PVG update | Important Changes

NO PVG, NO START, NO EXCEPTIONS

The Scottish government passed changes to the Protection of Vulnerable Groups (Scotland) Act 2007 and Disclosure Scotland have been providing updates and setting actions to help Sports Governing Bodies meet the compliance deadline of the 1^st of April 2025.
Scottish Gymnastics has been providing clubs with updates to our process and club process to support changing the way we all work to meet the requirements of the updated legislation.

The changes to the PVG process are:

PVG Scheme membership will become mandatory – complete
This means minimal change if any to club current practice which should follow the safer recruitment process of: NO PVG, NO START, NO EXCEPTION.
CHANGE: a person cannot start regulated role without having a PVG in place first – if they do this will be a criminal offence for the individual AND the club.

Regulated work will become Regulated Roles – ongoing
The criteria for those who need a PVG has changed with the legislation update. The existing list of roles which need a PVG in Gymnasts has not changed.  You can find these on the Scottish Gymnastics Safe Recruitment and PVG webpage: Safe Recruitment & PVG – Scottish Gymnastics.

We anticipate several additional roles will require PVGs within clubs. Scottish Gymnastics has undertaken a role assessment against the new Regulated Roles criteria. This has been submitted to Disclosure Scotland for approval. The updated list will be shared as soon as it is available.
Disclosure Scotland has set up a 3-month grace period for PVG applications to be submitted for these new roles that will need a PVG from the 1^st of April.

GRACE PERIOD: 1^st April 2025 -30^th June 2025.
Only applies to roles which need a PVG from 1^st of April 2025. This time scale is set by Disclosure Scotland. Any role that needs a PVG and does not have it by this date must stop activity or the individual will be committing an offence, the club will be committing an offence and insurance will be invalid.

CHANGE: From 1^st April 2025 for every role in the club, the club must undertake a regulated role assessment that looks like this:
Check to see if the role is on the Scottish Gymnastics regulated roles list:  Safe Recruitment & PVG – Scottish Gymnastics
If Yes – submit a PVG application as normal when required.
If No – Complete a regulated Role assessment by completing the Scottish Gymnastics PVG Regulated Role Assessment Jot Form: Scottish Gymnastics Club PVG Regulated Role assessment form.
The assessment will check if:
Is the role carrying out Regulated Activities as a “normal” part of its duties?
Does the role have contact with children or protected adults?
The safe sport team will confirm the outcome of the assessment and a PVG can then be applied for if required.

Action needed now!
To get ready for Regulated Roles Clubs will need to follow the following steps:
1. Identify all roles in your club – coach, helper, volunteer, committee, contractor etc and create role descriptions for all of these if not already in place.
You may want to keep track of these using a spreadsheet or word table which can be updated with PVG and safeguarding requirements.
2. Club admins should make sure that where possible, all club staff and volunteers are assigned the correct role on Justgo.
3. Check the following:
Is the role on the current list of roles requiring a PVG? – if yes, apply for a PVG now if one is not in place.
If no – wait for the updated regulated roles list and apply for a PVG for any new roles on that list from 1^st April.
If the role is not on the updated regulated roles list after 1st of April, complete Scottish Gymnastics PVG Regulated Role Assessment Jot Form:
Scottish Gymnastics Club PVG Regulated Role assessment form

Recap on previous changes
The following changes have already been implemented to the PVG process and previous updates/briefings cover them in more details, a short recap:

Revised Fee structure – complete
Disclosure Scotland has confirmed that volunteer PVG checks will continue to be free and there will be no fee increase for 2025 for checks.

PVG Scheme age restrictions – complete
a minimum age of 16 years for PVG applicants, there is no change for you, as this is already in effect within Gymnastics.

Digital access – complete
Both the application and results (certificates) are digital now.

PVG Scheme membership length – complete
Ending lifetime membership, replaced with time‑limited membership of five years, all PVGs processed by Scottish Gymnastics will now expire after 5 years.
All PVGs processed form the 1^st of April 2025 will automatically be the new 5 year limited membership.
For current PVG scheme members (lifetime memberships) Disclosure Scotland will inform the sector by 1^st of April 2026 what the transfer process will be. Further update will be provided when information is available. No action required form clubs at this time.

Changes to Processing body status – complete
Scottish Gymnastics now process directly through DS.

All clubs, as part of the membership renewal process now complete PVG processing agreements and must have core policies in place:
The club PVG suitability agreement – to be signed by the club Chair and counter signed by the Safeguarding Officer.
The PVG processor agreement – to be signed by the club Safeguarding Officer and/or any other individual who processes PVG for the club e.g. club manager, second safeguarding officer, secretary etc.
Safer Recruitment Process – club level policy – has been updated. All Clubs need to adopt this policy and the associated procedures (or ensure existing ones cover all content in the new templates), if they want to employ individuals in Regulated Roles. The policy and the agreements can be found under ‘PVG resources’ in the Safer Recruitment & PVG section of the Scottish Gymnastics website: Safe Recruitment & PVG – Scottish Gymnastics

Scottish Gymnastics PVG and Suitability Decision Policy – The policy governing the PVG process, roles and responsibilities and the suitability decision on appointment to regulated work, has been updated and placed in a single document replacing the current approach where parts of the process were covered in different policies and procedures. While some of the language has been updated there is no major change to the division of responsibility or the making of appointment decisions.
Consent Form – Scottish Gymnastics take consent from the individual to share information returned on the PVG certificate as part of the self-declaration the individual complete. The wording of the consent statement has been updated and no PVG will be processed until this item (self-dec and consent) is completed by the individual. Moving forward when the new membership system is lunched the Self declaration and consent process will be separated.

The way Scottish Gymnastics process PVGs on behalf of our member clubs is
changing. Disclosure Scotland, who oversees the PVG process, has completed a
review ahead of implementing updates to PVG legislation. They have asked sports’
governing bodies to update elements of the PVG process particularly around
consent and enforcing compliance with the code.

To support clubs through the change, we have reviewed and updated all the
policies and process documents. We have also created up-to-date templates for
clubs to use for their own compliance.

Please be assured that most of the process remains the same. However, it is
important you read all the information about the changes which are:

Scottish Gymnastics PVG and Suitability Decision Policy
The policy governing the PVG process, roles and responsibilities, and the suitability
decision on appointment to regulated work has been updated and placed in a
single document replacing the current approach. While some of the language has
been updated, there is no major change to the division of responsibility or the
making of appointment decisions.

Safer Recruitment Process – club level policy
This has been updated. All clubs must adopt this policy and the associated
procedures, or ensure existing policy covers all content in the new templates, if they
want to employ (paid or unpaid) individuals in regulated roles. You can find the
policy in the Safer Recruitment & PVG section of the Scottish Gymnastics website.

Consent Form
Scottish Gymnastics takes consent from the individual to share information
returned on the PVG certificate as part of the self-declaration form the individual
completes. The wording of the consent statement has been updated. No PVG will
be processed until the self-declaration and consent form is completed by the
individual. When the new membership system is launched later this year, the self
declaration and consent process will be separated.

Processing agreements
As the body who processes PVGs on behalf of clubs, Scottish Gymnastics is
required to show that both the clubs we process on behalf of, and the individuals
who access PVG information in those clubs, understand their responsibilities and
confirm they meet them. The roles and responsibilities have not changed. We are
recording compliance through two agreements that must be signed and returned:

The club PVG processing agreement – to be signed by the club chair and
counter signed by the safeguarding officer

The PVG processor agreement – to be signed by the club safeguarding
officer and any other individual who processes PVG for the club e.g. club
manager, second safeguarding officer, secretary etc.

The rest of the process stays the same:
The ID check and online PVG application request form
The eight-step end-to-end PVG process
Help and support from the Wellbeing and Safe Sport team

Action needed now!
To transfer to the new process clubs must complete the following steps:

1. sign and return the club PVG processing agreement.
2. sign and return the PVG processor agreement – one for each person who
administers the PVG process for your club. If you have more than one
person, please indicate who the lead PVG processor is.
3. adopt necessary policies in the PVG Processing Contract (templates
attached to this email).

We recommend completing and returning both agreements as soon as possible,
although this can be done at any time. However, if the agreements and any polices are
submitted at the point of PVG application, there may be a delay in processing PVGs, as
we are required to review agreements and policies.

Please note, clubs and the PVG processor will need to sign the agreements each year as
part of the club registration and membership renewal process.