Safer online learning environments: Busting the myth that PVG applications are "just for face-to-face roles"
As part of International Safeguarding Children Week 2026, today's theme focuses on safer online learning environments.
Today is an opportunity to challenge a dangerous misconception: that Protecting Vulnerable Groups (PVG) applications only apply when adults are physically in the same room as children.
They don't. And getting this wrong isn't just an oversight, it's a criminal offence.
The myth: "I only work online, so PVG doesn't apply to me"
In Scotland, online tutoring, virtual mentoring and remote supervision of children have become increasingly common, whether through dedicated e-learning platforms, video-call tuition, or online youth and mentoring schemes. With that, growth has come a persistent myth: that because there's a screen between the adult and the child, online tutoring isn't a regulated role.
This simply isn't true. If your role involves teaching, instructing, mentoring, supervising or caring for children, it is a regulated role under the PVG scheme.
The reality: online-only roles can be a regulated role
Disclosure Scotland is clear that the nature of the activity determines whether a role is regulated. A volunteer delivering one-to-one online tutoring to children, a mentor running video sessions with young people, or a coordinator supervising children through a digital learning platform may all be undertaking regulated work in exactly the same way as someone doing this face-to-face.
This matters because:
It is a criminal offence to work or volunteer in a regulated role, such as tutoring children, without holding a valid PVG scheme membership for the vulnerable group concerned. There is no exemption for online-only contact.
Organisations have the same legal duty to ensure the right checks are in place for online roles as they do for in-person ones.
Safer online learning environments depend on the same safeguarding infrastructure as physical ones. A safe digital space for children isn't just about the right platform settings or moderation tools, it's about ensuring that every adult with regulated access to children, however that access happens, has been properly vetted.
International Safeguarding Children Week exists to sharpen awareness of the everyday decisions that keep children safe, and today's theme reminds us that "online" doesn't mean "lower risk" or "out of scope." If anything, the growth of online learning and mentoring means more adults than ever may unknowingly be carrying out a regulated role without realising their legal obligations.
What you should do now
If you work or volunteer in a role involving teaching, mentoring or supervising children online, even occasionally, don't assume the rules don't apply to you. Check your position now, rather than risk prosecution later.