Disclosure Scotland business continuity arrangement: FOI release

Information requested

Given the clear guidance from both the UK and Scottish Government , the fact that the majority of CSG’s are now working from home , therefore unable to sign forms ( including HR in the NHS) for PVG applications and currently the law does not require employers to insist upon PVG membership, can you confirm:
1. The current (23/03/2020) business continuity arrangement you have in place
2. Why you deem it necessary to prevent staff from accessing your control or ‘war room’
3. Why you still have a substantial number of employees located in close proximity within the building , in particular with reference of current ‘group’ restrictions
4. The indemnity both you as acting CEO and Disclosure Scotland has in place , should individuals contract COVID-19 traced back to the workplace.

Response

The answer to your questions are:
The current (23/03/2020) business continuity arrangement you have in place
On Monday 16 March Disclosure Scotland invoked Business Continuity (BC) to prevent any disruption
to our safeguarding services during coronavirus. At this time we maintained level 1 of our plan, which
had the following arrangements:
Level 1 - continue to do all types of Disclosure, but in this current crisis softprioritise PVG checks for those responding to Covid-19. Ends when the performance target for PVG does not meet the requirements of the national response.
In light of Government guidance, on 23 March the Interim Chief Executive sought agreement from Ministers to move to level 3 of our BC plan. This meant the following BC arrangements:
Level 3 - Stand up a priority only service for our PVG level applications. Applications to be provided by email template instead of paper forms posted. Basic and Standard and Enhanced level checks priority service, whereby only urgent applications to be submitted through our online channels. .
The PVG barring service will stand up an emergency service that notifies the employer that the individual is being considered for barring wherever that is so, allowing risky applicants to be immediately removed from potential deployment.

Why you deem it necessary to prevent staff from accessing your control or ‘war room’ As part of our emergency planning, an incident room was set up for the incident response team to manage our response to coronavirus.
The space used for this was the former Chief Executive’s Room which is not a public meeting room, however others could use it if it was not in use by the Chief Executive. Due to the nature of our required planning, this room was designated as the hub for the emergency response team, and was therefore
unavailable for any other purpose. All other meeting rooms were available for staff to use during this time. On 23 March 2020 the incident room was no longer used due to further social distancing guidance.  

Why you still have a substantial number of employees located in close proximity within the building, in particular with reference of current ‘group’ restrictions
In Disclosure Scotland we are providing a service essential to supporting the critical national infrastructure to combat COVID-19. As a result, we are permitted, as key workers critical to national government infrastructure, to come in to work should we not be able to work from home. There is an urgent need to get doctors, nurses and carers onto the front line but it is important, that even at a time like this, our vital safeguarding work continues.

There are a number of processing functions within Disclosure Scotland that cannot be performed remotely for security reasons.
On 23 March 2020, the Interim Chief Executive advised all staff not identified to be critical to delivering services, to vacate the building. From this date, mobile devices were successfully re-distributed to critical service delivery staff who could perform critical roles from home. We then identified and distributed mobile devices to additional staff to expand our virtual teams’ capability, and reduce the
number of staff required to work on-site.
In addition, those staff who identified as being at a higher risk, had childcare or caring requirements or expressed another reason as to why they could not attend the office were advised to leave the building and wait on further instruction to receive a device to allow them to work from home.
We have issued 234 devices since 23rd March to enable staff to work from home, allowing a 92% reduction in the amount of people needed in the office. Eight percent of our staff remain working in the office.

For those critical staff still in the office, Disclosure Scotland followed guidance issued by the Government on social distancing and provided email communications (Annex A) and numerous walk rounds by the Interim Chief Executive to reinforce the social distancing best practice.
on the 23 March 2020 further measures were put in place to protect critical staff in the office:
1. desk moves to ensure staff in the office are not working within two meters of one another;
2. redistributed laptops from senior managers to give critical operational staff with underlying conditions to enable home working;
3. all staff not critical to delivering the PVG services went home to limit numbers in the office; 
4. closed communal seating areas, such as the canteen, to avoid people congregating in violation of the rules; and
5. distributed devices to staff to stand up a remote processing service as far as feasible, to ensure as many staff as possible are not in the office.

The indemnity both you as acting CEO and Disclosure Scotland has in place, should individuals contract COVID-19 traced back to the workplace 

As part of the Scottish Government we are covered by the Crown and we do not have, nor are required to have, commercial insurance, this includes Employee and Public Liability.

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FOI-202000023008 Information released

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