed on all Level 2 disclosures.  It will also show:

A PVG scheme disclosure is mandatory for people in a regulated role with children or protected adults – See next Section PVG Scheme. For example, a teacher or carer. This disclosure level is known as a 'Level 2 with PVG' in legislation.  Employees in relevant roles will need to join the PVG scheme and keep their membership updated.   A PVG scheme disclosure will show:

  • the baseline information shown for all Level 2 disclosures
  • that you're a member of the Protecting Vulnerable Groups (PVG) scheme
  • if you're under consideration for inclusion on the barred lists for work with children or adults
  • if you have had any prescribed civil court orders 

PVG Scheme

Employees must hold PVG membership for the regulated workforce they are working with before they start working with these groups.

New Employees

  • Candidates who are already PVG members and working within the same regulated workforce will be required to add Falkirk Council onto their membership.   Option on online application - Existing
  • Candidates who are already PVG members but required to work with a different regulated workforce, will be required to join the scheme for that particular group.  Falkirk Council will be added on to their membership.  Option on online application - Join
  • Candidates who are not already PVG members will be required to submit an application to join the PVG scheme.  Falkirk Council will be added on to their membership.  Option on online application - Join 

Existing employees

  • Employees who are not already PVG members, who apply for a regulated role will be required to submit an application to join the PVG scheme
  • Employees who are already PVG scheme members through their existing employment with Falkirk Council who apply for a regulated role within the same regulated workforce do not require to do a further PVG check. Managers should however make sure that the relevant details are recorded on the Council’s HR/Payroll system
  • Employees who are already PVG scheme members but who apply for a job within a different regulated workforce will be required to join the scheme for that particular regulated group.  Option on online application - Join
  • In exceptional cases, a further update/record can be required as part of a risk assessment process 

PVG Scheme – Leaving employment

  • It is the responsibility of the individual to notify Disclosure Scotland if they leave employment with Falkirk Council.
  • HR will notify Disclosure Scotland regularly of those who have left employment to ensure we do not receive updated information.  

Confirmation of identity

  • Three forms of ID are required which, as a minimum, should confirm the candidate’s date of birth, national insurance number and current address, for example, photocard or paper (not counterpart) driving licence, passport, utility bill, rental agreement/mortgage, or bank statement.
  • Original identity documents, not copies, should be checked at interview and the recruiting manager should ensure that these are valid on the date of check, if applicable. Utility bills should be provided from a period within the previous three months and should be addressed to the candidate. The Recruitment Checklist (External and SSSC) or Recruitment Checklist (internal excl SSSC)  must be completed, confirming which documents have been checked.
  • Evidence provided of the candidate’s identity should be checked and compared against the details provided on the recruitment application form.
  • Please contact HR if you are unsure about combinations of documents. Photographic ID should be provided where possible.

Disclosure checks

A disclosure certificate would be required for all external candidates where this is required for the post.

Where an existing employee applies for an internal post, a new disclosure is only required if there is a change in the level of disclosure required for the new post.

Applying for Disclosure & PVG

Applications for disclosure products are managed online.  The requirement for disclosure/PVG should be noted on the recruitment checklist and actioned by the relevant team.  Some teams within the Council have countersignatories who can action applications, such as Resource Managers in High schools; however, for those who do not, Staffing & Recruitment will assist managers with relevant checks, which are managed through an online portal.  Information on countersignatories can be obtained from HR Helpdesk. Candidates must pay for these checks themselves. This can be done on the online application, or if they wish for this to be done as a salary deduction, for either option, they must complete the Disclosure and PVG Payment Form and return it to initiate the application process and authorize the deduction to be made from their salary. 

All Level 1 & 2 Disclosures including PVG Scheme

  • The individual in conjunction with the manager will require to complete a Disclosure & PVG Payment Form and return to the associated countersignatory within their relevant team or to staffing.recruitment@falkirk.gov.uk as required.
  • The Disclosure & PVG Payment Form, along with the confirmation and verification of identity documents, will initiate the relevant countersignatory to start the online application process within the Disclosure Scotland Portal.
  • The relevant fee, depending on the PVG product/application required as above, will either be paid for by card by the applicant or be deducted from the individual’s salary once they have started in their new post depending on the option they choose.
  • Disclosure Scotland will then send the individual an email asking them to complete their section of the application.  Individuals should do so as soon as possible as delays will impact their appointment start date.  The link will be accessible for 14 days and if this is not completed in this timeframe, a new application will be needed.
  • The countersignatory/Staffing & Recruitment Team will receive an email from Disclosure Scotland advising that the individual has completed their section of the application and that it is being processed.
  • Once the application is processed and completed, the individual will be notified direct from Disclosure Scotland that their Certificate is available within their online account to be able to view and share within 14 days of receipt.
  • Individuals must then consent to sharing a copy of their certificate with the countersignatory, or to notify Disclosure Scotland that they are seeking a review of the content of their disclosure.
  • Individuals should follow the instructions in their email/online account.  If they do not share their information with us within the 14 day window, a new application may be needed and the individual will be liable for the additional cost of this. 

Guidance from Disclosure Scotland is noted below: 

If the individual is unable to complete the application online, please contact the Staffing & Recruitment Team for support. 

Outcomes of checks

Criminal Convictions

On receipt of Disclosure/PVG certificates, HR will notify managers if there are any convictions on the certificate and they will be asked to carry out a risk assessment, to consider if any information disclosed makes the candidate unsuitable for employment.

More information is available in How to carry out PVG and Disclosure Risk Assessments

Satisfactory checks

If there are no conviction on the certificate and the candidate is not barred from working with children or protected adults  a clearance form must be completed and uploaded to document storage on MyView.

Countersignatories must also record Membership numbers and disclosure certificate numbers along with countersignatory details and relevant dates on the HR/Payroll (Resourcelink) system for future reference.  Guidance for countersignatories on this can be found on the relevant Teams Channel.