Scottish Disclosures

Policy Statement

Updated 5th August 2023


The Code of Practice (“the Code”) is published by Scottish Ministers under section 122 of Part V of The Police Act 1997 (“the 1997 Act”). The Code sets out obligations for registered bodies, countersignatories and other recipients of disclosure information issued under the 1997 Act and the Protection of Vulnerable Groups (Scotland) Act 2007 (“the 2007 Act”).

General Principles

We comply with the Code and the 1997 and 2007 Acts regarding the handling, holding, storage, destruction and retention of disclosure information provided by Disclosure Scotland. We comply with the Data Protection Act 2018 (“the 2018 Act”). We will provide a copy of this policy to anyone who requests to see it.


We will take reasonable steps to ensure that the third-party organisation/.individual on whose behalf we act and to whom we the pass the disclosure information also comply with the requirement of the Code of Practice regarding the use of disclosure information.


We recognise that, under section 1241 of the 1997 Act and sections 66 and 67 of the 2007 Act, it is a criminal offence to disclose disclosure information to any unauthorised person. Disclosure information is only shared with those authorised to see it in the course of their duties. We will pass disclosure information from our organisation to the third-party organisation/individual securely and ensure that the receiving party is able to store is securely.


We will not retain any paper or electronic image of the disclosure information once passed to the third-party organisation/individual. We will retain details about the third-party organisation whose applicants we obtained checks for and self-employed workers so that contact names can be supplied to Disclosure Scotland as part of their quality assurance process upon request.


We will ensure that disclosure information is destroyed in a secure manner i.e. by shredding, pulping or burning. We will ensure that disclosure information which is awaiting destruction will not be kept in any insecure location

Acting as Umbrella Body

Before acting as an Umbrella Body (a body which countersigns applications for Standard or Enhanced Disclosures or makes declarations in relation to PVG disclosure requests on behalf of other organisations) we will take the following steps. We will ensure that the organisation on whose behalf we are acting complies with the Code and the 1997 and 2007 Acts. We will take all reasonable steps to satisfy ourselves that they will handle, use, store, retain and dispose of disclosure information in full accordance with this policy. We will also ensure that any body or individual for whom applications or requests are countersigned, has such a written policy. If necessary, we will provide a model policy for that body or individual to use or adapt for this purpose.