Disclosure (Scotland) Bill: data protection impact assessment

Data protection impact assessment (DPIA) for the Disclosure (Scotland) Bill explores how the bill impacts on personal data and privacy.

4. Stakeholder analysis and consultation

4.1 List all the groups involved in the project, and state their interest.



Police Scotland

Police Scotland will have to notify Disclosure Scotland and the applicant of proposed ‘relevant police information’, and offer the applicant the opportunity to provide representations as to why ‘relevant police information’ should not be disclosed. Individuals and Disclosure Scotland will have to be notified of the outcome.

Local Authorities

Local authorities will have strengthened referral powers to refer individuals to Disclosure Scotland. Local authorities may be contacted by the independent reviewer to provide additional information during review process.

Accredited bodies

Accredited bodies are formally accredited and their processing and storage of personal data regulated.

PVG Review Consultation respondents

Use the disclosure regime as individuals or organisations, must be kept informed of any changes in legislation/ processes which may affect them.

Scottish Courts and Tribunal Service

Court referrals under section 7 of the PVG Act will end.

May be contacted by the independent reviewer to provide additional information during review process.

4.2 Method used to consult with these groups when making the DPIA.

Following extensive pre-consultation engagement between January and August 2017 with over 300 individuals and organisations, and an online survey generating over 800 responses, Disclosure Scotland published a consultation paper the ‘Protection of Vulnerable Groups and the Disclosure of Criminal Information’. The public consultation ran from 25 April 2018 until 18 July 2018 and received over 350 responses from a range of stakeholders with varying backgrounds including judicial bodies, the legal sector, local government, voluntary organisations, the health sector and individual scheme members. The consultation paper included a specific question on impacts to individuals’ privacy by the options set out in the consultation.

Disclosure Scotland has an existing Stakeholder Advisory Board, which includes representation from local authorities, health boards, care sector, regulatory bodies and victims groups, that provides advice and guidance on changes in operation.

Disclosure Scotland’s User Research team have been conducting face to face interviews and user testing with individuals and organisations throughout the UK. This research has included testing the privacy statement and capturing user needs around privacy and data protection such as simplifying the privacy statement and ensuring it is in plain English.

Regular meetings have been held with major data providers (Home Office, Police Scotland, PSNI) and critical stakeholders such as ITECS who can support the delivery of the security processes required to implement the new systems. Regular meetings are also held with Disclosure Scotland’s independent security assessor.

4.3 Method used to communicate the outcomes of the DPIA.

The DPIA will be published on gov.scot. Disclosure Scotland will also provide an update via a quarterly e-bulletin, which is issued to over 15,000 countersignatories.

The Disclosure Scotland Bill Team will continue to engage with relevant advocacy and representative groups for input on developing proposals and guidance materials.


Email: DSPolicyTeam@disclosurescotland.gov.scot

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