Legal requirements for professional Santas and seasonal entertainers: Common questions answered

In this article, we aim to answer commonly asked questions and queries.

Disclosure Scotland is reminding organisations and seasonal entertainers to check their Protecting Vulnerable Groups (PVG) scheme requirement, ahead of the festive season.  

It is a legal requirement in Scotland for anyone carrying out a regulated role with children or protected adults, whether paid or voluntary, to hold PVG scheme membership. 

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 at 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. 

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