FOI release: Guidance on due diligence: human rights

Published: 18 August 2022
Freedom of information class: How we deliver functions and services

Information request under the Freedom of Information (Scotland) Act 2002 (FOISA)

FOI reference: CW-2022-286
Date received: 27 July 2022
Date responded: 18 August 2022

Information requested

  1. You asked for a list of human rights due diligence checks your organisation has conducted since the publication of the Scottish Government document, Guidance on due diligence: human rights, detailing in each case whether or not you proceeded with an investment relationship or business agreement following the undertaking of these checks.
  2. any instances of non-compliance with the guidance that have been reported. If unable to provide such a list, please confirm for me whether your organisation was previously aware of or has ever given consideration to this guidance, including whether you are aware of having been notified of it by a representative of the Scottish Government or other public body.
  3. also how many investment relationships or agreements your organisation has engaged in since June 2018.


  1. While our aim is to provide information whenever possible, in this instance the Registers of Scotland does not have the information you have requested. This is because RoS does not undertake any of these activities.
  2. There have been no instances of non-compliance. RoS is aware of this guidance. RoS was notified through the procurement weekly updates which come from the Scottish Government Procurement Capability Team.
  3. There have been no investment relationships by RoS since June 2018. There have also been no Major Investment Projects as defined in the SPFM.
  4. In collaboration with Ordnance Survey GB, Registers of Scotland operates the Geovation Scotland Accelerator Programme. This is a third-party agreement to which RoS provides support and grants to early stage start-ups over a 12 month period. As the start-ups are at a very early stage during this programme they are given support for developing processes such as due diligence.

    To qualify to be considered for a place on the Geovation programme, the company must be registered in the UK (and have a head office/registered address). In addition, all our companies are subject to BPSS security/background checks upon acceptance to the programme, carried out by the RoS HR department. These checks cover the following;

    1. Electronic verification of identity, including name, any aliases, address and linked accounts.
    2. Basic DBS to screen for any unspent convictions.
    3. Right to Work check, covering nationality, immigration status and the right to carry out the required work.
    4. Employment history check, covering a minimum of the preceding 3 years.
    5. Scrutiny of any periods of 6 months or longer spent abroad in the preceding 3 years, in accordance with the Immigration, Asylum and Nationality Act 2006.

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