Working with children, young people, or vulnerable adults? Then you need to read this…
Compliance with the Protecting Vulnerable Groups (PVG) scheme is a legal requirement under the Disclosure (Scotland) Act 2020. The legislation applies to everyone whose work/volunteering involves any kind of disclosure process. Changes to this legislation came into effect on 1 April 2025, and these can be categorised in terms of…
We’ll explain below in more detail how these changes affect Scotland’s youth theatre sector, and our recommended actions to take.
We’ve also added some additional resources and links to information sessions at the bottom of the page, but please get in touch with us if you need further guidance.
What this means for Scotland’s youth theatre sector
Safeguarding
The concept of ‘doing regulated work’ under the previous version of the scheme has been replaced by ‘regulated roles’ that qualify for PVG Scheme membership.
In summary, regulated roles for children involve paid or unpaid work with those under 18 where the normal duties involve…
- Teaching, instructing, training or supervising children.
- Being in sole charge of children.
- Providing advice or guidance to a child or to particular children which relates to physical or emotional well-being, education or training.
The activity involved must be regular and not incidental to the role.
Volunteer Scotland provides a basic checklist of what constitutes a ‘regulated role’ and the Scottish Government provides a comprehensive legislative description.
- As of 1 April 2025, it is a legal requirement for anyone aged 16+ carrying out a paid or voluntary regulated role with children (i.e. aged under 18) and/or vulnerable adults to be a member of the PVG Scheme.
- All current members of the PVG Scheme were moved to the new digital system after 1 April 2025. There was a three-month grace period to administer this, until 1 July 2025.
From 1 July 2025, two new offences came into force. It became an offence for…
- anyone carrying out a regulated role to do so whilst not a member of the PVG scheme ;
- organisations to offer any type of regulated role to an individual unless they have received a PVG scheme disclosure.
Simplifying
The new concept of ‘regulated roles’ makes it easier for employers to identify when to use the PVG Scheme.
All PVG applications, including for first-time membership and Scheme Record Updates are made digitally, and individuals and organisations are able to view PVG application results online.
Privacy
The ‘lifetime PVG membership’ under the previous scheme has now ended. It was replaced by a (renewable) five-year membership. Implementation for this is scheduled for April 2026. This will ensure employers are not notified of sensitive information on an individual after they have left regulated roles/work, reducing the risk of non-compliance with data protection legislation.
There is a minimum age limit of 16 years on obtaining a disclosure check. This means that under 16s are allowed to work in regulated roles without PVG membership.
The new digital application process means that individuals no longer have to share all their personal details with an organisation. This provides greater privacy protection for individuals and reduce the risk of identity theft.
YTAS recommends taking the following actions
Keeping your youth theatre organisation right
Get informed
- Use the ‘further information and resources’ listed below to understand how these legal changes affect your youth theatre.
Make sure you are legally compliant
- Confirm all your paid and unpaid staff aged 16+ in regulated roles are members of the PVG scheme.
- Update your policies, recruitment practices and admin processes to reflect any changes in managing PVG applications and memberships.
- Make sure everyone involved is informed about the updates and has the necessary training to implement new practices and processes.
Keeping yourself right as a freelance youth theatre practitioners
Get informed
- Use the ‘further information and resources’ listed below to understand how these legal changes affect your freelance work.
Check employer compliance
- Make sure every organisation employing you in a regulated role starts a new PVG application for you before you start work. This is their legal responsibility. Depending on your situation, this application will either be for…
- A Scheme Record (for new applicants joining the PVG scheme for the first time.)
- A Scheme Record Update (for current PVG members whose existing ‘workforce’ membership covers the requirements of the role (e.g. working with ‘children’ or ‘vulnerable adults’.)
- An Existing Member Scheme Record (for current PVG members applying to change workforce type or an additional category (e.g. ‘children’ or ‘vulnerable adults’).
- Confirm each new employer’s policy on who pays the PVG application fee before you start work. This is at the discretion of individual employers. Some may cover it, while others may ask you to pay.
Stay legally compliant
- If you’re a PVG scheme member and you change your name or gender, by law you must tell Disclosure Scotland within three months of doing so.
Keep your PVG Record up to date
- Make sure the details you’ve shared with Disclosure Scotland are current (e.g. address / email address / contact number /employer). This ensures they can contact you quickly if needed and information is sent to the right place.
Further information and resources
Read
- Disclosure Scotland explains the changes which meant that the Protecting Vulnerable Groups (PVG) scheme became a legal requirement from 1 April 2025.
- Disclosure Scotland explains how an organisation must start a PVG application for a worker or volunteer.
- Disclosure Scotland explains how an individual must complete a PVG application they have been sent by an organisation which has offered them work.
- The Scottish Government website has the most up-to-date information.
Watch
If you would prefer, you can watch a one-hour recording of Volunteer Scotland’s information session, which was co-hosted by SCVO in December 2024.
