Disclosure (Scotland) Act 2020 - accredited body fees and discounting proposals: partial equality impact assessment

2. Screening

2.1 Policy Aim

Disclosure Scotland charges fees for some of its functions, including disclosure certificates. There is also a longstanding fee waiver in relation to PVG disclosures for qualifying voluntary organisations. The current fees were set in 2011: basic, standard and enhanced were set at £25, PVG Scheme at £59 for a full scheme record and £18 for a short scheme record.

2011 to present is the longest period disclosure fees in Scotland have remained frozen.

The primary objective of setting fees is to bring Disclosure Scotland back to a cost-neutral position, as required by the Scottish Public Finance Manual by changing statutory fees. Charging for services helps to avoid unnecessary public expenditure and eliminate hidden subsidies.

This consultation supports the development of policy proposals which could provide more targeted support to certain groups of customers who may be less able to pay the full fee as we move towards a cost recovery position.

The Scottish Government is acutely aware that any change in charging of fees will most significantly affect people already at or at risk of inequality of outcome through socio-economic disadvantage.

The policy options contribute to the following National Outcomes:

• Children and Young People: We grow up loved, safe and respected so that they realise their full potential.
• Communities: We live in communities that are inclusive, empowered, resilient and safe.
• Poverty: We tackle poverty by sharing opportunities, wealth and power more equally.

2.2 Who will it affect?

The policy propsals included in the consultation primarily effect PVG scheme members. These are people doing regulated roles with children or protected adults. There are estimated to be around 800,000 active scheme members in Scotland. The new policies in relation to discounting for people in receipt of certain benefits and care experienced young people are currently estimated to impact at most 150,000 scheme members.

The revised policy in relation to volunteers in Qualifying Voluntary Organisations (QVOs) would effect any existing volunteers and those newly looking to volunteer in regulated roles. The eligibility for volunteering with QVOs includes roles ranging from providing entertainment to children in hospital to volunteer sports coaches. Around 19% of PVG scheme members join through QVOs, however, some are also in or move into paid employment.

2.3 What might prevent the desired outcomes being achieved?

There are significant budgetary pressures across the public sector, Disclosure Scotland’s position is no different. Having absorbed inflationary costs for a number of years, we do not come in at a cost recovery position, requiring significant additional funding from the Scottish Government Budget. Best practice is to charge fees for government services at cost recovery.

Any path to cost recovery would require increasing fees. For many customers, this is not welcome but would nonetheless remain affordable. However for many people on no or low income, facing additional barriers to entry to work such as an increased fee, would prevent them from applying for and taking on work in areas where we often see significant pressures, including social care and child care roles.