Comment on Vulnerable Person’s Database from Scotland Director Matthew Rice

Scotland Director, Matthew Rice said:

“Police Scotland’s attempt to fix a problem has created another headache. Without informing or seeking people’s consent they have created a database of over 400,000 individuals that they have labelled as vulnerable, nearly 1 in 10 people. Once on there, there is no way of getting off. This is a sorry state of affairs.”

“There is no accusation of malice here, but you don’t need to be malicious to undermine people’s right to privacy. Police Scotland have gone about removing the autonomy and dignity of those on this database while trying to support them.”

“The Information Commissioner has notified them that the Vulnerable Persons Database is in breach of the Data Protection Act by not having any retention or deletion policy. But fixing that policy gap will not respond to the wider problem of people being unaware they are on this database in the first place.”

“If Police Scotland were serious about making this database fit for purpose, they would give people who find themselves on it the opportunity to request removal. To do that, they first need to notify the 400,000 plus people that they are on the Vulnerable Person’s Database and seek their consent for them to remain on it. There may be circumstances in which people should remain on this database, that genuinely meet the threshold of a vulnerable person, the police should make that assessment after receiving the replies.”

“But first, Police Scotland need to start communicating to those on the database. At this stage, this is the least they can do to begin to give back some of the agency they have taken from members of the public.”

Notes to Editors


The BBC exclusively revealed that 400,000 people had been placed on the Vulnerable Person’s Database.

The Information Commissioner said the database breached the Data Protection Act because it lacked an information removal policy.

Many people were not told that they had been put on the system.

The system involves collating disparate pieces of information about a particular vulnerable individual into a single file- allowing officers to build a narrative about that person.

At a supervisor’s discretion, the file can be shared with other government bodies – for example, health, social work or education – so that the person receives support.

There is no equivalent database in England and Wales.