Protecting Vulnerable Groups Checks

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					                                 Alzheimer Scotland

                           Safer Recruitment Manual

              Protecting Vulnerable Groups (PVG) Checks

1     Policy

      Please read this in conjunction with the document ‘PVG information 1 February
      2011’, which can be found on the Safer Recruitment section of the intranet, at:

      The Protection of Vulnerable Groups (Scotland) Act (2007) came into force in Scotland
      on 28 February 2011, and from this date PVG applications are required for any member
      of staff, or volunteer, who will be involved in ‘regulated work’.

      Regulated work is a new concept, defined in the Act, and it is a fundamental
      requirement, before submitting any application for PVG membership, that the recruiting
      manager confirms that the individual will be carrying out regulated work as defined.

              Adverts for posts that require a police check must carry the following wording
               “The successful candidate for this post will be subject to a criminal conviction
               check through Disclosure Scotland”.

              All new staff and volunteers doing “regulated work” require a PVG Scheme
               Record before they start work with vulnerable adults.

              In exceptional circumstances, a member of staff may be commenced in post
               before their PVG check is returned, providing:
                   o A senior manager has been consulted and no alternative option can be
                   o The PVG application has been countersigned and sent for processing
                   o The individual does not work unsupervised with vulnerable adults
                   o The reasons for the decision and an assessment of the risks are recorded
                       on file.

              Where training schedules make it desirable for a candidate to attend induction
               training before checks are complete and they are able to start their employment,
               this can be done on a sessional basis, provided there is no contact with
               vulnerable adults.

              Any member of staff moving to a different job internally to a “Regulated Work”
               position requiring a check and who has not been police checked within the last
               six months should complete a PVG application for processing. Retrospective
               checks will start February 2012 unless it is part of a service agreement and
               requires rechecking before then.

              Alzheimer Scotland complies with legislation on security, retention and disposal
               of all Disclosure Scotland/PVG paperwork. (Our Disclosure Scotland Statement
               of Compliance is on the intranet) Only Disclosure Scotland/PVG counter
               signatories see the organisation’s copy of the disclosure certificate.

HR Manual: Protecting Vulnerable Groups Checks                                        Page 1of 5
Owned by: HR Manager; Approved by: Policy Review Group ; Review due
                                                                           Alzheimer Scotland

             The decision as to whether an applicant is deemed suitable or not must be made
              by the recruiting managers involved with advice from the Disclosure
              Scotland/PVG counter signatory. Decisions about existing members of staff may
              require use of the Disciplinary Policy.

      Good practice tips

      -   Sessional staff that have not worked for the organisation for more than six months
          also require a further check. (Consider their availability and the £59 cost of the PVG
          Scheme membership)
      -   it is important not to assume that, because we may have applied for disclosure for a
          similar role, under the previous scheme, that a PVG application is relevant
      -   Refer to the ‘Guidance notes for Application to Join PVG Scheme’, available on the
      -   For additional support in completing the required documentation, or if your service
          or roles have changed significantly, please contact the HR team.

2     Disclosure Scotland/PVG – Procedure

The following are authorised counter signatories for Disclosure Scotland paperwork which
includes disclosures and PVG checks:

             Jennifer Hope, HR Manager

             Sarah Burgess, Glasgow Regional Manager (for Glasgow & East
              Dunbartonshire region)

             Jan Johnston, Regional Manager Argyll and Clyde (for Argyll and Clyde region)

The recruiting manager must:

             Check identity documents as listed below, and confirm this using the
              Confirmation of Identity Form.

             Check application form in line with guidance below for completeness and
              accuracy to minimise delay. Please also refer to ‘Guidance Notes for
              Application to Join Scheme'

             Send Confirmation of Identity Form to the counter signatory with the
              Disclosure Scotland application and Agreement to repay PVG Scheme
              membership cost.

             In order to satisfy CRBS that PVG applications, received from Alzheimer
              Scotland, are for those involved in regulated work, the recruiting manager is
              required to complete, and sign, the appropriate CRBS Checklist, and submit
              with every completed PVG application form. A job description should be

HR Manual: Protecting Vulnerable Groups Checks                                          Page 2 of 5
Owned by: HR Manager; Approved by: Policy Review Group; Review due 2013
                                                                           Alzheimer Scotland

              included with each checklist. This form will also be signed by a counter

      There are four relevant CRBS Checklists:
       (all are available at:

      If you are registered with Social Care and Social Work Improvement Scotland
      (previously known as Care Commission):

                   the first time your service submits a PVG application, for processing, the
                    Care Service Checklist A should be completed
                   for each subsequent PVG application, from your Service, Care Service
                    Checklist B should be used.

      If you are not registered with Social Care and Social Work Improvement

                   the first time your service submits a PVG application, for processing, the
                    Welfare Service Checklist A should be completed
                   for each subsequent application, from your Service, Welfare Service
                    Checklist B should be used.

      N.B. Please ensure that you complete the checklist appropriate for the role/service.

             Reply quickly to NO queries to avoid a second fee

             In services, file all Disclosure Scotland/PVG correspondence from counter
              signatories in personal file at the service office and record on Recruitment and
              Induction Checklist.

     Good Practice
     If you learn that an applicant, who has completed a PVG application that is being
     processed by a counter signatory, does not wish to take up this job offer please
     send an urgent email to the HRMailbox with the name of the applicant. We may be
     able to stop processing and save the £59 fee.

The counter signatory must:
         Check the paperwork and prepare accompanying documents for Central
            Registered Body in Scotland (CRBS) or Disclosure Scotland if applying

             Ensure incomplete forms are not sent to CRBS or Disclosure Scotland and
              resolve queries with managers to avoid payment of a second fee.

             Check the returned scheme PVG scheme record

HR Manual: Protecting Vulnerable Groups Checks                                           Page 3 of 5
Owned by: HR Manager; Approved by: Policy Review Group; Review due 2013
                                                                           Alzheimer Scotland

    Confirm a clear scheme record to the service in an email addressed to the recruiting
    manager and the administrator. The email contains the applicant’s name, certificate
    number and date of issue and that the certificate is clear. This email should be printed and
    placed on the relevant person’s personal file.

Where a scheme record is not clear, the recruiting manager and counter signatory will carry
out a risk assessment.
            All discussion about entries on the scheme record such as convictions, fines or
              police intelligence should be with relevant managers only.

             A decision on how to progress the job application is taken after considering the
              risks to our vulnerable service users, other staff and our reputation. The
              decision will be based on considerations such as whether or not the recruiting
              manager had prior awareness of the conviction/caution etc.; nature of the
              conviction and length of time elapsed since it was committed. The recruitment
              decision will ultimately remain that of the recruiting manager.

             Brief notes of the conversation, the date it took place and considerations leading
              to a decision will be sent by the counter signatory concerned to the recruiting
              manager making it clear if the decision is to condone or not and how we will be
              proceeding with the recruitment of that person. If the applicant is recruited this
              email will be included in their personnel file.

Requests for more PVG forms should be sent to
3     Forms of identity required

      Two forms of identity are required:

          1. Photo ID: passport, driving licence with photo or other photographic ID such as
             a staff card. If standard photo ID is not available, an original UK birth
             certificate or adoption certificate must be shown.

              Disclosure Scotland will also accept a recent passport sized photo signed and
              dated at the back by a responsible person. This photo must be accompanied by a
              letter signed by the same responsible person who has signed the photograph. For
              definition of responsible person see CRBS Disclosure Application Guidance
              Notes for Applicants (not yet included in PVG guidance notes). Paper clip this
              to the Disclosure application.

          2. Two different proofs of current address One should be within the last three
             months. Bank statements, bills etc should be less than 12 months old.

      If in doubt, check the Disclosure Scotland website or consult HR.

Good Practice
Most homes now have an electricity supplier number on their electricity bill which
provides a link to a unique address. This field (B35) is not yet mandatory but if an
electricity bill is offered as proof of address then record the number.

HR Manual: Protecting Vulnerable Groups Checks                                           Page 4 of 5
Owned by: HR Manager; Approved by: Policy Review Group; Review due 2013
                                                                          Alzheimer Scotland

4     Guidance for Completing the Application to Join the PVG

      Part A – we seek a Scheme Record
      Application relates to regulated work with Protected Adults
      Part B – must be completed by the applicant (please refer to Guidance Notes for
      completion of the Application to Join PVG Scheme Form ).
      Check that ALL Mandatory fields highlighted in yellow are completed.

      Here are some common follow up errors.

Section Action                              Notes
B2/3    Present surname and                 This needs to be the same one on their documents
        Check applicant name
B13     Mother’s maiden name                Mother’s maiden name needed for all applications
        Check if empty
B5      Known by different name          Needed if Mrs is ticked in B1 (may be the same as
        Check if empty                   current name)
B15     Gender                           Check male or female is indicated
B28/30 Driving Licence no                A UK driving licence usually starts with the 1st
        Check if two letters in the      letters of the surname, followed by numbers then
        middle of the numbers            more letter(s) and further numbers. More than one
                                         letter in the middle of the numbers indicates more
                                         than one fore name. Check they are in B3.
B40/45 Current home address              Check this is current address
B47 on Home address history              The date needs to be given for all addresses. The
         Check resident dates are        minimum required is the year they moved to each
         included.                       address. Ensure at least 5 years history is given, the
                                         most recent first.
         Volunteer Role ( on             More is needed than word volunteer to get a PVG
         Confirmation of identity        Check. Please specify their role i.e. driver, support
         form)                           worker, befriender etc
     Part C – The applicant once signs the form once on page 3 Declaration. (C1/2)

      Please leave the rest of the form blank for the counter signatory to complete.

Have you …..?
- Read the document ‘PVG information 1 February 2011
- Checked the application form for omissions/errors
- Checked that ID documents recorded on the Confirmation of Identity Form are also
detailed on the PVG Application to Join the PVG Scheme.
- Included the volunteer role on confirmation of identity form
- Included an agreement to repay PVG Scheme membership
- Sent all three documents to counter signatory for staff and applicants, two documents
for volunteers as their PVG Scheme membership is free.

      Reviewed March 2012

HR Manual: Protecting Vulnerable Groups Checks                                          Page 5 of 5
Owned by: HR Manager; Approved by: Policy Review Group; Review due 2013

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