Disclosure Scotland Protecting Vulnerable Groups (PVG) scheme processing times: FOI release

Information requested

I would like the following information for the period 1 April 2025 to 31 August 2025:

1. The average length of time taken to process new PVG scheme applications (for people applying to join the scheme for the first time).

2. The average length of time taken to process PVG scheme updates / existing member updates (for existing PVG members who are updating their scheme record or expanding it, as relevant).

3. If available, separate statistics showing:

• The number and proportion of applications processed within 7 working days, between 7-14 working days, between 14–28 working days, 29–60 working days, and over 60 working days (for both new applications and existing member updates).
• Any backlog or delay trends month-by-month over that period (April, May, June, July, August 2025) showing how the processing times have changed.

4. Any documentation or reports that discuss the impact of the legislative change on processing times, especially if they include target vs actual turnaround times for the above categories.

Response

You asked for the average time to process both types of PVG applications between 1 April and 31 August 2025. During this period, we experienced a significant short-term rise in application volumes. Since August, performance has improved overall and we have returned within our Service Level Agreement. As of last week, week commencing 29 September, 96.1% of PVG applications were completed within 14 days. This reflects the steady improvement in performance, with average processing times for PVG applications at 7.3 days in the reporting week.

1. The average length of time taken to process new PVG scheme applications (for people applying to join the scheme for the first time).

The average time taken to process a PVG join application for 1 April 2025 to 31 August 2025 was 18.03 days. As of last month (September), the average time taken to process a PVG Join application was 8.1 days.

2. The average length of time taken to process PVG scheme updates / existing member updates (for existing PVG members who are updating their scheme record or expanding it, as relevant).

The average time taken to process an Existing PVG application for 1 April 2025 to 31 August 2025 was 14.44 days.

As of last month (September), the average time taken to process an Existing PVG application application was 6.7 days.

3. If available, separate statistics showing:

• The number and proportion of applications processed within 7 working days, between 7-14 working days, between 14–28 working days, 29–60 working days, and over 60 working days (for both new applications and existing member updates).
• Any backlog or delay trends month-by-month over that period (April, May, June, July, August 2025) showing how the processing times have changed.

An exemption under Section 27(1) - Future publication applies to this information, as Disclosure Scotland intends to publish statistical data on our website within the next couple of weeks. This will detail statistical information from April to September 2025 and will include application volumes, processing times and the percentage of applications completed within Service Level Agreement. This will show trends on a month-to-month basis. Once this data is published, further application statistics will be published on an ongoing, monthly basis.

This exemption is subject to the ‘public interest test’. While it is recognised that there is a public interest in disclosing information as part of open, transparent and accountable government, we consider that there is a greater public interest in following our intended release schedule such that our statistical reports can be properly reviewed and checked for accuracy.

4. Any documentation or reports that discuss the impact of the legislative change on processing times, especially if they include target vs actual turnaround times for the above categories.

I have enclosed some of the information you requested. Exemptions under sections 25(1), 27(1), 30(b) (i) and 38(1)(b) apply to some of the information you’ve requested. I have provided our reasoning below.

Section 25(1) - Otherwise accessible

Some of the information you have requested is available from our website. Specifically, Disclosure Scotland Board Meeting minutes are periodically published. I have provided a link to such minutes in which the matters concerning processing delays are discussed: Disclosure+Scotland+Board+minutes+-+April+2025.pdf

Under section 25(1) of FOISA, we do not have to give you information which is already reasonably accessible to you. If, however, you do not have internet access to obtain this information from the website(s) listed, then please contact me again and I will send you a paper copy.

Section 27(1) - Future publication

Some of the information you have requested will be published on our website within the next 12 weeks. As above, Disclosure Scotland Board Meeting minutes are periodically published and can be found on our website at this link: Disclosure Scotland board meeting minutes - Disclosure Scotland

This exemption is subject to the ‘public interest test’. While it is recognised that there is a public interest in disclosing information as part of open, transparent and accountable government, we consider that there is a greater public interest in following our standard release schedule. By releasing documents within our schedule, we are afforded the time and space to properly consider information prior to release.

Section 30(b)(ii) - Free and frank exchange of views

This exemption applies to some of the information requested because disclosure would, or would be likely to, inhibit substantially the free and frank provision of advice for the purposes of deliberation. The exemption recognises the need for Ministers to have a private space within which to seek advice from officials prior to meetings. Disclosing the content of free and frank information will substantially inhibit such information in the future.

This exemption is subject to the public interest and prejudice test. Taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exemption. We have found that, on balance, the public interest lies in favour of upholding the exemptions. We recognise that there is a public interest in disclosing information as part of open, transparent and accountable government, and to inform public debate.

However, there is a greater public interest in allowing a private space within which officials can provide free and frank advice and views to Ministers. Disclosure of this type of information could lead to a reduction in the comprehensiveness and frankness of such advice and views in the future, which would not be in the public interest as it would substantially prejudice the ability of Ministers to engage with Scottish Government officials.

This exemption is subject to the ‘public interest test’. Therefore, taking account of all the circumstances of this case, it has considered if the public interest in disclosing the information outweighs the public interest in applying the exemption. It is concluded that, on balance, the public interest lies in favour of upholding the exemption. It is recognised that there is a public interest in disclosing information as part of open, transparent and accountable government, and to inform public debate. However, there is a greater public interest in allowing a private space within which officials can exchange views.

Exemptions under section 38(1)(b) – Personal Data

This exemption applies to some of the information requested because it is personal data of a third party, i.e. names and contact details, and disclosing it would contravene the data protection principles in Article 5(1) of the General Data Protection Regulation and in section 34(1) of the Data Protection Act 2018. This exemption is not subject to the ‘public interest test’, so we are not required to consider if the public interest in disclosing the information outweighs the public interest in applying the exemption.

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FOI 202500485201 - Information released - Enclosure

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