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The Scottish Government has not undertaken a risk assessment or evaluation of the liabilities of pharmacist independent prescribers who do not have read/write access to patient records. However, other organisations make clear the clinical and professional expectations required to support all prescribers, including pharmacist independent prescribers, to work safely and effectively.

All qualified pharmacist independent prescribers must adhere to robust policies, competency frameworks and requirements, as set out by Health Boards, the General Pharmaceutical Council (GPhC), the pharmacy regulator, and the Royal Pharmaceutical Society (RPS), the professional leadership body. For every prescribing consultation, pharmacist independent prescribers must use their professional judgement and take into account the person’s best interests to decide whether they have the information they need to prescribe safely.

Disclosure Scotland’s fees are set by secondary legislation and do not provide for offering an expedited service at additional cost. This ensures that all customers receive the same level of service.

Disclosure Scotland’s Service Level Agreement (SLA) is to process 90% of applications within 14 days. For week commencing 6 October, the average processing time for all applications was 7.4 days with 97.46% of applications completed within 14 days.

Disclosure Scotland has historically exceeded its SLA of 90% of applications processed within 14 days. In 2023-2024, 95.3% of applications were completed within 14 days and in 2024-2025, 97.7% within 14 days.

A paid expedited service would not improve response times where applications are delayed due to further information being required from third parties.

I have asked Gerard Hart, Chief Executive of Disclosure Scotland to respond. His response is as follows:

Disclosure Scotland is currently performing back within its service level agreement to process 90% of applications within 14 days.

Improvements have been made to the employer dashboard so that accredited bodies can check the processing status of an application without the need to contact Disclosure Scotland directly.

Disclosure Scotland regularly engages with customers to support them in understanding their rights and responsibilities in relation to disclosure and the Protecting Vulnerable Groups (PVG) scheme. To stay up to date on changes at Disclosure Scotland, we encourage customers to sign up to our quarterly newsletter or read it on our website. We also provide workshops to assist organisations in understanding regulated roles, their duty to refer and the practical and legal processes involved in countersigning disclosure applications. Our dedicated Customer Engagement team is also available to provide one to one advice and support to organisations who need it.

In response to user feedback, Disclosure Scotland has improved its regulated roles guidance and developed specific guidance for parent-run groups, sports organisations and health services.

Volunteer Scotland Disclosure Services (VSDS) are funded by the Scottish Government to help voluntary sector organisations process applications and provide advice, guidance and training.

The Scottish Government will set out its approach to winter preparedness for 2025/26 in due course. This will include the publication of the planning document National Planning Priorities and Principles for Surge and Winter Preparedness in Health and Social Care.

Employees already in regulated roles on 1 April 2025 and whose employer had received a Protecting Vulnerable Groups (PVG) scheme record did not need to obtain a new Level 2 with PVG disclosure. Only people who were in regulated roles whose employer had never registered their interest in the PVG scheme member or who were taking up a regulated role with a new employer needed to apply.

In recognition of the need for organisations to adapt to the new legislation and allow those in roles that were not eligible for PVG scheme membership prior to 1 April to join the Scheme, Disclosure Scotland provided a “grace period” of three months from 1 April for applications to be submitted before offence provisions came into force.

To manage volumes, Disclosure Scotland worked with organisations to encourage them to get those people who were eligible to join prior to April 2025 into the scheme before it became mandatory. Organisations were encouraged to contact Disclosure Scotland to discuss regulated roles and provide anticipated volumes that would be received between 1 April and 30 June 2025. While Disclosure Scotland had no power to compel organisations to do so at that time due to the non-mandatory nature of the scheme, many stakeholders did work with Disclosure Scotland to ensure those already eligible were in the scheme before 1 April and project their applicant volumes for the grace period.

I have asked Gerard Hart, Chief Executive of Disclosure Scotland to respond. His response is as follows:

There has never been a provision in law for supervised working while organisations were waiting to obtain a Protecting Vulnerable Groups (PVG) scheme record. Until 1 April 2025, the PVG scheme was not a legal requirement therefore organisations could choose to have people in regulated work without seeing PVG scheme membership.

In forecasting volumes resultant from the legal requirement to be in the PVG scheme if carrying out a regulated role, Disclosure Scotland expected 50,000 additional applications against normal levels and diverted 10 full-time equivalent staff from other areas of the business to help manage delivering disclosure processing and support services. Planning included that, from 1 April onwards, application volumes and resources were monitored daily through checkpoint meetings to enable timely decision-making.

Within normal resource, Disclosure Scotland has historically exceeded its Service Level Agreement (SLA) of 90% of applications processed within 14 days. In 2023-24, 95.3% of applications were completed within 14 days and in 2024-25, 97.7% within 14 days.

Disclosure Scotland is currently performing within its SLA to process 90% of applications within 14 days.

Between winter 2023-24 and winter 2024-25 uptake across all adult groups for both flu and COVID-19 decreased, with flu uptake dropping back in line with pre-pandemic levels.

Each year, the Scottish Vaccination and Immunisation Programme (SVIP) reviews the performance of the previous winter programme to improve delivery and implement new initiatives with the aim of improving uptake. In addition, SVIP holds regular winter task and finish groups throughout the winter programme, led by PHS and attended by immunisation teams from the 14 territorial Health Boards, as well as the national Boards and Scottish Government policy teams. This helps the programme to respond in real time to any unexpected drops in uptake, including sharing best practice.

There are a wide range of steps being taken to encourage uptake through how people are invited for vaccination. People eligible due to age and/or health condition will receive a direct communication by letter, email or text with details about their appointment or information on how to book one. In winter 2023-24, all those with a digital preference who self-booked via the online booking portal or national vaccination helpline received a digital reminder 24 to 48 hours before their appointment. This winter, we have expanded those reminders to 100% of those with a booking who have a digital preference, which now includes all those who have been automatically scheduled by the national programme. For those who are sent an appointment via SMS or email, a new process launched in spring 2025, whereby if an email address is undeliverable, or the mobile number is no longer in use, a letter is sent to inform the individual and encourage them to log in or ring the helpline to update their details and book an appointment.

Public Health Scotland (PHS) has developed a new communications campaign (For some, flu hits harder) focused on raising awareness and encouraging uptake of the flu vaccine. Communications and marketing activity is running nationally across radio, social media, out of home, paid display and pay per click advertising from 15 September to 7 December. This activity is highly targeted at lower uptake groups including those aged 18-64 years of age with an eligible health condition, pregnant women and health and social care workers, as well as in areas with lower SIMD and with ethnic minority communities.

New resources including posters and social media toolkits have been shared with over 1,300 key stakeholders. The social media toolkit includes resources for both the flu and COVID-19 vaccines and includes a range of videos, statics, case studies, website, newsletter and intranet copy.

Updated information is available on NHS Inform and significant activity is being undertaken by PHS to reach particular people. PHS currently share health information resources such as leaflets, posters and social media toolkits with a wide range of partners who represent Scotland’s diverse population. As standard, core resources are produced in five primary languages (English, Arabic, Chinese Traditional (Cantonese), Chinese Simplified (Mandarin) and Polish) and four other formats: Audio, British Sign Language, Easy Read and Large Print, with additional formats and languages available on request.

PHS have also been working closely with a range of third sector partners to help design and disseminate programme materials for particular stakeholder groups. This includes members of the Alliance, the British Islamic Medical Association, Age Scotland and Asthma and Lung UK.

Scotland’s spring and winter vaccination programmes for flu and COVID-19 are implemented as part of the Scottish Vaccination and Immunisation Programme (SVIP) - a collaborative effort involving the Scottish Government, Public Health Scotland, and Health Boards.

In recognition of Scotland’s changing demographics and the ageing population, territorial Health Boards assess and plan their workforce needs to effectively implement their respective programs each season.

For each programme, SVIP conducts precise assessments of the eligible population - based on criteria established by the Joint Committee on Vaccination and Immunisation - recognising that these numbers may vary annually, and planning is accordingly adjusted to ensure effective implementation.

The Joint Committee on Vaccination and Immunisation (JCVI), in its minutes of 10 October 2023, advised that the adult flu programme should run from the beginning of October to the end of November, with Health Boards able to apply flexibility as appropriate.

The Scottish Vaccination and Immunisation Programme (SVIP) has been operationalising this advice since winter 2023-24. For each immunisation programme, SVIP looks at the precise numbers of those eligible, as the denominator fluctuates each year, and planning is undertaken to operationalise accordingly.

Planning for winter 2026/27 will commence in spring 2026 and we will align programme dates with the JCVI advice as normal.