Disclosure (Scotland) Bill: partial BRIA

5. Scottish Firms Impact Test

Extensive engagement has taken place with a wide range of stakeholders. During this engagement a number of options for reform were presented and the impacts discussed. These were presented in the statutory consultation that ran for 12 weeks from 24 April 2018. Not only were the views on various options requested, there were also a number of questions specifically asking about the impact of the proposals on businesses and organisations.

As well as this engagement, the proposals and their impacts were discussed during several Stakeholder Advisory Board meetings. The Stakeholder Advisory Board consists of representatives across the various sectors using disclosures. The organisations and sectors represented are:

• General Teaching Council for Scotland
• Coalition of Care and Support Providers in Scotland (CCPS)
• General Pharmaceutics Council
• Scottish Ambulance Service
• NHS Lothian
• Community Pharmacy Scotland
• NHS Dumfries and Galloway
• Church of Scotland (Safeguarding Service)
• NHS Greater Glasgow and Clyde
• Scottish Social Services Council (SSSC)
• East Lothian Council
• General Dental Council
• Scottish Women’s Aid (as of October 2018)

Businesses were asked to consider a projection of the impact of changing fees to their organisation, current administrative costs for managing the current Scheme (staff numbers, admin costs, postage etc) and impacts of the move to a mandatory scheme on their organisations.

The main concerns were around:

• potential for a significant increase to annual costs due to existing membership renewals
• the administrative burden could deter people from volunteering, as could the threat of criminalising those who fail to join the scheme for roles which necessitate membership
• digital compatibility with any new system brought in
• how to ensure the regulated roles route to membership can be audited by both organisation and individual to ensure safeguarding.

The main benefits were perceived as:

• lower costs for new starts with no fee on updates;
• digital providing a quicker application process and having the potential to help with human resourcing administration monitor scheme membership;
• a mandatory scheme closing safeguarding gaps.

The Scottish Government has carefully considered the views expressed through the consultation and the Scottish Firms Impact Test in shaping the Bill’s provisions.