Any hospitality business planning to hire a professional Santa or elves to interact with customers over the festive season should be sure to check their credentials under Disclosure Scotland’s Protecting Vulnerable Groups (PVG) scheme.
Disclosure Scotland is an executive agency of the Scottish Government created to help organisations make ‘safer decisions’ when they are recruiting people.
The Disclosure (Scotland) Act 2020 made the PVG scheme a legal requirement in Scotland, from 1 April 2025, for all individuals carrying out a ‘regulated role’ with children or protected adults, whether paid or voluntary.
Disclosure Scotland has this week reminded businesses, organisations and any ‘seasonal entertainers’ they might hire to confirm their PVG Scheme status ahead of the festive season – and offered the following Q&A by way of explanation.
Q: What characters need to be part of the PVG scheme?
Whether the character you play is considered to be a regulated role or not depends on the specific activities involved they are expected to do as part of their festive role.
If you’re unsure, use our free online checker tool and supporting guidance to help determine whether a role requires PVG scheme membership.
Q: Why do I need to be part of the PVG scheme?
Roles such as professional Santas, elves or volunteers who expect to carry out an activity as part of a wider role, require PVG scheme membership. This is because they are directly providing a cultural, leisure or recreational activity aimed at children.
Q: I’m a self-employed seasonal entertainer, playing Santa as a festive event, do I need to be part of the PVG scheme?
Yes. Self-employed professional characters and children’s party entertainers who are working in a regulated role with children under 18 must join the PVG scheme for children. Applications for PVG scheme membership can be made online through Disclosure Scotland.
Q: What if characters and entertainers are only responsible for managing queues and taking tickets, like professional elves or helpers?
No. This kind of role is not likely to require PVG scheme membership as they are carrying out a supporting role, and are not directly providing the service.
This role would require PVG scheme membership if, for example, the elves had additional duties, such as direct participation in the actual delivery of the seasonal activity, that meant they were directly involved in the delivery of the cultural, leisure or recreational activity that would mean that PVG scheme membership is required.
