Scottish Parent Teacher Council

Letter to the Minister

SPTC are part of a voluntary sector coalition formed in response to the vetting (disclosure) proposals. Read the coalition's letter to Adam Ingram, Minister for Children and Early Years.

7 March 2008 Adam Ingram MSP
Minister for Children & Early Years
Victoria Quay
Edinburgh
EH6 6QQ

Dear Mr Ingram

Protection of Vulnerable Groups (Scotland) Act 2007 Consultation

I am writing to you on behalf of a voluntary sector coalition formed in response to the Consultation on Protection of Vulnerable Groups (Scotland) Act 2007.

At the outset, I would like to make clear that the voluntary sector welcomes some of the new Act, seeing it as potentially offering a huge improvement on the current regime. Proposals under the new scheme for the ‘constant updating’ of disclosure checks and the option of subsequent nominal checks will lead to improvements in the disclosure process and hopefully will reduce the need for multiple checks within the sector. In addition we see the retaining of free volunteer checks under the new system as a positive step.

The sector has been an active participant in Governments efforts around the Protection of Vulnerable Groups Act. For example, many voluntary organisations have submitted responses and attended information events during the consultation process and the sector has taken part in regular implementation meetings organised by the Government, which have been helpful. However, we must point out that many small community and voluntary sector organisations with limited capacity have not been able to take part in the consultation events, many of these organisations work with vulnerable adults and children.

The sector still has a significant number of concerns relating to implementation of these policy proposals that must be publicly addressed in order for it to be adequately implemented.

In the short to medium term, the proposals would incur a very large increase in costs for the voluntary sector, with the potential to cause greater harm to the vulnerable groups that this consultation sets out to protect. During the implementation of PoCSA the phasing in period as well as training and support were underestimated and we seek to work with you to ensure that this situation is not repeated.

For the legislation to work in practice, Parliament and the Scottish Government must ensure that the voluntary sector is fully engaged with the parliamentary process and through the transitional stage, ensuring the short term costs of the scheme are manageable and that long term costs are reduced. Government is aware of the pressures on the sector and we welcome your commitment to work in partnership to address these.

Our concerns centre on:

Significant start-up costs of the scheme to the voluntary sector
An adequate phasing in period for retrospection
The provision of on-going training, support & guidance for the voluntary sector on the new scheme
Easy and accessible guidance well in advance of the Act coming into force
A cap on disclosure costs under the new system for paid staff
A system proportional to voluntary organisation capacity
Supporting and encouraging volunteering
Consistency in the handling of sensitive information
Proper monitoring and evaluation of the protection system
Some of the definitions used and redefining them

The coalition includes some of the most experienced organisations working with children and vulnerable adults in Scotland, ranging from national membership organisations to local community organisations working at the frontline, protecting vulnerable groups. The organisations involved are committed to supporting the evolution of the best possible protection arrangements and I would be delighted if you would be willing to meet with representatives of the coalition, outside of the formal parliamentary process, to discuss our concerns and mutual interests. We will of course also be submitting evidence as the proposals make their way through the parliamentary process.

I hope you will appreciate the very real concerns of the voluntary sector around the implementation of the vetting and barring scheme. The coalition is keen to work in partnership with you and asks for your help in rectifying these concerns. We believe that by working together we can make sure this legislation delivers the best possible protection for vulnerable groups in Scotland.

Yours sincerely,

Lucy McTernan
Director of Corporate Affairs
SCVO (Scottish Council for Voluntary Organisations)

Current coalition signatories include:

Clubs for Young People (CYP) Scotland
Shetland Council for Social Service
WRVS
Scottish Society for Autism
Black & Minority Ethnic Infrastructure in Scotland
NSF (Scotland)
Community Care Providers Scotland
Fife Gingerbread
Volunteer Centre Edinburgh
Volunteer Centre East Ayrshire
Volunteer Centre Midlothian
Scottish Women’s Aid
Scottish Pre-School Play Association
Glasgow Council for Voluntary Sector
Council for Voluntary Sector Fife
Stepping Stones for Families
CrossReach
Scottish Council of Jewish Communities
Youthlink
Fairbridge Scotland
Scottish Independent Advocacy Alliance
Inclusion Scotland
The National Deaf Children’s Society
Lead Scotland
ENABLE Scotland
Voluntary Arts Scotland
Scottish Disability Equality Forum
Sense Scotland
The Richmond Fellowship
Scottish Parent Teacher Council

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