Disclosure (Scotland) Act 2020 - accredited body fees and discounting proposals: draft island communities impact assessment

4. Step Three - consultation

4.1 Who do you need to consult with?

Public consultation to be run March to May 2024.

Disclosure Scotland will also engage with voluntary sector organisations and specific public authorities operating in island areas and island only areas.

4.2 How will you carry out your consultation and in what timescales?

Formal consultation will take place over the standard 12 week period at least nine months before new fee regulations are expected to take effect. Disclosure Scotland will also engage directly with several relevant stakeholders, including those working in and with island communities.

4.3 What questions will you ask when considering how to address island realities?

The evidence available does not highlight a significant difference between island realities and the mainland in relation to fees for disclosure services. In the formal consultation, we invite further comment from our island stakeholders on any challenges specific to their communities.

4.4 What information has already been gathered through consultations and what concerns have been raised previously by island communities?

Disclosure Scotland asked some questions in relation to fees during the 2018 consultation on ‘Disclosure of criminal information and protecting vulnerable groups’. Responses were received from the following organisations operating in island communities:

• Crossroads (Harris) Care Attendant Scheme
• North Argyll Volunteer Car Scheme
• Shetland Canoe Club
• Cobhair Bharraigh
• Shetland Islands Council
• North Ayrshire Council
• Shetland Adult and Child Protection Committee
• Diocese of Argyll & the Isles - Catholic Church
• Argyll and Bute Council
• NHS Orkney
• NHS Western Isles
• Shetland Link Up

No financial issues unique to island communities were raised in relation to the charging of fees.

Shetland Link Up noted that in a small community it is harder to attract potential volunteers and if the fee waiver on PVG was removed, this would have a substantial negative impact on their services. This concern is present for many smaller third sector organisations.

4.5 Is your consultation robust and meaningful and sufficient to comply with the Section 7 duty?

Yes.