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.

Improving uptake in this group is a key focus for Ministers and for the Scottish Vaccination & Immunisation Programme (SVIP). By improving vaccination in this group, staff are protected, onward transmission to colleagues and patients is reduced, all of which contributes to the resilience of Scotland’s health care services.

A range of steps are being taken this winter to encourage Health and Social Care staff to take up the offer of the flu vaccine. Public Health Scotland’s campaign “For some, flu hits harder” is being highly targeted at lower uptake groups including health and social care workers. Health Boards are running specific staff engagement sessions and actively promoting vaccination eligibility and information on how to receive the vaccine via staff intranet sites and social media channels. Boards are also championing vaccination uptake through senior leadership forums and staff briefings across the health care sector. Most Boards are also using dedicated flu champions to promote vaccination locally and case study videos, using health care workers, are in development, aimed at sharing their personal and/or professional experience on the importance of the flu vaccination programme. Digital prompts have been sent to health and social care workers via SMS and email to encourage them to book appointments, and most Health Boards plan to hold drop-in clinics for health and social care workers at convenient, flexible and easy to access locations. An expansion of peer-to-peer vaccination programmes is taking place across different health and social care sites within Health Boards.

Territorial Health Boards are responsible for assessing and planning for the workforce required to deliver their programme locally. Scotland’s winter vaccination programme for Covid-19 and flu is delivered as part of the Scottish Vaccination and Immunisation Programme (SVIP), which is a partnership between Scottish Government, Public Health Scotland and Health Boards. This supports appropriate workforce planning for operational delivery.

NHS National Services Scotland (NSS) Procurement is responsible for the management and logistics in relation to the Scotland’s vaccine stocks. COVID-19 and childhood flu LAIV vaccine supplies are procured on a 4 nations basis by UKHSA on our behalf, and adult flu vaccine supplies are procured on a Scotland-only basis by NSS. An SVIP Expert Advisory Group is convened, as necessary, to consider stock amounts required each year to meet need and uptake level.

There are sufficient vaccine supplies for the flu and COVID programme this winter and all supplies were made available prior to programme launch.

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.

The Scottish Government has no plans to consider making flu vaccination mandatory for any eligible groups, including public-facing NHS staff.

There is evidence that mandatory vaccination damages confidence in vaccination and provokes a negative reaction in those for whom it is mandated. During the COVID-19 pandemic, for example, the UK Government briefly made COVID-19 vaccination a mandatory condition of employment for frontline health and social care workers and staff in care homes, but quickly rescinded it due to significant opposition from the staff group. Although never mandated by Scottish Government, some private Scottish health and social care employers did require COVID-19 vaccination, and some health and social staff conflated their employers’ position, and that of the UK Government, with that of the Scottish Government. Some workers still have residual objections in regards to this, which impacts their views on workplace vaccination. Our policy is therefore to provide evidence-based, scientific rationale that encourages the workforce forward for vaccination on a voluntary basis.

Taking up the offer of the flu vaccine is the best way for people to protect themselves and those around them from getting ill; however it must be an individual's choice to get vaccinated. The Scottish Government ensures that accurate and trusted information is available to the public to help them to make an informed decision.

We continue to encourage all eligible individuals, including NHS staff, to take up the offer of the flu vaccine.

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.