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Agenda Document Pack - Audit and Scrutiny Panel - 14/05/2026

North Lanarkshire Council · 14 May 2026
Back to Audit and Scrutiny Panel — 14 May 2026 and its agenda

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5 May 2026 
Members of the 
Audit and Scrutiny Panel
Chief Executive’s Office
Rachel Blair
Chief Officer (Legal, Democratic and Strategy)
Civic Centre, Windmillhill Street,
Motherwell ML1 1AB
www.northlanarkshire.gov.uk 
Notice is given that a Meeting of the Audit and Scrutiny Panel is to be held in the Council
Chamber, Civic Centre, Windmillhill Street, Motherwell, ML1 1AB on Thursday, 14 May 2026
at 14:00 PM which you are requested to attend. 
The agenda of business is attached. 
Rachel Blair
Chief Officer (Legal, Democratic and Strategy) 
Members : 
Clerk Name: Karen Swan
Clerk Telephone: 07919 730272
Clerk Email: committee@northlan.gov.uk 
S Watson, P Kelly, C Costello, M Hughes, J Hume, D Johnston, J Leckie, A McCrory, M
McCulloch, J McLaren, G Robinson.  
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Agenda 
1 Declarations of Interest In Terms of the Ethical
Standards In Public Life Etc. (Scotland) Act 2000 
2 Housing Performance Update
Submit report by the Chief Officer (Housing and
Communities) providing information to the Audit and
Scrutiny Panel in relation to the non-reporting of ‘the
percentage (%) of reactive repairs appointments kept’. 
5 - 10  
Scrutiny Related Items 
3 Quarterly Performance Assurance
Submit report by the Chief Officer (Legal, Democratic
and Strategy) bringing together a summary of the
council’s performance reports in one composite
assurance overview to support the Audit and
Scrutiny Panel in maintaining strategic oversight and
awareness of the Council’s performance reporting
arrangements in line with the Panel’s remit to provide
“independent review of the council’s governance, risk
management, performance, and control frameworks”. 
11 - 38  
Audit Related Items 
4 Audit and Risk Related Items - Action Log
Submit report by the Chief Officer (Audit and Risk)
tracking implementation of outstanding requests and
recommendations made by the Panel in respect of
audit and risk-related items. 
39 - 46 
5 Internal Audit Progress Report
Submit report to the Chief Officer (Audit and
Risk) providing an overview of Internal Audit activity
and audit reports issued since the last update to the
Panel in March 2026. 
47 - 90 
6 Internal Audit Follow-up of Implementation of Audit
Recommendations
Submit report by the Chief Officer (Audit and Risk)
providing an update on the progress made in the
implementation of Internal and External Audit
recommendations. 
91 - 110 
7 Internal Audit Charter
Submit report by the Chief Officer (Audit and
Risk) seeking approval for the Internal Audit Charter. 
111 - 132
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8  Internal Audit Strategy
Submit report by the Chief Officer (Audit and
Risk) seeking endorsement of the attached Internal
Audit Strategy for 2026-27 to 2028-29. 
133 - 146 
9 Internal Audit Plan 2026-27
Submit report by the Chief Officer (Audit and Risk)
presenting the proposed Internal Audit Plan 2026-27. 
147 - 154 
10  Risk Management Update
Submit report by the Chief Officer (Audit and
Risk) seeking to support the Audit and Scrutiny Panel
in the discharge of the aspect of its remit of monitoring
the effective development and operation of
risk management in the Council. 
155 - 164 
11  Risk Management Strategy
Submit report by the Chief Officer (Audit and
Risk) presenting the revised Risk Management
Strategy to the Panel for noting. 
165 - 210 
12  Corporate Fraud Policy
Submit report by the Chief Officer (Audit and Risk)
detailing the Council’s approach to the prevention,
detection and investigation of fraud across all Council
service areas. 
211 - 230 
13  National Fraud Initiative - Update
Submit report by the Chief Officer (Audit and Risk)
informing of the progress made in response to the
National Fraud Initiative data matching exercise. 
231 - 238 
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North Lanarkshire Council
Report
Audit & Scrutiny Panel 
Does this report require to be approved? ☐ Yes   ☒ No
Ref     SL/KMcG Date 14/05/26 
Housing Performance Update 
From  Stephen Llewellyn, Chief Officer (Housing & Communities)  
E-mail LlewellynS@northlan.gov.uk 
1. Background 
1.1 Panel Members will recall the ‘quarterly performance assurance review’ report
presented to the Audit and Scrutiny Panel on 13/11/25, which set out the outcomes of
the assurance review of reports submitted to Council Committees during cycle 3 of
2025. 
Executive Summary 
This report provides information to the Audit and Scrutiny Panel in relation to the non-
reporting of ‘the percentage (%) of reactive repairs appointments kept’, within the council’s
quarterly performance assurance review report. The report informs the panel of the
reasons why the housing service are currently unable to report on this indicator, and
outlines the actions being taken to address this issue to enable reporting on the indicator
in the future. The report also provides supplementary information on alternative
performance indicators which give assurance on the repairs service being provided to
tenants. 
Recommendations 
It is recommended that the Audit and Scrutiny Panel 
(1) Note the reasons why performance information on ‘the percentage (%) of reactive
repairs appointments kept’ is currently unavailable and the actions underway to ensure
that reporting on this indicator can be provided in future performance reports  
(2) Note the alternative key performance measures currently being reported, which
provide assurance on repairs service provision for our tenants. 
The Plan for North Lanarkshire
Priority  Improve economic opportunities and outcomes
Ambition statement (1) Ensure a housing mix that supports social inclusion and
economic growth
Programme of Work Statutory / corporate / service requirement
Item 2
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1.2 The composite report presented included performance information in relation to all
services of the council, including the housing service, who have 22 indicators in the
Strategic Performance Framework, covering all aspects of the council’s social
landlord role. 
1.3 The report presented on 13th November 2025 identified 5 red indicators within the
housing report, however the narrative commentary under the section ‘Areas of
Performance requiring improvement’ only provided information on 2 of these
indicators 
1.4 A further report presented to the Audit and Scrutiny Panel on 26/2/26 explained the
reason for the discrepancy between the number of red indicators highlighted and the
associated narrative, along with up to date commentary for the remaining 3 indicators. 
1.5 Within the performance reports presented, it was highlighted that the housing service
are unable to report on the ‘Housing Repairs - % of reactive repairs appointments kept’
indicator, as we do not currently have the facility to report this. 
1.6 At the meeting on 26/2/26 members of the Audit and Scrutiny Panel asked that:
“A report in relation to the non-reporting of reactive repairs appointments be
submitted to the next meeting of the panel”
1.7 In response to this request the panel were advised that a report would be submitted
to the May 2026 meeting of the Audit and Scrutiny Panel to provide a detailed
response, in line with the established approach for enquiries arising from the panel. 
2. Report 
2.1 This report provides an explanation for the non reporting of the ‘Housing Repairs - %
of reactive repairs appointments kept’ indicator. 
2.2 The ‘Housing Repairs - % of reactive repairs appointments kept’ indicator is not a
Statutory Indicator and has been agreed as an internal KPI only. 
2.3 Currently, performance information on reactive repairs appointments made and kept is
generated from 3 separate IT systems that collectively support the end to end process.
These include the Dynamic Field Services system, which is a new system that was
introduced for the purpose of scheduling and reporting on repairs appointments; the
council’s current Housing Services Management System (HSMS) which all repairs
requests from tenants are issued and closed through; and the contractors (MEARS)
Repairs Management system (MCM), which they use to manage repairs operations
and report on the status and completion of all jobs for the council.   
2.4 Each of the 3 systems used in the repairs management process have separate
purposes and capture different elements of the repairs completion process, and at
present these systems do not interface in a way that allows a consistent and reliable
replication or reconciliation of appointment data across all stages of the process. This
limitation within the reporting infrastructure means that the Council is unable to report
with confidence, on the percentage of reactive repairs appointments kept at this time. 
2.5  Since the introduction of Field Services for scheduling and reporting appointments kept,
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the housing service has undertaken regular sample reporting and audit reviews of jobs
processed through the system. These reviews have identified a number of system
anomalies including, booking outcome fields not being calculated, job completion dates
reverting to previous years, and tenant requested appointment changes being recorded
as failures, with each of these issues having an impact on reported performance in this
area. 
2.6 As each issue is highlighted through the ongoing sample reporting, this then requires
further system investigation, development and testing prior to implementation.
Unfortunately, to date each time testing is carried out after system developments to
eliminate identified issues, further anomalies continue to be identified that require
resolution. Each of the newly identified anomalies then have to follow the same process
before being released into the live system for reporting. 
2.7 Collaborative working between our Housing Repairs, Business Development &
Support, Technology & Digital Strategy Teams and MEARS IT services continues to
be carried out to ensure each of the issues highlighted through the testing are fully
resolved and sustainable solutions are implemented as quickly as possible. 
2.7 At present all failures through the system are being reviewed 4 weekly to identify any
other system issues, with meetings ongoing within the service to address these system
integration and reporting challenges to ensure that accurate, auditable performance
information can be produced for future reporting cycles. 
2.8 While it is not currently possible for us to report on the ‘Housing Repairs - % of reactive
repairs appointments kept’ indicator, the housing service continues to monitor, audit
and report on key performance measures, including the percentage of repairs jobs
completed within timescale and Customer Satisfaction with MEARS. These measures
continue to provide assurance on service performance for tenants, with the recent
performance presented to housing committee on the 16 February 2026 indicating for
the period July 2025 – December 2026:
• 97.50% of Immediate Response Jobs were completed within timescale;
• 97.04% of Normal Response Jobs were completed within timescale;
• Customer Satisfaction levels with MEARS Limited is 95.06% 
3. Measures of success 
3.1  That members will have an understanding of the reasons why the Housing Service
have not, to date, been able to report on the ‘Housing Repairs - % of reactive repairs
appointments kept’ performance indicator, and will be confident that the actions being
taken by the service to address this matter will enable accurate reporting on this 
indicator in the future. 
Stephen Llewellyn
Chief Officer (Housing & Communities) 
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5. Impacts 
5.1 Public Sector Equality Duty and Fairer Scotland Duty 
Does the report contain information that has an impact as a result of the Public
Sector Equality Duty and/or Fairer Scotland Duty? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact? 
If Yes, has an assessment been carried out and published on the council’s
website? https://www.northlanarkshire.gov.uk/your-community/equalities/equality-
and-fairer-scotland-duty-impact-assessments 
Yes ☐ No ☐
5.2 Financial impact 
Does the report contain any financial impacts? 
Yes ☐ No ☒ 
If Yes, have all relevant financial impacts been discussed and agreed with
Finance? 
Yes ☐ No ☐ 
If Yes, please provide a brief summary of the impact? 
5.3 HR policy impact 
Does the report contain any HR policy or procedure impacts? 
Yes ☐ No ☒ 
If Yes, have all relevant HR impacts been discussed and agreed with People
Resources? 
Yes ☐ No ☐ 
If Yes, please provide a brief summary of the impact? 
5.4 Legal impact 
Does the report contain any legal impacts (such as general legal matters, statutory
considerations (including employment law considerations), or new legislation)? 
Yes ☐ No ☒ 
If Yes, have all relevant legal impacts been discussed and agreed with Legal and
Democratic? 
Yes ☐ No ☐ 
If Yes, please provide a brief summary of the impact? 
5.5 Data protection impact 
Does the report / project / practice contain or involve the processing of personal
data?   
Yes ☐ No ☒ 
If Yes, is the processing of this personal data likely to result in a high risk to the
data subject? 
Yes ☐ No ☐ 
If Yes, has a Data Protection Impact Assessment (DPIA) been carried out and e-
mailed to dataprotection@northlan.gov.uk 
Yes ☐ No ☐
5.6 Technology / Digital impact 
Does the report contain information that has an impact on either technology, digital
transformation, service redesign / business change processes, data management,
or connectivity / broadband / Wi-Fi? 
Yes ☐ No ☒
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If Yes, please provide a brief summary of the impact? 
Where the impact identifies a requirement for significant technology change, has
an assessment been carried out (or is scheduled to be carried out) by the
Enterprise Architecture Governance Group (EAGG)? 
Yes ☐ No ☐
5.7 Environmental / Carbon impact 
Does the report / project / practice contain information that has an impact on any
environmental or carbon matters? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact? 
5.8 Communications impact 
Does the report contain any information that has an impact on the council’s
communications activities? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact? 
5.9 Risk impact 
Is there a risk impact? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the key risks and potential impacts,
highlighting where the risk(s) are assessed and recorded (e.g. Corporate or
Service or Project Risk Registers), and how they are managed? 
5.10 Armed Forces Covenant Duty 
Does the report require to take due regard of the Armed Forces Covenant Duty (i.e.
does it relate to healthcare, housing, or education services for in-Service or ex-
Service personnel, or their families, or widow(er)s)? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the provision which has been made to
ensure there has been appropriate consideration of the particular needs of the
Armed Forces community to make sure that they do not face disadvantage
compared to other citizens in the provision of public services. 
5.11 Children’s rights and wellbeing impact 
Does the report contain any information regarding any council activity, service
delivery, policy, or plan that has an impact on children and young people up to the
age of 18, or on a specific group of these? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact and the provision that has
been made to ensure there has been appropriate consideration of the relevant
Articles from the United Nations Convention on the Rights of the Child (UNCRC). 
If Yes, has a Children’s Rights and Wellbeing Impact Assessment (CRWIA) been
carried out? 
Yes ☐ No ☐ 
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North Lanarkshire Council
Report
Audit and Scrutiny Panel 
Does this report require to be approved? ☒ Yes   ☐ No
Ref RB/SL Date 14/05/26 
Performance reporting schedule - quarterly performance
assurance review 
From  Rachel Blair, Chief Officer (Legal, Democratic and Strategy)  
E-mail BlairR@northlan.gov.uk 
Executive Summary
The purpose of this report is to bring together a summary of the council’s performance
reports in one composite assurance overview to support the Audit and Scrutiny Panel in
maintaining strategic oversight and awareness of the council’s performance reporting
arrangements in line with the Panel’s remit to provide “independent review of the council’s
governance, risk management, performance, and control frameworks”. It also supports the
Audit and Scrutiny Panel’s governance and accountability role in terms of ensuring the
council can demonstrate Best Value through the existence of robust arrangements for
performance reporting and scrutiny.   
This process monitors reports which have been submitted to council committees (in line
with the Strategic Performance Framework - Performance Reporting Schedule) during the
previous cycle. This process began in 2023 with implementation of a quarterly performance
assurance review report thereafter. 
This report herewith provides the Panel with the outcome from the latest quarterly
performance assurance review that has been undertaken on performance reports
previously submitted to council committees during cycle 1 2026 (in line with the most recent
Performance Reporting Schedule which was at the Panel in August 2025).
Recommendations
It is recommended that the Audit and Scrutiny Panel: 
(1)  Review the composite overview of performance reporting provided in Appendices 1
and 2 to maintain an awareness of each report within the latest Performance
Reporting Schedule, and
(2)  Identify whether there are any significant issues arising, from the composite
performance overview presented in the attached Appendices, that the Panel
considers requires additional scrutiny and a further report to be submitted from the
respective Chief Officer to a future meeting of the Panel (following review through the
Scrutiny Assessment and Prioritisation Process). 
The Plan for North Lanarkshire
Item 3
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1. Background 
1.1 The quarterly performance assurance review report is now well established at the Audit
and Scrutiny Panel, having been in place since May 2023. It aligns to the Performance
Reporting Schedule considered by the Panel each year which sets out the reporting,
review, and scrutiny arrangements for a range of performance information to be
considered at each cycle of committee meetings in support of the Strategic
Performance Framework. 
1.2 The Strategic Performance Framework comprises performance measurement at three
levels. This aims to collectively provide an overview of performance to help understand
the impact of council activities on improving services and outcomes for the people and
communities of North Lanarkshire.  The measures in this Framework allow for day-to-
day activities, and progress towards achieving the long-term vision set out in The Plan
for North Lanarkshire, to be regularly monitored, reported, assessed, and scrutinised.   
1.3 The supporting Performance Reporting Schedule forms a key part of the Scrutiny Work
Programme that underpins the Best Value governance and accountability theme by
ensuring the council can demonstrate the existence of robust arrangements for scrutiny
and performance reporting.  It also aims to fulfil the Audit and Scrutiny Panel’s remit as
per the Scheme of Administration to:
• Review and monitor the performance of the council in delivering upon its priorities,
outcomes, programme of work and targets in the council plan, specifically
performance in improving local services and outcomes and in demonstrating Best
Value.
• Review performance to assess whether intended policy outcomes have been
achieved. 
1.4 The Strategic Performance Framework comprises a set of non-negotiable standards
which Chief Officers are required to apply in all performance reporting that supports the
Framework.  These standards aim to ensure that performance reporting is:
• Aligned - to The Plan for North Lanarkshire to give stakeholders an insight into the
performance of council activities both in the short-term and against the long-term
ambitions.
• Consistent - to ensure a standard, easily recognisable, and well-established
process across each different audience over time.  This aims to help build
credibility, reliability, and a common understanding.
• Transparent - to allow stakeholders to understand what is being measured, what
it means, what level of performance has actually been achieved, and what
difference this means in reality for the people and communities of North
Lanarkshire.
• In context - to avoid the So What? question and provide a coherent narrative to
ensure fully informed review, reporting, scrutiny, and decision-making processes.
• Balanced - to ensure reporting contains areas in which performance has improved
as well as areas where performance has not improved or has declined.  Any
supporting narrative in this respect must add value and tell a balanced narrative. 
The narrative should include reasons for performance levels not in line with targets,
standards, or original plans and the remedial action undertaken to address this. 
Priority  All priorities
Ambition statement All ambition statements
Programme of Work Statutory / corporate / service requirement
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1.5 The Performance Reporting Schedule highlights a significant volume of performance
information scheduled for reporting to council committees throughout the year. Cycle 1
2026 reports were reviewed by the Business Management Team in April 2026 to
provide assurance, in line with the Best Value duty, that performance management
arrangements support the effective use of council resources, are subject to appropriate
senior management scrutiny, and that performance monitoring effectively identifies and
addresses areas of underperformance through agreed remedial actions. 
1.6 The volume of performance information in the latest cycle has been reviewed and
summarised in Appendices 1 and 2 attached - it should be noted that the performance
information within these Appendices has already been reviewed by Service
Committees during cycle 1 2026.  The purpose of the information presented herewith
is therefore to provide Audit and Scrutiny Panel members with a composite, but easily
digestible, overview for governance and assurance purposes in line with the specific
scrutiny and strategic oversight role of the Panel. 
1.7 Should the Panel consider there are any significant issues arising from the composite
performance overview which require additional scrutiny, these matters will be reviewed
through the Scrutiny Assessment and Prioritisation Process (updated and approved by
the Panel in September 2022 and further endorsed in September 2023), prior to being
added to the Scrutiny Work Programme for a further report to be submitted from the
respective Chief Officer to a future meeting of the Panel. 
2. Quarterly performance assurance review 
2.1 The Strategic Performance Framework - Performance Reporting Schedule sets out
several aspects of performance reporting.  As part of this, paragraphs 2.2 to 2.6 itemise
the performance reports submitted to cycle 1 2026 committees in accordance with the
timetable set out in the Schedule. 
(1) Chief Officer’s individual Performance Review reports at Service Committees in
line with the Strategic Performance Framework.
(2) Chief Officer service specific performance reporting which takes place each year
to meet business and/or statutory obligations. 
(1) Chief Officer’s individual Performance Review reports at Service Committees in
line with the Strategic Performance Framework. 
2.2 The Strategic Performance Framework comprises a range of performance indicators
from each Chief Officer’s portfolio and the latest results in this respect are aligned to
the respective ambition statements in The Plan for North Lanarkshire. The three reports
previously submitted to the relevant committee in cycle 1 2026 are listed in Table 1
below, along with the corresponding hyperlink for ease of access.   
Table 1 
Report title Committee Date
Latest performance results - Community
Operations
link to file
Environment and
Climate Change
Committee
11 February
2026
Latest performance results - Housing
link to file Housing Committee 18 February
2026
Adult social care performance - Quarter 2 (July to
September 2025) link to file
Adult Care and Social
Work Committee
24 February
2026 
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2.3 Each council report was produced in line with a standard template and (a) provides the
reader with the current context within which the service is operating, (b) highlights areas
of good performance that can be evidenced in the accompanying data, and (c) provides
a summary of areas of performance requiring improvement along with narrative that
gives an explanation for the level of performance achieved and summarises the
remedial action implemented (or to be implemented) to bring performance back on
track.   
2.4 A short summary analysis for each of the reports is set out in Appendix 1 against the
five non-negotiable standards. 
(2) Chief Officer service specific performance reporting which takes place each year to
meet business and/or statutory obligations. 
2.5 This aspect relates to service specific reporting which is required to meet business
and/or statutory obligations. This is included in the Performance Reporting Schedule to
ensure all the council’s performance reporting arrangements are captured in the one
place and the Schedule reflects a one council approach to performance reporting.   
2.6 The 13 reports previously submitted to the relevant committee in cycle 1 2026 are listed
in Table 2 below, along with the corresponding hyperlink for ease of access. A short
summary for each of these reports is set out in Appendix 2.  While this summary is set
out against the five non-negotiable standards it recognises there may also be statutory
specific approaches or standards which require to be adhered to. 
Table 2 
Report title Committee Date
Data protection compliance and activity - annual
report 2024/25
link to file
Finance and
Resources Committee 4 March 2026
Senior Information Risk Owner (SIRO) interim
assurance and performance report January -
March 2025 link to file
Finance and
Resources Committee 4 March 2026
Public Sector Duties climate change annual report
2024/25
link to file
Environment and
Climate Change
Committee
11 February
2026
Community safety hub - performance 2024/25
link to file Housing Committee 18 February
2026
Community payback order - annual report 2024/25
link to file
Education, Children,
and Families
Committee
3 March 2026
North Lanarkshire Community Planning
Partnership: annual oversight and improving
outcomes report 2024/25
link to file
Communities
Committee
9 February
2026
Education performance update
link to file
Education, Children,
and Families
Committee
3 March 2026
Housing and corporate maintenance and
investment services contract - interim report
link to file
Housing Committee 18 February
2026
Roads and infrastructure maintenance and
improvement services contract - interim report
link to file
Environment and
Climate Change
Committee
11 February
2026
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Report title Committee Date
Revenue and benefits update
link to file
Finance and
Resources Committee 4 March 2026
Financial monitoring report - council summary
(revenue)
link to file
Finance and
Resources Committee 4 March 2026
Financial monitoring report - council summary
(capital)
link to file
Finance and
Resources Committee 4 March 2026
Financial monitoring - savings 
link to file
Finance and
Resources Committee 4 March 2026 
Next steps 
2.7 Assurance reviews will continue to be undertaken and reported to the Audit and
Scrutiny Panel on a quarterly basis in order to maintain the measures of success set
out in paragraph 3.1. The content of the quarterly assurance review reports will continue
to be informed by the Performance Reporting Schedule, most recently updated and
presented to the Audit and Scrutiny Panel in August 2025. 
2.8 Reports submitted to the respective committees, in line with the Performance Reporting
Schedule, will continue to be kept under review by the council’s senior management
team to ensure adherence to the agreed timetable. This approach also provides
assurance regarding the efficient and effective operation of the council and supports
the ongoing delivery of the long-term ambition set out in The Plan for North Lanarkshire,
underpinned by robust corporate governance arrangements. 
3. Measures of success 
3.1  Measures of success include:
• Regular oversight and monitoring of performance across the organisation,
providing assurance on effective governance, accountability, and transparency.
• Regular review and challenge processes that scrutinise council performance to
ensure effective use of resources, alignment with agreed policy and priorities,
sound decision-making, and clear accountability for how resources are applied to
achieve improved outcomes for service users and the local community.
• Robust performance monitoring, management, and reporting arrangements that
support the demonstration of service improvement, improved outcomes, and the
delivery of Best Value. 
4. Supporting documentation 
Appendix (1) Chief Officer’s individual Performance Review reports at Service
Committees in line with the Strategic Performance Framework.
Appendix (2) Chief Officer service specific performance reporting which takes place
each year to meet business and/or statutory obligations. 
Rachel Blair
Chief Officer (Legal, Democratic and Strategy) 
5. Impacts 
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5.1 Public Sector Equality Duty and Fairer Scotland Duty 
Does the report contain information that has an impact as a result of the Public
Sector Equality Duty and/or Fairer Scotland Duty? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact?   
If Yes, has an assessment been carried out and published on the council’s
website? https://www.northlanarkshire.gov.uk/your-community/equalities/equality-
and-fairer-scotland-duty-impact-assessments 
Yes ☐ No ☐
5.2 Financial impact 
Does the report contain any financial impacts? 
Yes ☐ No ☒ 
If Yes, have all relevant financial impacts been discussed and agreed with
Finance? 
Yes ☐ No ☐ 
If Yes, please provide a brief summary of the impact?
5.3 HR policy impact 
Does the report contain any HR policy or procedure impacts? 
Yes ☐ No ☒ 
If Yes, have all relevant HR impacts been discussed and agreed with People
Resources? 
Yes ☐ No ☐ 
If Yes, please provide a brief summary of the impact?
5.4 Legal impact 
Does the report contain any legal impacts (such as general legal matters, statutory
considerations (including employment law considerations), or new legislation)? 
Yes ☒ No ☐ 
If Yes, have all relevant legal impacts been discussed and agreed with Legal and
Democratic? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact? 
The legal impact in this report is only in relation to supporting demonstration of the
council’s compliance with the relevant legislation listed below.  It does not introduce
new legal duties or changes to the council’s statutory duty in this respect.
• The Local Government Act 1992 established the role of the Statutory Direction
to direct councils in terms of the “publication of information as to standards of
performance”.  
• The Local Government in Scotland Act 2003 introduced the statutory duty of
Best Value which requires the council to “make arrangements which secure Best
Value” and ensure “continuous improvement in the performance of the
authority’s functions”.
5.5 Data protection impact 
Does the report / project / practice contain or involve the processing of personal
data?   
Yes ☐ No ☒ 
If Yes, is the processing of this personal data likely to result in a high risk to the
data subject? 
Yes ☐ No ☐ 
If Yes, has a Data Protection Impact Assessment (DPIA) been carried out and e-
mailed to dataprotection@northlan.gov.uk 
Yes ☐ No ☐
5.6 Technology / Digital impact
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Does the report contain information that has an impact on either technology, digital
transformation, service redesign / business change processes, data management,
or connectivity / broadband / Wi-Fi? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact? 
Where the impact identifies a requirement for significant technology change, has
an assessment been carried out (or is scheduled to be carried out) by the
Enterprise Architecture Governance Group (EAGG)? 
Yes ☐ No ☐
5.7 Environmental / Carbon impact 
Does the report / project / practice contain information that has an impact on any
environmental or carbon matters? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact?
5.8 Communications impact 
Does the report contain any information that has an impact on the council’s
communications activities? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact?
5.9 Risk impact 
Is there a risk impact? 
Yes ☒ No ☐ 
If Yes, please provide a brief summary of the key risks and potential impacts,
highlighting where the risk(s) are assessed and recorded (e.g. Corporate or
Service or Project Risk Registers), and how they are managed? 
Implementation of the Performance Reporting Schedule, which facilitates regular
reporting, review, and scrutiny processes, contributes to mitigating the risk on the
Corporate Risk Register in relation to governance, leadership, and
decision-making.
5.10 Armed Forces Covenant Duty 
Does the report require to take due regard of the Armed Forces Covenant Duty (i.e.
does it relate to healthcare, housing, or education services for in-Service or ex-
Service personnel, or their families, or widow(er)s)? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the provision which has been made to
ensure there has been appropriate consideration of the particular needs of the
Armed Forces community to make sure that they do not face disadvantage
compared to other citizens in the provision of public services.
5.11 Children’s rights and wellbeing impact 
Does the report contain any information regarding any council activity, service
delivery, policy, or plan that has an impact on children and young people up to the
age of 18, or on a specific group of these? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact and the provision that has
been made to ensure there has been appropriate consideration of the relevant
Articles from the United Nations Convention on the Rights of the Child (UNCRC). 
If Yes, has a Children’s Rights and Wellbeing Impact Assessment (CRWIA) been
carried out? 
Yes ☐ No ☐
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Appendix 1 
(1) Chief Officer’s individual Performance Review reports at Service Committees in line with the Strategic Performance Framework. 
Report title Summary
Latest performance
results - Community
Operations 
February 2026
Community Operations has 34 indicators in the Strategic Performance Framework which assess efficiency and effectiveness in terms of delivery on
a day-to-day basis. A suite of benchmarking indicators also enables performance, costs, and satisfaction to be assessed and compared nationally.   
A single Community Operations service is in place following various structural realignments which have brought together a range of front facing
services in relation to the council’s environmental assets (i.e. Street Cleaning, Grounds Maintenance, Cemetery Services, Roads Maintenance
Operations, and Country Parks for the Future) as well as regulatory related services (i.e. Environmental Health and Trading Standards), and
services in respect of Waste Solutions, Fleet Resources, and the Built Environment.  The creation of a single front-line community operation has
integrated services and enhanced natural environments and green spaces, supporting the day-to-day management of environmental, cultural, sport,
and leisure assets while promoting wellbeing, social inclusion, physical and mental health, and stronger connections with the local environment.
Aligned Priority:  • Improve the health and wellbeing of our communities.
• Enhance participation, capacity, and empowerment across our communities.
Ambition statement: 14. Ensure the highest standards of public protection.
16. Transform our natural environment to support wellbeing and inward investment and enhance it for current and future generations.
17. Ensure we keep our environment clean, safe, and attractive.
Consistent The pre-defined template was used to ensure a standard, easily recognisable, and well established process across each different audience over time.  The use
of this template aims to help build credibility, reliability, and a common understanding.
Transparent Benchmarking indicators: https://www.improvementservice.org.uk/benchmarking/explore-the-data 
• Parks and open spaces - cost per 1,000
population
• Satisfaction - with parks and open spaces
• Street cleaning - net cost per 1,000 population 
• Satisfaction - with street cleaning services 
• Street cleanliness score - % assessed as clean 
• Satisfaction - with refuse collection 
• Roads - cost of maintenance per km of roads
• Road network - % A class roads that should
be considered for maintenance treatment
• Road network - % B class roads that should
be considered for maintenance treatment
• Road network - % C class roads that should be
considered for maintenance treatment 
• Road network - % Unclassified roads should be
considered for maintenance treatment 
• Environmental health - cost per 1,000 population
• Street lamps - energy usage
RAG 
indicators: 
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In context As the service’s operating environment has changed significantly in recent years, performance should be considered within the context of the following: 
• A rationalisation of land and waste services is underway to consolidate operations within key depots, improving efficiency, co-locating services, and
generating capital through the sale of surplus sites.
• The service played a key role in supporting the council’s pandemic response and recovery from 2020 to 2022, while maintaining key public health and safety
services in line with legislation. Resuming business as usual activities involved significant backlogs which are now reducing with performance stabilising.
• As services returned to normal, increased caseloads - particularly in environmental health - combined with the post-pandemic food law recovery plan led to
higher inspection volumes and required changes to processes and ways of working. 
In addition, the report references the Internal Audit review reported to the Audit and Scrutiny Panel in May 2025 and confirms that the performance report
implements one of the recommendations to report performance information to senior management and elected members. Work is ongoing to address the
second recommendation on improving compliance with corporate processes for performance indicators, including a review of the current suite to ensure
effectiveness, alignment with The Plan for North Lanarkshire, and support for continuous improvement, with new measures (including updated targets and
thresholds) to be reported from April 2026. 
In the meantime, work is underway to align systems and integrate request processes to support a new measure tracking bins lost or damaged during collection,
with data expected to be available for reporting from April 2026.
Balanced Performance highlights: 
• Latest figures show that 32.6% of North Lanarkshire's roads overall are considered to require maintenance treatment which maintains the consistent trend
over the years of less than a third of all roads requiring maintenance treatment. Performance also remains below (and therefore better than) target. 
• The council’s performance in respect of A class roads (i.e. major and strategic roads) which are considered to require maintenance treatment continues to
remain lower than the averages for Scotland and the family group of similar councils with less than a quarter (23.8%) of A class roads in North Lanarkshire
considered to require maintenance treatment compared to the Scottish average (30.6%) and the family group of similar councils (28.2%). The latest figures
show a decrease in the cost of maintaining roads per kilometre, which is also lower than comparable councils, despite North Lanarkshire’s heavily used road
network and higher levels of wear due to traffic density.
• Overall refuse service performance remains strong, with disposal costs below target, stable customer satisfaction, a record recycling rate of 47.9% - above
national and comparable councils averages - and low complaint levels at 1.3 per 1,000 household collections (which overall equates to 15,195 complaints
out of over 12 million household collections during 2024/25).
• The proportion of eligible premises achieving the national Food Hygiene Information Scheme (FHIS) pass award continues to perform above target. The
latest year to date figures, up to and including quarter 3 of 2025/26, show 96.1% of premises (2,452 out of 2,552) achieving the pass award. 
Areas of performance requiring improvement:
• Previous performance reports to the Environment and Climate Change Committee had noted performance in completion certificates and building warrants
continuing to remain below target, however both these service areas had experienced a significant improvement as at the 2024/25 year end. This followed a
prolonged period of high demand volumes combined with increased customer expectation around the completion of projects and extent of on-site activities
as well as challenges around the recruitment process, long-term absences, support issues, and system outages all contributing to lower than target
performance. Performance in 2025/26 to date has subsequently shown a small decline and the reasons for this are being investigated. 
• Enquiries closed off within response timescales in relation to roads enquiries and streetlight repairs completed within 7 days had both shown performance
lower than the expected target for 2024/25. This period included the transition to a new term maintenance contractor and the implementation of a new
maintenance management system, both of which encountered some teething issues that impacted on the reported performance figures; however, these
have now been resolved, and it is expected that the 2025/26 figures will show improvement in this respect. 
• Overall, performance results in relation to unit costs available through the Local Government Benchmarking Framework (LGBF) suite of indicators represent
a mixed picture across all councils in Scotland. The annual LGBF overview publication recognises general trends across Scotland, however, unit costs
should never be considered in isolation and a full picture of performance is required to show the full and complete position.  In addition, it should be noted
that the LGBF does not cover every service delivered by Community Operations.
Report title Summary Page 19 of 238

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Latest performance
results - Housing 
February 2026
Housing has 22 indicators in the Strategic Performance Framework, covering all aspects of the council’s social landlord role, including housing
management, property services, housing repairs and investment, rent and void management, tenancy management, tenant satisfaction, and 
homeless related services. 
Performance is monitored through statutory returns (the Annual Return on the Charter (ARC), the Scottish Government Housing Annual Statistical
Return (HSAR), and the Scottish Government Homeless returns (HL1)), alongside service and contract indicators, with regular benchmarking and
practice sharing through the Scottish Housing Network. 
The council’s new Local Housing Strategy for 2026-28 was approved by the Housing Committee in February 2026.  This sets out the long-term
vision to deliver affordable and sustainable homes in thriving communities that meet individual needs and enhance quality of life, supported by
housing services that promote health, wellbeing, and opportunity for all in North Lanarkshire. 
As set out in the council’s Local Housing Strategy for 2026-28, there are an estimated 160,847 dwellings in North Lanarkshire, with home ownership
remaining the predominant tenure and 63% of households owning their own home - of this, 37% own their home outright and 25% own it with the
help of a loan or mortgage. 
Aligned Priority:  • Improve economic outcomes and opportunities.
Ambition statement: 1. Ensure a housing mix that supports social inclusion and economic growth.
Consistent The pre-defined template was used to ensure a standard, easily recognisable, and well established process across each different audience over time.  The use
of this template aims to help build credibility, reliability, and a common understanding.
Transparent  RAG indicators: 
In context • The continued increase in the cost of living is placing substantial financial pressure on tenants, and responding to this challenge remains a central priority for
the service. The Rent Assistance Fund, introduced in February 2023, has played a significant role in providing support to tenants, particularly those on low
incomes. This has contributed to sustaining stable tenancies during this period of economic difficulty. To date 2,373 tenants have been helped by this
innovative fund, which not only helps the tenant in their time of need but encourages continued engagement between the tenant and their housing officer.
This has in turn helped reduce the overall rent arrears figure to 6.6%. 
• Several Scottish local authorities have formally declared a housing emergency in response to rising homelessness, severe shortages of affordable homes,
and increasing pressure on statutory services. In May 2024, the Scottish Government also declared a national housing emergency, acknowledging
escalating homelessness, falling housing completions, and wider affordability challenges. Over recent years, North Lanarkshire has experienced an increase
in homelessness presentations, with a 13% increase recorded between 2021/22 and 2022/23 and a further 16% rise observed between 2022/23 and
2023/24. This reflects the growing pressures faced by vulnerable households. Despite these challenges, the sustained commitment and proactive prevention Page 20 of 238

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work of locality teams and support staff have enabled the council to manage resources effectively and provide targeted assistance where it is most needed.
This approach has contributed to a reduction in presentation numbers (8% in 2024/25 and a further 3.5% year to date in 2025/26), indicating that
interventions are delivering positive outcomes and work continues to target operational activities to address caseloads. 
• The service continues to comply fully with the Homeless Persons (Unsuitable Accommodation) (Scotland) Order 2014 and does not utilise B&B-type
accommodation, which remains a common contingency measure in other local authority areas.
Balanced Performance highlights 
• The percentage of rent due in the year that was lost due to properties being empty (0.67%) is sitting below (i.e. is better than) last year’s outturn of 0.80%
and is below the target of 1%. Average time taken to re-let properties remains consistent with last year’s figure at 29.9 days and within the target of 30 days. 
• The proportion of lets to homeless people has increased further in 2025/26 to 52% to address the caseload. The latest results with the quality of temporary
accommodation shows 97.8% compared to an increased target of 96%, and reflects the quality of furnishings and fittings in the accommodation as well as
the high level of decoration.
• The repairs service continues to perform well with the average timescale for emergency repairs completed being 2.37 hours, 0.3 hours less than last year’s
outturn and well within the target timescale of 3.75 hours. The latest average of 6.7 days to complete non-emergency repairs is within the target of 7 days.
Areas of performance requiring improvement 
• The percentage of decisions made within 28 days for households presenting as homeless (90.8%) is below the target of 95%. The percentage of decisions
made within 28 days for households under 25 years old presenting as homeless (90.7%) is also below the target of 95%. These figures reflect the transient
nature of the client group, where maintaining contact to allow staff to make decisions within timescale can be difficult. Service audits are ongoing to
determine the reasons for the decline in performance in these areas; the main reason being lost contact from the applicant.
Report title Summary
Adult social care
performance - Quarter 2
(July to September 2025) 
February 2026
The Chief Officer (Health and Social Care North Lanarkshire) holds joint quarterly performance review meetings with the Chief Executives of NHS
Lanarkshire and North Lanarkshire Council. These are supported by a Chief Executive’s Performance Framework, covering key measures,
targets, and trajectories across health and social work systems. 
In each quarter areas for improvement within the performance framework are identified through the use of a RAG rating.  Measures flagged as
Red or Amber are subject to improvement or corrective action, which are jointly agreed through the performance review meetings.
Aligned Priority:  • Improve the health and wellbeing of our communities.
Ambition statement: 12. Ensure our residents are able to achieve, maintain and recover their independence through appropriate supports at home and in
their communities.
13. Improve preventative approaches including self-management and giving people information and choice over supports and services.
14. Ensure the highest standards of public protection.
Consistent A pre-defined Health and Social Care Partnership template is in place to ensure a standard, easily recognisable, and well established process for quarterly
reporting on areas for improvement.
Transparent Based on a traffic-light system there are areas for improvement identified within the performance framework each quarter for those areas that are flagged as
Red or Amber.  The areas for improvement identified are progressed as a matter of priority, and progress updates are reported at future meetings of the
Integrated Joint Board and/or the Integration Joint Board Performance, Finance, and Audit Committee as appropriate.
In context • Information from the joint quarterly performance reviews has been supplemented with additional information to offer a wider overview of performance across
key areas of adult social care delivery.
• Mosaic, the new Social Work Information System, went live in June 2025. This meant that all standardised reporting provided by the team required to be
rebuilt and necessitated testing with live data along with verification by users of the reports. In addition, due to data recording on the previous system (SWIS) Page 21 of 238

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ceasing prior to the go-live for Mosaic, data and information from multiple sources is required to produce standardised reporting. This includes data from
ELMS2 (the software solution that supports the management of community equipment services) for equipment and adaptations and the dynamic scheduling
tool for home care where both systems have also recently gone live, with reporting still in development to reflect the new recording processes and subject to
testing and validation. While every effort is being made to maintain continuity of reporting, the ability to provide data and information is impacted in the short-
term and there is some disruption to the Social Care reporting contained within the Chief Executive’s scorecard. Some metrics therefore have no value for
certain quarters as these parts of the Mosaic system are not yet operational.
Balanced The purpose of the report is to provide an update on the areas for improvement what have been identified as part of the quarterly performance review.  The
quarter 2 report (for July - September 2025) sets out corresponding narrative and corrective actions agreed; these are summarised below. 
• Assistive technology - performance remains below target, largely due to improved data completeness following system changes rather than reduced activity.
Better visibility from ELMS2 and Mosaic now gives a more accurate picture. Demand for assistive technology remains high, driven by hospital discharge
pressures and the priority to support people at home, while capacity constraints continue to affect delivery. Work is ongoing to stabilise performance through
improved alignment with home support and reablement, clearer prioritisation, refined data quality, and a review of targets, with assistive technology
remaining a key enabler of discharge and community support.
• Reablement and rehabilitation - the indicators for reablement presented in the scorecard in the appendix to the report have not met the targeted levels of
performance. Performance in Q2 remains below target, with fewer new or increased home support cases progressing through reablement and little change
in local variation. Capacity constraints, pathway complexity, and local operational pressures continue to influence decision making in this area.  Overall,
system pressures and local practice variation continue to constrain delivery, and further work is required to improve compliance, reduce variation, and
strengthen reablement’s role within home support and discharge pathways.
• Home support redesign - this programme focuses on delivering outcome-based support for individuals and families, aligned with B2B, self-directed support,
and developments in hospital flow.  It is supported by several products that have been produced to progress the work, including service specifications, a
workforce profile, and an analysis of demand / capacity data. The proposal is for a Living Well service that provides home support to achieve individual
outcomes for the people using the service and a distinct assessment and planning service, that will include Rehabilitation and Reablement services.  This
aims to ensure that people receive a holistic assessment of their need and are provided with the most appropriate services to meet individual outcomes. 
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Appendix 2 
(2) Chief Officer service specific performance reporting which takes place each year to meet business and/or statutory obligations. 
Report title Summary
Data protection
compliance and activity
- annual report 2024/25 
March 2026
This report provides a strategic assessment of the council’s performance and compliance with its statutory data protection and information
governance obligations during 2024/25. It presents a detailed analysis of personal data breaches, engagement with the Information
Commissioner’s Office (ICO), Subject Access Request (SAR) performance, staff training and awareness, and the effectiveness of governance
and assurance arrangements. 
The report fulfils the requirement for the Data Protection Officer (DPO) to report assurance on the council’s overall compliance position. 
It provides assurance alongside the Senior Information Risk Owner (SIRO) annual report.
Aligned Priority:  • All priorities. 
Ambition statement: • All ambition statements.
Consistent As a public authority and data controller, the council is subject to a comprehensive statutory framework governing the processing of personal data.
Effective data protection and information governance are fundamental to maintaining public confidence, safeguarding individuals’ rights, and ensuring
compliance with statutory obligations, including the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR). This legislation
imposes enhanced accountability obligations, requiring the council not only to comply with legal requirements but to be able to demonstrate that
compliance through effective governance, documentation, and assurance.
Transparent The report outlines the council’s governance arrangements that are in place to provide strategic leadership, operational oversight, and assurance in
relation to information governance and data protection compliance.  This comprises:
• The Senior Risk Owner (SIRO) - providing strategic leadership on information governance and information risk management across the council,
ensuring that information risks are identified, understood, and managed in line with the council’s risk appetite and statutory obligations. 
• The Data Protection Officer (DPO) - responsible for overseeing compliance with data protection legislation, including the UK GDPR and the Data
Protection Act 2018, providing independent advice to the council, monitoring internal compliance, advising on Data Protection Impact Assessments
(DPIAs), and acting as the primary point of contact with the Information Commissioner’s Office (ICO). 
• The Data Governance Board (DGB) - providing strategic oversight of data protection and information governance, with regular reporting to the Business
and Corporate Management Teams. It is responsible for setting direction, overseeing implementation, and securing assurance that effective
arrangements are in place across the council and its Arm’s Length External Organisations (ALEOs).  The DGB is supported by a group of
representatives from across services who provide operational oversight, monitor compliance, and drive day-to-day implementation and improvement.
• The Information Governance Team in Legal and Democratic - providing specialist legal advice and support across a range of information governance
legislation, ensuring services are supported to meet their statutory obligations. Through a combination of strategic oversight, operational monitoring,
and continuous engagement, the council ensures that its approach to data protection is integrated, proactive, and aligned with best practice.
In context Regulatory expectations, particularly those articulated by the ICO, have increasingly emphasised leadership accountability, evidence-based decision-
making, and demonstrable continuous improvement.  This report reflects that context and provides an integrated view of performance, risk, and assurance
across the council’s information governance landscape. 
During 2024/25, the council has continued to strengthen its arrangements across the following core areas - management and reporting of personal data
breaches, engagement and compliance with the ICO, delivery of mandatory and targeted staff training, compliance with individuals’ information rights
(particularly SARs), and strengthening governance, assurance, and accountability structures. 
A strategic focus has been placed on anticipating emerging risks, embedding a culture of accountability, and ensuring that operational practices are both
proactive and resilient to future regulatory developments. The council has also sought to integrate technological solutions, including SAR tracking systems Page 23 of 238

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and secure communication platforms, to enhance efficiency and reduce human error.
Balanced Overall, the council has demonstrated measurable and sustained improvement across several key areas of compliance. In particular, notable progress has
been achieved in the management and governance of SARs within social work services, the development and delivery of targeted service-specific training,
and a significant increase in completion rates for mandatory data protection and information security training. These improvements reflect strengthened
leadership oversight, clearer accountability, and increased organisational focus on information governance as a core corporate responsibility. 
Notwithstanding this progress, the report also identifies areas where further improvement is required to ensure full and consistent compliance with statutory
requirements and regulatory expectations. Increased scrutiny from the ICO, particularly in relation to SAR performance, underscores the need for
continued focus on timely and high-quality responses, improved recording and tracking arrangements, and sustained staff awareness to prevent avoidable
personal data breaches. 
A clear programme of ongoing and planned improvement actions is therefore set out to address these risks and to support continuous improvement. The
report also provides strategic insight into emerging legislative frameworks, technological enablers, and organisational trends that will influence the council’s
information governance practices over the next three to five years. 
Report title Summary
Senior Information Risk
Owner (SIRO) - interim
assurance and
performance report
January - March 2025 
March 2026
The Senior Information Risk Owner (SIRO) report provides assurance that the council’s information governance, data protection, and
information security arrangements remain effective, proportionate, and appropriately overseen. These arrangements support the council in
meeting its statutory, regulatory, and good practice obligations, while protecting the confidentiality, integrity, and availability of information
essential to service delivery and public trust. 
The report covers the interim period from January to March 2025. It has been prepared to close out reporting under the previous calendar-year
SIRO reporting cycle and to support the transition to annual SIRO reporting aligned to the financial year (April to March), in line with other
corporate governance, risk, and assurance reports considered by the same committee.
Aligned Priority:  • All priorities. 
Ambition statement: • All ambition statements.
Consistent • The SIRO role is mandatory for public sector organisations and organisations which are contracted to deliver services under the NHS standard contract.
The report sets out the SIRO responsibilities which includes:
- Leadership and overall ownership of the council’s corporate governance action plan in terms of acting as corporate champion for information
governance.
- Acting as Executive Sponsor and advocate for the management of information governance at a senior level.
- Providing advice and reports in respect of information incidents and risks, including informing the content of the council’s Annual Governance
Statement relating to information risk. 
- Owning the management of information governance and associated risk assessment processes within the council. 
- Understanding how the strategic priorities of the council may be impacted by information governance risks, and how these risks need to be managed
including the adequacy of resources and levels of independent scrutiny.
Transparent • The report advises that SIRO responsibilities had previously been aligned with the Chief Officer (Business and Digital) remit since September 2019, but
following consideration of the One Place, One Plan - Governance update report at Policy and Strategy Committee in September 2024, this responsibility
transferred to the Chief Officer (Legal and Democratic) from April 2025. This change strengthens alignment between information governance, legal
compliance and corporate assurance, and future SIRO reports will reflect this revised governance structure.
• The primary purpose of the interim report is to: 
-  Provide clear, concise and proportionate assurance across the key areas for which the SIRO is accountable. Page 24 of 238

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-  Confirm whether any material changes to assurance positions arose during the January-March 2025 period.
-  Provide forward-looking context by summarising known improvements and developments being delivered during 2025/26, ensuring the report
remains relevant when considered by committee. 
• To support clarity and transparency, the report adopts a structured, assurance-based approach, presenting the council’s position through a single
consolidated assurance table at Appendix 1. This approach avoids duplication with detailed operational reporting, strengthens the line of sight between
assurance and risk, and enables Members to readily understand three key points in relation to assurance and risk - what assurance was previously
provided, whether that assurance position has changed, and what further improvements are being delivered.
In context • The report sets out the contents within which information governance and information security responsibilities are distributed across the council, i.e.
across multiple officers, teams, and governance structures.
• While specialist functions provide expertise and operational delivery, effective information governance relies on strong leadership, clear accountability,
robust assurance mechanisms and consistent organisational compliance. The SIRO acts as the council’s corporate champion for information
governance, providing senior-level ownership of information risk and assurance to the Corporate Management Team and the Finance and Resources
Committee. This includes oversight of compliance with data protection legislation, information security standards, records management obligations, and
associated risk management arrangements. 
Balanced The report provides the following assessment of the council’s information governance arrangements for the period January to March 2025, representing an
interim assurance position ahead of the move to annual financial-year SIRO reporting:
• The council has well-established information governance, data protection, and information security arrangements, embedded within its wider corporate
governance, risk management, and internal control framework. These arrangements are supported by documented policies and standards, technical
controls, mandatory training, and structured governance oversight.
• Oversight of information governance continues to be provided through the Data Governance Board (DGB), which monitors compliance, risk, incidents,
improvement activity, and assurance across the organisation. This is supported by specialist operational teams with responsibility for data protection,
cyber security, records management, and digital services. 
• Previous SIRO reports have confirmed that the council operates at a developing level of data and information management maturity, with sustained and
measurable improvement achieved over recent years. This has been driven by targeted investment in systems, strengthened governance, improved
training compliance, and increased senior oversight of information risk. To improve transparency, readability, and Elected Member assurance, this interim
report presents the SIROs assurance through a consolidated assurance table which is attached to the report at Appendix 1, covering the key statutory
and good-practice areas relevant to the SIRO role. This includes data protection compliance, cyber security, incident management, risk management,
records management, training and awareness, and corporate accountability.
• Based on the evidence reviewed, the report states that the SIRO is satisfied that appropriate and proportionate information governance, data protection,
and information security arrangements were in place during the period January to March 2025. No material deterioration in assurance was identified
during this interim period, and no regulatory enforcement action was taken against the council. 
• The transition to financial-year SIRO reporting will enable stronger alignment with corporate planning, risk management, audit and digital transformation
activity, and will allow future reports to provide a more comprehensive, outcome-focused, and forward looking assurance position.
Report title Summary
Public Sector Duties
climate change annual
report 2024/25 
February 2026
The Climate Change (Duties of Public Bodies: Reporting Requirements) (Scotland) Order 2015 introduced a legal obligation for public bodies
to report annually on their compliance with the duties specified in the Climate Change (Scotland) Act 2009 and its subsequent amendments.
The report is produced annually for the most recently completed financial year with a national submission date of 30th November each year. 
The report provided the Environment and Climate Change Committee with a summary of the content of the Public Sector report on Compliance
with Climate Change Duties submitted on behalf of the council in November 2025 for the 2024/25 reporting year.  It also provides an update on
progress against carbon budgets set within the council’s Climate Plan ACT2030 and work that contributes to the overall net-zero ambition.  
Aligned Priority:  • All priorities. Page 25 of 238

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Ambition statement: • All ambition statements.
Consistent • A standard report template is provided to all local authorities which comprises a number of sections that require information on the organisation’s profile,
governance, emissions and projects, adaptation, procurement, and validation as well as a non-mandatory section in relation to wider influence.  Within
the council, this information is collated annually and verified for submission by the relevant council service.
• The report follows on from that at Committee in 2023 and uses an organisational carbon boundary.  An organisational carbon boundary is a visual
representation of the scope of activities, assets, and emissions sources that are included when calculating the carbon footprint. Those sources outwith
the carbon boundary are ones where they are not organisational emissions (such as domestic consumption) or there is no data available to provide a
meaningful result. The council’s carbon boundary was determined by looking at how buildings are used, how transport is used for service delivery, and
how waste is managed.
Transparent The February 2026 report shows a summary of the council’s greenhouse gas emissions in terms of carbon tonnes equivalent (CO2e) from the baseline year
(2015/16) to the end of the latest reporting year (2024/25).  This includes the annual emissions target set.  A breakdown of emissions and the emissions
source is also contained within an appendix to the report.  
• For 2024/25 the council’s greenhouse gas emissions totalled 57,155 tCO2e.  This has been achieved via reductions in scope 1, 2, and 3 emissions
(2.3%, 5%, and 17.8% respectively).
- Scope 1 emissions accounted for 29,066 tCO2e, a 2.3% reduction from last year achieved through less use of natural gas, kerosene, and diesel.
- Scope 2 emissions arise solely from electricity use, which decreased year-on-year, reducing emissions.
- Scope 3 emissions for the reporting year are 17.8% lower than 2023/24 with reductions in grey fleet (business mileage) and various waste streams
contributing to the overall reduction, with the most significant reduction in refuse municipal to landfill realising a 7% reduction in related emissions.
The overall reduction in scope 3 emissions since baseline year is 23,593 tCO2e (59.1%).
• The statutory reporting process is supported by the Sustainable Scotland Network who also analyse annual submissions from the public sector bodies’
reports and report their overall findings publicly.  This includes identifying strengths and weaknesses
(https://sustainablescotlandnetwork.org/organisation-report/north-lanarkshire-council/ ).
In context The report advises that:
• The council’s progress towards net zero has benefitted from deliberate climate action. Progress can be impacted on by policy decisions and hence why it
is important for services to complete Carbon Impact Assessments to inform decision-making. 
• The council has continued to deliver climate action and has realised good outcomes that goes beyond emission reductions such as helping those in fuel
poverty and improving wider poverty outcomes as well as improving the physical wellbeing of residents. 
• Adapting to a changing climate is an essential consideration for the council and future action will be wider than flood prevention as other impacts, such as
severe heat, are becoming more frequent.
Balanced The report highlights some of the council’s climate activity and actions incorporated into the submission. These actions contribute to reducing North
Lanarkshire’s emissions as well as encouraging more sustainable practices within the area.
• The Energy Efficiency Standard for Social Housing (EESSH) was developed to help improve the energy efficiency of the social housing stock in
Scotland. Enhancing the energy efficiency of council homes contributes to reductions in domestic emissions and the carbon footprint of North
Lanarkshire. In 2024/25, the council’s pass rate for EESSH was 87%. Note, the EESSH is due to be replaced by the Social Housing Net Zero Standard
which will have a particular focus on clean heat.
• The council has a key role in the promotion of energy efficiency in the private housing sector through schemes such as Energy Company Obligation
(ECO) phase 4. The Statement of Intent sets out how the council aims to help the most vulnerable households and increase the uptake of energy
efficiency improvements for such households. Since 2013, 27,767 households have had 45,380 energy efficiency measures installed through ECO.
• Non-Domestic Energy Efficiency (NDEE) - a suite of energy conservation measures has been delivered across 26 sites and is expected to realise
savings and a carbon reduction of 774 tCO2e.  These measures include Building Energy Management Systems (BMS) upgrades, LED lighting, electric
boilers and boiler upgrades, recommissioning CHPs (combined heat and power), fridge and freezer optimisation, solar photovoltaics, air handling unit
optimisation, insulation, air conditioning optimisation, and voltage optimisation.  Page 26 of 238

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• New build homes - 48 new homes were completed in February 2025 at Brandon Street, Motherwell. All the homes are heated by a ground source heat
pump system and to a high level of energy efficiency, employing innovative use of both internal and external wall insulation as well as triple glazed
windows and roof-mounted photovoltaic panels. 
• Town and community hubs - Orbiston Community Hub located in Bellshill is the council’s first fully electric town and community hub, delivering a 90%
reduction in carbon emissions and a 60% reduction in energy consumption compared to the previous school buildings.
• Dumbreck and Garrell project - local volunteers were upskilled in practical conservation and habitat management, delivering works such as lapwing
scrapes, sand martin wall repairs, planting, and path improvements, alongside new benches to improve site accessibility for the wider community. 
The report also notes that the council has a duty to act in a way that supports the successful delivery of the Scottish National Adaptation Plan 2024-29.
Examples of adaptation action carried out within the council to date include:
• Water management - where activity has focused on reducing flood risk through maintenance planning for watercourses and structures, completion of
flood risk assessments, progress on the Kilsyth Flood Risk Reduction Scheme, delivery of local flood plan actions, and finalisation of actions from the
Clyde and Loch Lomond Local Flood-Risk Management Plan.  
• Tree management - which includes better use of data to manage storm-related tree impacts.
Report title Summary
Community safety hub
performance and
development 
February 2026
A report in 2020 provided a one off update on the performance of the Community Safety Hub following its merger into the council’s Housing
service.  In order to ensure ongoing performance monitoring this report has since been incorporated into the service’s programme of annual
service performance reports. 
Aligned Priority:  • Improve the health and wellbeing of our communities.
Ambition statement: 1. Ensure the highest standards of public protection.
Consistent A standard set of measures are in place which are recorded and monitored consistently in order to provide a live and complete picture of community safety
across North Lanarkshire.  These measures focus on incidents captured (criminal incidents, community safety incidents, and anti-social incidents),
environmental incidents, evidence requests (evidence disks and review requests), and missing persons.
Transparent A breakdown of all types of incidents is provided in various data tables throughout the report.  
In context The Plan for North Lanarkshire aims to make North Lanarkshire a better place to live, learn, work, invest, and visit, where homes and public spaces are
safe - and feel safe - for everyone. The work of the Community Safety Hub plays a key role in this respect by improving community safety through CCTV,
tackling anti-social behaviour, managing the homeless out-of-hours calls, and ensuring public protection.  The Community Safety Hub currently delivers: 
• Provision of 24 hour/365 days per year proactive monitoring of 1,376 public space CCTV cameras across North Lanarkshire.
• 3 autonomous re-deployable trailers capable of sustaining four to six weeks without a dedicated power supply.
• Evidence disks for Police Scotland, the Crown Office, and the Procurator Fiscal. 
• Call handling for the anti-social behaviour service 24/7, and the out-of-hours anti-social behaviour witnessing service. 
• Out-of-hours telephony service for emergency homelessness, and organisation of the out-of-hours homeless standby provision.
• Co-location of Police Scotland officers. 
• Winter preparedness support for roads and land maintenance services.
• An emergency response centre, including using CCTV images to support council resilience during major incidents, severe weather, and emergencies.
• Provision of rest centres in the event they are required during incidents and / or emergencies. 
• Gypsy traveller liaison remit, including management of unauthorised encampments.
Balanced Key highlights in the report include the following. Page 27 of 238

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• The programme to upgrade CCTV cameras in housing areas has now concluded, with 170 cameras replaced by high-definition units capable of
operating in low-light conditions. This has significantly improved monitoring, with clearer images supporting crime detection and prevention, anti-social
behaviour monitoring, fly-tipping and littering enforcement, and wider community safety.
• Deployments of re-deployable mobile CCTV trailers continued throughout the year to assess the need for permanent installations. At four locations,
costs were developed to consider permanent cameras: two permanent cameras have been installed at one site, installation is underway at a second
site, and planning is nearing completion at the remaining two. This demonstrates the value of trailer deployment in informing investment decisions.
• Work is progressing to deploy the Noise App for use by North Lanarkshire residents (the Noise App is an alternative to installation of sound monitoring
equipment). Following trial and procurement, planning is underway to support investigations into anti-social behaviour and noise complaints, and future
reports will provide updates on roll-out and uptake.
• To tackle anti-social behaviour across North Lanarkshire, the Break the Cycle programme continues as a pilot to Friday/Saturday Night Projects
attended by young people. The programme aims to educate on anti-social behaviour and its community impact, with ongoing engagement with
Education colleagues to support roll-out within secondary schools.
• To improve incident recording within the CCTV control room, the previous Access database has been replaced with a new Microsoft Lists database.
Introduced in April 2025, this has improved accuracy, flexibility, and access to information, allowing live updates to categories and ongoing development
of dashboards to support reporting and analysis.
• Work has also been undertaken to update CCTV information within the council’s GIS mapping system. CCTV locations are now available on the
internal council GIS Viewer via the CCTV layer on the Inside NL homepage. 
Key points in respect of performance in 2024/25 include the following: 
• Operating 1,376 cameras 24/7, CCTV monitoring continues to perform to a high standard. A total of 4,360 incidents were recorded, including criminal,
community safety, anti-social and environmental incidents. The service produced 570 evidence disks, processed 1,711 review requests, supported 508
apprehensions, cautions or fixed penalties, and assisted with 137 missing person cases, highlighting its significant role in community safety.
• CCTV incident data shows criminal incidents as the largest proportion of activity (42.6%), followed by community safety incidents (30.4%), with
anti-social behaviour (13.3%) and environmental incidents (13.7%) making up smaller but similar shares. This reflects a primary focus on crime
prevention alongside broad support for community safety and environmental issues.
• The anti-social behaviour call handling and out-of-hours service handled 16,400 calls during the year, resulting in 10,064 service requests, with strong
demand outside normal working hours. The out-of-hours witnessing service attended 992 call-outs and issued 115 warnings, demonstrating a key
preventative and enforcement role in tackling anti-social behaviour and supporting community safety.
• The out-of-hours anti-social behaviour services manages the deployment and assessment of sound monitoring equipment to investigate noise
complaints. In 2024/25, 45 referrals were received, with only three cases on the waiting list and one in progress at year end. No instances of excessive
noise were identified, indicating effective case management and low overall demand for formal noise enforcement.
• The out-of-hours homeless service saw high demand in 2024/25, handling 8,764 calls outside normal working hours, averaging 24 calls per day. Of
these, 2,164 calls (around 25%) were passed to standby officers to support homelessness assessments, emergency accommodation placements and
welfare checks, highlighting the service’s critical role in supporting vulnerable individuals out-of-hours.
Report title Summary
Community Payback
Order annual report
2024/25 
March 2026
Community Payback Orders (CPOs) were introduced in Scotland in 2011 as an alternative to custody. They are intended to ensure that
individuals convicted of offences make restitution to the community, while engaging in interventions that support rehabilitation, reduce
reoffending, and promote social inclusion. 
The report provides an overview of service delivery, performance, key issues and outcomes relating to Community Payback while also
providing information on the impact on individuals who are subject to CPOs and the tangible benefits provided to local communities.
Aligned Priority:  • Improve the health and wellbeing of our communities.
Ambition statement: 14.  Ensure the highest standards of public protection. Page 28 of 238

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Consistent • Section 227ZM of the Criminal (Procedure) Scotland Act 1995 places a duty on local authorities to prepare an annual report (outlining the operation of
CPOs) which requires to be submitted to both the Scottish Government and Community Justice Scotland.
• Community Justice Scotland collates these returns and summarise them in a report which is laid before Scottish Parliament. 
• To support the reporting requirement, Community Justice Scotland - in collaboration with Justice Social Work, the Scottish Government, and Social
Work Scotland - have developed a template of questions for local areas to complete.
Transparent This report outlines activity that includes:
• The scale and nature of Community Payback Orders imposed in North Lanarkshire.
• Examples of trauma-informed, person-centred practice.
• Case studies demonstrating impact on reducing reoffending and addressing underlying needs. 
• Delivery and benefits of unpaid work and other activity requirements. 
• Feedback from service users and community beneficiaries. 
• Partnership working with third sector, health, housing, and employability services. 
• Organisational improvements and ongoing pressures, including increasing Multi-Agency Public Protection Arrangements (MAPPA) demand. 
In doing this, the report highlights the positive contribution of Community Payback to communities across North Lanarkshire, alongside challenges
associated with rising complexity of need, mental health demand, poverty, and public protection responsibilities. 
The covering report provides an overview with more detail on specific activities included in the appendix to the report.
In context • The National Community Justice Strategy sets out four national aims for Community Justice, and 13 priority actions and provides context for the
delivery of justice social work services at local level. This is reflected in the North Lanarkshire Community Justice Partnership Board publication of their
North Lanarkshire Community Justice Outcome Improvement Plan for 2023-28. While the work described within the report is guided by the national
vision and policy as well a core statutory responsibilities in this area, the report reflects also that the role of justice services within North Lanarkshire is
aligned to the council’s Programme of Work and supports the wider ambitions of The Plan for North Lanarkshire’s vision and priorities.
• Prior to 1 October 2022, individuals subject to court-mandated unpaid work requirements were given up to 12 months to complete these hours,
following emergency provisions introduced by the Scottish Government under the Coronavirus (Scotland) Act 2020 to address pandemic-related
backlogs. From October 2022, the timescale reverted to the standard six-month completion period for new unpaid work requirements.
Balanced During 2024/25 North Lanarkshire justice services delivered person-centred, trauma-informed CPO interventions that prioritised community safety,
rehabilitation and reducing reoffending.  Key highlights include the following:
• 898 new supervision requirements were imposed, including 551 with unpaid work. 
• Strong outcomes were evidenced through intensive supervision, multi-agency working, and targeted interventions, including women’s services,
domestic abuse programmes, and mental health support. 
• Holistic support remained central, with partnership working across addiction, mental health, employability, and third-sector services, generating
£650,201 through income maximisation. 
• Unpaid work delivery remained strong, with almost 91,000 hours of activity completed, 554 bespoke items produced, and 364 refurbished bikes
donated, supporting communities, wellbeing, and employability. 
• Other activity interventions continued through third-sector partnerships, offering mentoring, counselling, training, and digital learning. 
• Service user and community feedback was overwhelmingly positive, highlighting consistent support, skill development, and high-quality unpaid work. 
• Conduct requirements remained the most commonly used CPO requirement after supervision and unpaid work. 
• MAPPA workload increased by 8.5%, reflecting growing complexity, risk, and challenges linked to staffing, recruitment, system pressures, and poverty. 
• Partnership working remained a key strength, supporting training, employment, wellbeing, and reintegration. 
• Future priorities include exploring the Caledonian Programme and strengthening support for individuals unsuitable for group interventions. 
Appendix 2 to the report includes a range of examples in relation to unpaid work which takes place in a number of different settings across local areas:
• Individual placements - working in charity shops, maintaining parks, community facilities, local food banks, and sheltered housing complexes.
• Squad placements - landscaping, maintaining gardens of community buildings, and being part of North Lanarkshire’s gritting plan. Page 29 of 238

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• The Restorative Justice Hub in Bellshill - containing a number of workshops that focus on utilising existing skills or creating new skills for service users
to make a practical contribution to North Lanarkshire. This includes woodwork, the bike workshop, home improvement workshop, laundry, and
preparing food parcels.
• Justice Hub in Motherwell - unpaid work at this hub focuses on practical skills that do not involve machinery, e.g. making crafts to be sold for the local
community and healthy cooking on a budget.
• Allotment Hub at the Clydeside - unpaid work at this hub provides outdoor placements in nature, which help individuals get involved in the growing of
fruit and vegetables that benefits local communities. A cooking group then follows the journey of seed to plate. The allotment also hosts a number of
rescued battery chickens offering an opportunity to learn animal care. 
Report title Summary
North Lanarkshire
Community Planning
Partnership: annual
oversight and outcomes
report 2024/25 
February 2026
• The Community Empowerment (Scotland) Act 2015 introduced a range of requirements on local authorities and community planning
partners to empower and strengthen community involvement in the design, planning, and delivery of local services and in enabling
community management or ownership of buildings and land. 
• The Act requires all public sector bodies to work together and engage with local communities on the issues that matter most to them with
the shared aim of improving outcomes in these priorities. There is a particular focus on tackling inequalities, poverty, and socio-economic
disadvantage within local communities. Community planning partners must also report publicly on progress, demonstrating where
outcomes have improved through joint planning, collaboration, and effective partnership working - both operationally and strategically. 
• This annual oversight and outcomes report highlights the positive impact of community planning in North Lanarkshire, showcasing
strengthened partnership working and improved outcomes aligned with The Plan for North Lanarkshire’s shared ambitions.
Aligned Priority:  Enhance participation, capacity, and empowerment across our communities.
Ambition statement: 20.  Improve the involvement of communities in the decisions, and development of services and supports, that affect them.
24.  Review and design services around people, communities, and shared resources.
Consistent All Community Planning Partnerships are required to annually review and report on their progress.
Transparent • The report provides assurance that the North Lanarkshire Community Planning Partnership has identified communities experiencing significantly poorer
outcomes compared to other areas within the local authority. For these communities, individual Locality Improvement Plans are developed and
published, outlining the specific issues to be addressed and the actions partners will take to improve outcomes. This report provides assurance that the
North Lanarkshire Community Planning Partnership is fulfilling these statutory obligations.
• A detailed summary, attached as an appendix to the report, highlights collaborative efforts between public sector partners, the voluntary sector, and
residents in planning, delivering, and resourcing services aimed at improving outcomes and tackling inequalities.
In context • The report advises that an integrated programme of reporting activity supports the North Lanarkshire Community Planning Partnership in monitoring
progress against priorities while fulfilling its statutory reporting obligations. This includes - consideration of the annual Outcomes report by the North
Lanarkshire Partnership Strategic Leadership Board and the Communities Committee, followed by publication on the council’s website.  It also includes
submission of a composite performance report to the North Lanarkshire Partnership Strategic Leadership Board every six months, detailing partnership
activity and progress on identified priorities and actions across the nine Local Outcome Improvement Plans (similar reports are considered by the
Communities Committee and published online), as well as preparation and publication of annual progress reports on delivery of individual Local
Outcome Improvement Plan actions for each area, considered by the relevant Community Board, and annual reporting by statutory partnerships and
other working groups on thematic plans (such as the Children’s Services Plan and Tackling Poverty Action Plan).
Balanced Key highlights - described more fully in the appendix accompanying the report - include the following: 
• Community empowerment - the Partnership successfully advanced the implementation of Local Outcomes Improvement Plans across all nine
Community Board areas, supported by strengthened Local Partnership Teams and enhanced improvement planning through Community Board Chairs. Page 30 of 238

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• Community wealth building - a comprehensive multi-agency Community Wealth Building Statement and Implementation Plan were developed,
embedding Community Wealth Building principles across procurement, employment, land use, finance, and inclusive ownership, while maintaining
active engagement with the national Community Wealth Building Practitioners Network. 
• Local Employability Partnership - collaborative efforts were intensified to expand initiatives targeting priority groups and to strengthen stakeholder
partnerships, ensuring the delivery of inclusive and sustainable employment pathways.
Report title Summary
Education performance
update 
March 2026
This report provides an update on North Lanarkshire’s educational performance for the 2024-25 session across key measures including
attainment within the broad general education (from early learning and childcare to end of S3) measured via Achievement of a Level (ACEL)
data, attendance and exclusion, teacher numbers, and the pupil teacher ratio.  The report includes local authority comparison data compiled
from national statistics published in December 2025 (https://www.gov.scot/collections/school-education-statistics/ ). 
The report also provides a summary of HMIe and Care Inspectorate inspection outcomes for 2024-25 and, where applicable, outlines impact,
progress to date, and planned next steps. 
Aligned Priority:  • Support all children and young people to realise their full potential.
Ambition statement: 6.  Raise attainment and skills for learning, life, and work to enhance opportunities and choices.
Consistent • Local authorities have a duty to improve standards in education, challenging and supporting educational establishments to ensure continuous
improvement.  North Lanarkshire’s quality improvement framework, updated in session 2022-23, empowers school leaders to secure continuous
improvement while providing assurance to stakeholders on the quality of education provided for learners.
Transparent • The report outlines the key strategies implemented in 2024-25 to further support the quality improvement framework and facilitate improvement across
North Lanarkshire’s educational establishments. The framework is managed by Education and Families Managers who, along with heads of
establishment, use ACEL data to support improvement discussions, attainment reviews, raise attainment, and close the poverty related attainment gap.
In context • The report sets the context in respect of attainment within the broad general education highlighting that the Curriculum for Excellence (CfE) is divided
into two phases - the broad general education (BGE) and the senior phase. 
• The BGE has five levels (Early, First, Second, Third, and Fourth). It begins in early learning and childcare and continues to the end of S3 (the third year
of secondary school). As illustrated in the table below, broadly speaking at the primary stages, progress through a level can take up to three years,
although the curriculum is designed to allow pupil progress to be accelerated to ensure breadth, depth, and challenge across and within levels. 
• ACEL data is the measure of attainment within the BGE.  It is based on Teacher Professional Judgement of a pupil’s attainment in literacy (listening and
talking, reading, and writing) and numeracy for all pupils at P1, P4, P7 and S3. This data is collected by the Scottish Government at the end of each
academic session and published, nationally, in December each year.
• Analysis of the published data informs the council’s future improvement planning and enables performance tracking against national averages and
comparable local authorities, particularly within the West Partnership and the family group of similar councils (which in this instance is based on the
level of deprivation - as per the Scottish Index of Multiple Deprivation (SIMD) - and comprises Dundee City, Glasgow City, East Ayrshire, Inverclyde,
North Ayrshire, North Lanarkshire, West Dunbartonshire, and the Western Isles. Page 31 of 238

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Balanced • The report comprises a number of detailed data tables that show North Lanarkshire’s performance over time as well as a comparison with the national
average and family group average of similar councils.  Data in these tables relates to the following:
-  P1, P4, P7 combined data for literacy and numeracy.  
- Performance within Curriculum for Excellence organisers - this shows attainment data across the literacy and numeracy organisers which provides
valuable insights to support the service’s strategic planning, including staff training and the allocation of support.  The data is shown as the
proportion of P1, P4, and P7 achieving expected Curriculum for Excellence levels.  The report also includes data for S3.
- Information on alignment with national patterns notes that North Lanarkshire’s attainment broadly mirrors national trends across the primary stages,
reflecting post-pandemic stabilisation. Recent slight dips in P1 and P4 literacy and P4 numeracy align with national slowing following earlier
recovery, while strengths in listening and talking, and stronger early numeracy, remain consistent with Scotland-wide patterns. 
- Combined data for literacy and numeracy, highlighting learners’ attainment at Curriculum for Excellence 3rd and 4th level.
- Cohort comparison in respect of ACEL data - comparing 2025 to 2022 data allows performance to be tracked in terms of the progress of the same
cohort of pupils who have moved from P1 to P4, P4 to P7, and P7 to S3 over the four year period.
- Progress towards closing the poverty related attainment gap over time. The latest national figures indicate that the poverty-related attainment gap
continued to narrow, with the primary literacy gap reducing to its lowest recorded level (19.4 percentage points) in 2024-25. The primary numeracy
gap also narrowed to its lowest recorded level (16.6), driven
by improved attainment among pupils in SIMD Quintile 1
(most deprived). In 2024-25, the S3 Curriculum for
Excellence 3rd level or better attainment statistics gap in
literacy reduced from 12.7 to 10.8 percentage points, and in
numeracy from 12.0 to 11.6. These are the lowest levels on
record, with greater improvement among pupils in the most
deprived areas.
- Senior phase pre appeal data, pupil numbers, teacher
numbers, the pupil teacher ratio, attendance, and
exclusions. 
- HMIe and Care Inspectorate inspection outcomes - from
August 2025 to January 2026, 14 North Lanarkshire schools
were involved in inspection activity (9 primary schools, 3
secondary, and 2 additional support needs).  A summary of
these outcomes, against each quality indicator, is shown in
the graph on the right - this is based on six inspection
reports published to date.
-  Ratings for four nursery inspections - these reported mainly satisfactory performance across key quality indicators, with one area rated as weak; all
gradings rated as weak require an action plan to be developed to ensure the establishment has the capacity to improve.
Report title Summary
Housing and corporate
maintenance and
investment services
contract - interim report 
February 2026
Operational, since July 2024, the housing and corporate maintenance and investment services contract has allowed the council to access a
range of maintenance, repair, and essential compliance services for its housing and corporate property portfolio. 
The report provides the latest results against the contract through a set of performance measures, as well as performance in relation to the
Scottish Housing Regulator and measuring the charter outcomes.  The report also includes an overview of the contractor’s performance
against social value targets, contract spend, any applicable service credits and strategic maturity monitoring for each contractual year.
It aims to ensure the Housing Committee has sufficient information to assess how contract performance supports the council in delivering
against The Plan for North Lanarkshire, as well as producing a high level of service delivery, legal compliance, and customer satisfaction.
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Aligned Priority:  • All priorities.
Ambition statement: • All ambition statements.
Consistent • To ensure regular updates on the contract are reported to committee, an annual report is scheduled to be presented to the Housing Committee in cycle
3 each year.  
Transparent • The report sets out a range of performance outputs in two detailed appendices showing data for housing and corporate measures.  
• In addition, Appendix 3 to the report provides an update on core projects awarded (and not awarded), and Appendix 4 reports on performance indicator
exclusions with reasons and remedial actions.
• The report notes that from contract commencement to 31st December 2025, a total of 33 additional contracts have successfully transitioned to the
contract with services being provided.
In context • The report provides information in respect of the transition of contracts in scope.  In addition, a summary of community benefits is reported to show the
benefits at a local area which was a key aspect of the procurement along with the contractor’s social value commitments (e.g. including the creation of
new jobs, craft and modern apprenticeship programmes, work placements, and employing locally).
Balanced • Social value highlights delivered during the latest reporting period of the contract include 36 craft trade apprenticeships, 17additional jobs created, 365
hours volunteering for St Andrews Hospice/projects, work ongoing re the North Lanarkshire Deaf Hub, St Aidan’s flexible learning space enhancing
inclusive education, a Christmas Appeal, support for homeless in North Lanarkshire, and the provision of winter warmer packs.  
• To accompany the detailed data appendices, the covering report shows the latest performance position between 1st July and 31st December 2025:
- Housing property - performance exceeded targets across all repair measures - 97.5% of immediate response jobs, 97.0% of normal response jobs,
and 98.2% of void repair orders were completed within timescale, all above the 95% target. Customer satisfaction was 95.1%, meeting the target
and exceeding the 2024/25 Scottish average of 87.0%, while the right first time measure is currently under review due to a potential calculation
anomaly, with corrective work underway.
- Corporate property - 97.96% of immediate response jobs and 99.02% of normal response jobs were completed within timescale, both exceeding the
95% target. Customer satisfaction is currently under review, with data presently collected at the post-inspection stage by technical officers.
- 52 stage one complaints were upheld or partially upheld. All complaints are analysed to identify recurring issues and drive service improvement
actions. There were no complaints relating to corporate property during this period.  
- 6 stage two complaints were upheld / particularly upheld.
• The report includes a section on core project contractor performance.  As well as traditional contract administration methods of contract and supplier
management, contractor performance is also monitored for the delivery of these contracts using balanced scorecards to capture performance indicator
scores against an agreed scoring framework and assign a RAG status.
Report title Summary
Roads and infrastructure
maintenance and
improvement services
contract - interim report 
February 2026
This report provides an interim performance update up to the first anniversary of the commencement of the roads and infrastructure
maintenance and improvement services contract (awarded to Hochtief PPP Solutions GmbH).  Since October 2024, this contract has been
used to deliver a range of maintenance, repairs, and investment services for the council’s roads and related infrastructure assets. 
The report provides the latest results against the contract through a set of performance measures, as well as information on the enhanced
contract management that has been developed around the enterprise contracts. It aims to ensure the Environment and Climate Change
Committee has sufficient information to assess how the contractor’s performance supports the council in delivering against The Plan for North
Lanarkshire, as well as producing a high level of service delivery, legal compliance, and customer satisfaction.
Aligned Priority:  • All priorities.
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Ambition statement: • All ambition statements.
Consistent • To ensure regular updates on the contract are reported to committee, an annual report is scheduled to be presented to the Environment and Climate
Change Committee in cycle 3 each year.  This will provide an overview of achievements against the performance indicators, as well as social value
outcomes, contract spend, any applicable service credits, and strategic maturity monitoring for each contractual year.
Transparent • The report sets out the contract’s governance arrangements which involves multiple layers of governance to provide essential scrutiny and oversight
and set out clear roles and responsibilities for operational ownership, contract management, and contract development activity.  This includes details of
the governance groups, their roles, meeting frequencies, and council membership.
• The report also sets out a range of performance outputs in Appendix 1, showing data against each performance indicator reference number.  
• The report includes performance narrative in the appendix in terms of reporting frequency and targets for each indicator in Appendix 2.  It also
summarises, in Appendix 3, the core projects undertaken or initiated during the reporting period (in addition to the annual improvement programmes
undertaken for roads and infrastructure assets such as carriageways, footways, street lighting, drainage, and signs).  
• Appendix 4 reports on performance indicator exclusions with reasons and remedial actions.
In context • As well as key social value highlights, the report includes information on the contractor’s Connecting Communities programme designed to deliver
community benefits including time, finance, and physical resources to support voluntary, community and social enterprises operating locally.
Balanced • Social value highlights delivered during the latest reporting period of the contract include 5 new apprenticeships created across the contract and supply
chain, £8.6m spent through local supply chain, 64% of workforce locally based, Gold Award status via the NL Employee Charter, Disability Confident
accreditation from the council, Age Friendly Employer Pledge signatory with Centre for Ageing Better, 11 site visits for school children or local residents,
12 women hired on the contract along with 3 armed forces veterans employees, 6 disabled employees, 99 residents employed directly or through the
supply chain, and 155 local direct employees hired or retained on the contract.
• Round one of Connecting Communities saw 9 organisations awarded over £17k and receive over 48 hours of staff resources to support local initiatives.
• The report and supporting appendix demonstrate compliance with statutory requirements for the day-to-day management and co-ordination of road
works. This includes performance on reactive maintenance (for roads, lighting, and other infrastructure assets, including potholes, drainage issues,
street lighting faults, bollards, signs, fences, and walls), incident response to emergencies, and winter maintenance.
• Compliance, safety, and value for money is also reported and - during the first year of the contract - the report states there were no formal interventions
from regulatory bodies, including the Health and Safety Executive, the office of the Scottish Roadworks Commissioner, or other recognised authorities.
Report title Summary
Revenues and benefits
update 
March 2026
This report provides a regular update on the payment performance for the administration and collection of all local taxation in North
Lanarkshire in the form of council tax and non-domestic rates.  In addition, the service is responsible for administering a number of benefits
for the residents of North Lanarkshire (including housing benefits, council tax reduction, Scottish Welfare Fund, Discretionary Housing
Payments, free school meals, clothing grants, and blue badges).   
It provides an update on performance as at 31st December 2025.
Aligned Priority:  • Improve North Lanarkshire's resource base.
Ambition statement: 21.  Continue to identify and access opportunities to leverage additional resources to support our ambitions.
Consistent • Produced quarterly, this report provides detailed in-year performance figures which can be compared to the same period in previous years.
Transparent • The year to date performance set out in the report covers a wide range of service activities as well as the amount of funding paid out to help
households in need in order to provide a safety net for local people on low incomes. Page 34 of 238

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In context • The report includes the latest context within which the service is operating; this is of particular relevance given the aforementioned administration of
grants and support payments required for low income households. The report also advises of any new national grants when they are introduced, or will
cease, and the qualifying conditions for receipt of such.
• Specific context is also provided in relation to Discretionary Housing Payments (DHP) and the Scottish Welfare Fund (SWF), along with grants
allocated to the council and paid through these supports.
Balanced The report provides a high-level summary of the highlights which shows that:
• As at 31st December 2025, 82.11% of council tax due for 2025/26 had been collected - a marginal increase from the same period last year (+0.37%).
• Non-domestic rates collection at 31st December 2025 had reached 64.65% of the total annual charge, lower than the previous year (81%). 
• The service continues to meet statutory timescales for administering benefits applications and changes. The latest performance shows this to be an
average of 15 days for new claims and 11 days for changes of circumstances, both lower than the DWP targets of 30 and 16 days respectively. 
In addition, for 2025/26 to date (as at December 2025):
• Blue badges - the council continues to administer the Blue Badge scheme in line with national guidance, assessing eligibility where automatic
entitlement does not apply. To date 8,743 applications have been processed, with 7,125 awarded - an 81.5% award rate, compared to 89.7% over the
same period last year. Although national guidance allows up to 12 weeks for decisions, the council is currently determining applications within 6 weeks. 
• Clothing grants and free school meal applications - 11,187 clothing grants were administered and paid out (compared to 11,711 at the same point last
year), and 10,211 free school meal applications were awarded (slightly higher than the 10,167 awarded during the same period last year).
• Discretionary Housing Payments - the council continues to manage housing support funding for tenants facing housing-related financial pressures. 
Total payments for support reached £6.115m, up from £5.956m at the same point in 2024/25, with a further £0.433m (75.94%) of funding for wider
housing and homelessness pressures paid or committed.
• Scottish Welfare Fund - the council continues to manage a £2.760m annual support fund for residents facing severe financial hardship, focusing on the
most vulnerable through high-priority assessment. To date, 17,010 applications were assessed, resulting in 12,763 awards, compared with 18,731
applications and 13,261 awards as at the same time last year.  To date, £2.158m (64%) of the available budget has been paid, with full spend expected
by year-end, while urgent cases (e.g. linked to homelessness) continue to be prioritised and support offered where applications are unsuccessful.
Report title Summary
Financial monitoring
report - council
summary (revenue) 
March 2026
This report updates on the overall financial position for the General Fund Account, Housing Revenue Account, and Adult Health and Social Care. 
(Note, the Council set its Revenue Budget and Council Tax for 2026/27 and provided a forecast Revenue Budget position for financial years
2026/27 and 2028/29 at the committee meeting in February 2026).
Aligned Priority:  • Improve North Lanarkshire’s resource base.
Ambition statement: 21. Continue to identify and access opportunities to leverage additional resources to support our ambitions.
25.  Ensure intelligent use of data and information to support fully evidence-based decision making and future planning.
Consistent • The report at each financial period end consolidates the budget monitoring position of all council services into one council summary, highlighting and
explaining major variances as per the council’s approved Financial Regulations.
• The March 2026 report presents the council’s revenue monitoring position for the financial year 2025/26 as at the end of period 10 (i.e. from 1st April
2025 to 2nd January 2026).
Transparent • The report highlights / explains major variances as per the council’s approved Financial Regulations which require services to remain within their
approved budgeting provision, and to report all significant deviations - defined as the higher of £100,000 or 5% - within budget monitoring reports.
• Following Committee agreement, this report also provides financial performance information in relation to the council’s Arm’s Length External
Organisations (ALEOs) (i.e. North Lanarkshire Properties, Fusion Assets Limited, and Routes to Work Limited).   Page 35 of 238

Page 36

In context • All activities undertaken by the council are subject to risk, and in acknowledging the council’s approved Risk Management Strategy, services manage
risks as part of their overall corporate and service planning processes. The March 2026 report states that the current economic climate and pay and
non-pay inflation, continuing at historically high levels, are some of the key factors that have the potential to impact on the council’s ability to provide
quality services within approved budget levels. 
Balanced • Where significant deviations are identified, services must provide explanatory commentary, outline the action required to rectify such deviations and,
where relevant, highlight any impact on other budget headings.  This information is captured by Finance and summarised in the overall council report. 
• A summary by division for the period ending 2nd January 2026 (P10) is included in an appendix to the report, as is a note of anticipated commitments
against earmarked and other reserves, and available general fund balances. 
Report title Summary
Financial monitoring
report - council
summary (capital) 
March 2026
This report provides an update on the 2025/26 resources and expenditure for the council's Strategic Capital Investment Programme. The report
also shows the 2025/26 projected outturn position and resultant variances. 
(Note, the Strategic Capital Investment Programme for 2024/25 to 2028/29 was approved by Policy and Strategy Committee in March 2024, with
an update reported on March 2025 and March 2026).
Aligned Priority:  • Improve North Lanarkshire’s resource base.
Ambition statement: 21. Continue to identify and access opportunities to leverage additional resources to support our ambitions.
25.  Ensure intelligent use of data and information to support fully evidence-based decision making and future planning.
Consistent • The report at each financial period end consolidates the capital monitoring position of all council services into one council summary. 
• The March 2026 report summarises the overall council Strategic Capital Investment Programme for 2025/26 in relation to resources and expenditure
and the 2025/26 projected outturn position and resultant variances. 
Transparent • The report notes that Strategic Capital Investment Programme 2024/25 to 2028/29 was approved at Policy and Strategy Committee in March 2024, with
updates provided in March 2025 and March 2026.  It represents the total Community Investment Programme incorporating the General Services Capital
Programme and HRA Capital Programmes. 
• The programme was developed in conjunction with services and led by the Strategic Capital Delivery Group (SCDG) using the principles established by
the council’s Capital Strategy. 
In context • The report states that the General Services Capital Programme (supported by General Services resources) demonstrates to communities that the place
making vision for towns remains a priority, and that the approved 5-year capital investment plan supports delivery of The Plan for North Lanarkshire.
• The programme includes investment in Town and Community Hubs, the City Deal programme, and external grant funding. In addition, the Housing
Revenue Account (HRA) resources support several HRA Capital Investment Programmes including the mainstream programme for investment in the
council’s existing estate and delivery of the ambition for additional supply through the new build and council buyback programmes.
Balanced • The report notes the current financial position in respect of the 2025/26 General Services Capital Programme and the Housing Revenue Account. This
reflects the approved budget and subsequent decisions made at the Strategic Capital Delivery Group (SCDG) in accordance with the SCDG terms of
reference, and where appropriate by the individual service committees, Finance and Resources Committee, or the Policy and Strategy Committee (as
per the Scheme of Administration).
• A breakdown of the overall 2025/26 budget by service programme and associated approved budget movements is included in an appendix to the report.
• In acknowledging the risks, the report recognises that the capital programme continues to face challenges in relation to the wider economic climate,
linked to availability of materials, contractors, and inflationary pressures. These are managed by services and Project Boards associated with specific
programme delivery and will continue to be monitored throughout the year in accordance with the SCDG Terms of Reference. Page 36 of 238

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Report title Summary
Financial monitoring -
savings 
March 2026
This report provides an update on the achievement of the three-year financial savings targets and progress.
Aligned Priority:  • Improve North Lanarkshire's resource base.
Ambition statement: 21.  Continue to identify and access opportunities to leverage additional resources to support our ambitions.
Consistent • This regular report ensures ongoing oversight by Elected Members of the Finance and Resources Committee in terms of implementing savings.
Transparent • The report provides an update on the achievement of the three-year financial savings total of £8.326m approved as part of the 2025/26 budget setting
process and advises it is projected that 89% will be delivered within the financial year, with replacement savings identified to fully address the shortfall.
In addition, it is currently anticipated that there will be no recurring savings gap arising from the 2025/26 to 2027/28 approved savings.
In context • Appendices to the report provide a review of budget savings by exception and a summary of service specific information on savings; the report states
that more detailed information in relation to savings is reported through the relevant service committee.
Balanced • Each service report, that supports the production of this composite report, sets out the context for savings in that services are required to monitor the
delivery of their target savings to ensure they remain within their approved budgets.  Periodic progress updates are required within individual service
revenue monitoring reports, identifying alternative solutions to any in-year shortfall envisaged. In addition, services are required to monitor whether the
original approved saving has been implemented and if not, provide an explanation along with alternative action required to ensure the recurring
financial saving will be achieved going forward. This information is captured by Finance and summarised in the overall council report. 
Key to RAG status
green Performance is on target and/or within acceptable thresholds
red Performance does not meet target and is outwith acceptable thresholds
blue Performance surpasses the target and exceeds expectations
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North Lanarkshire Council
Report
Audit & Scrutiny Panel 
Does this report require to be approved? ☐ Yes   ☒ No
Ref    FS/ASP/ALMay26 Date 14/05/26 
Audit and risk related items: Action log 
From  Francis Scott, Chief Officer (Audit and Risk)  
E-mail scottfr@northlan.gov.uk   
Francis Scott
Chief Officer (Audit and Risk)
Executive Summary
The purpose of this report is to allow elected members to track implementation of
outstanding requests and recommendations made by the Panel in respect of audit and risk-
related items. 
The attached log (at Appendix 1) records those audit and risk-related requests and
recommendations made by the Panel and when these were addressed and/or are
expected to be addressed.  Any actions that have previously been reported as complete
and noted by the Panel have been removed from the log.
Recommendations
The Panel is invited to note the report.
The Plan for North Lanarkshire
Priority  All priorities
Ambition statement All ambition statements
Programme of Work Statutory / corporate / service requirement
Item 4
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2
Appendix 1 Audit and Risk related items: Outstanding action log 
Date Requests or agreed action Status
March 2026 Can an update be provided to the next meeting of the Panel
to clarify how many volunteers require/already have PVG’s
and how these will be recorded internally and the
arrangements to be put in place to ensure records are and
remain up to date? 
Complete – the Chief Officer (Education – North) and the Chief Officer
(People Resources) have provided an update to the questions arising from
the Panel meeting in March and will attend Panel meeting in May to answer
any further questions.
Previous audit report on PVGs attached for information.
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3 
INTERNAL AUDIT REPORT 
PROTECTING VULNERABLE GROUPS 
Headlines
The Council has a statutory responsibility to ensure that individuals working with children and protected adults
are members of the Protecting Vulnerable Groups (PVG) scheme.  The PVG scheme is managed by Disclosure
Scotland and involves conducting criminal record checks on its members to ensure that individuals who are
unsuitable to work with children and protected adults cannot undertake regulated roles with these groups.  As
part of the changes arising from the introduction of the Disclosure (Scotland) Act 2020, from April 2025, it is
now a legal requirement for individuals undertaking regulated roles to be a member of the PVG scheme and
non-compliance with this requirement is now a criminal offence.  Further changes to the PVG scheme are
expected, including the requirement for PVG memberships to be renewed every five years.
The purpose of this audit was to assess the adequacy and effectiveness of the Council’s arrangements for
managing PVG scheme membership for its employees and volunteers undertaking regulated roles.  Based on
the results of our work, we are generally satisfied that there are appropriate processes in place for identifying
regulated roles, ensuring that new employees and volunteers undertaking regulated roles hold the appropriate
PVG membership and that records held to confirm PVG membership comply with data protection legislation. 
We have therefore categorised this audit as offering reasonable assurance.
However, the arrangements for recording whether a post is regulated and that individuals hold a valid PVG
membership are not always clear and consistent.  As a result, it was difficult to verify the completeness of
records in order to demonstrate that all employees in regulated roles hold the appropriate PVG membership. 
Additionally, the PVG Scheme and Disclosure Information Policy only refers to employees and does not
currently reflect the changes arising from the updated legislation, and there is a lack of clear processes for
school volunteers.  We have highlighted a number of areas for improvement, which are detailed in section 3 of
this report and include:
• An urgent need to improve the recording arrangements around PVG membership for employees and
volunteers.
• A need to review the Policy, processes and governance arrangements to fully reflect current legislation and
expected practice.
• The PVG arrangements and processes in place for school volunteers need to be clearly defined and
implemented. 
Internal Audit Opinion Reasonable assurance 
Priority of Recommendations
High Medium Low
1 2 1 
Organisational Impact Moderate 
Report status FINAL Audit ref 0900/2026/007 Date Issued 12/02/26
Audit Team Kimberley Hall and Lesley Armstrong 
Issued To Chief Officer (People Resources) and Chief Officers (Education) (Rec 3 only)
Copied To Chief Executive and Deputy Chief Executive 
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4
1.  Executive Summary 
Objectives
The audit sought to provide assurance on the following areas: 
• There are adequate written policies covering the requirements of the PVG scheme and these are aligned
with current legislation and Disclosure Scotland guidance.
• Roles and responsibilities for PVG compliance are clearly defined and communicated across Services.
• Appropriate arrangements are in place to correctly identify and document all roles undertaken by employees
and volunteers which involve regulated work and ensure that all individuals in such roles have a valid and
appropriate PVG.
• There are robust processes in place for verifying identity and eligibility of individuals and ensuring that PVG
checks are completed and approved before individuals commence regulated work.
• PVG information and records are stored securely, with retention and disposal of such records complying
with data protection legislation and council policy.
Work undertaken included confirming and reviewing the actions taken to ensure the Council’s continued
compliance with Disclosure requirements as a result of the changes to Disclosure legislation introduced from
April 2025 as well as checks on a sample of employees in regulated roles to confirm that they have the
appropriate PVG membership.
This engagement has been conducted in accordance with the Global Internal Audit Standards.  The Internal
Audit section reports formally on conformance with these standards to the Audit and Scrutiny Panel.
We would like to thank officers involved in this audit for their cooperation and assistance. 
2.  Findings and Recommendations 
Good practice identified
We noted the following areas of good practice during the audit: 
• The HR Business Partner team undertook a review of all posts within the Council to identify any additional
roles which require a PVG/Disclosure as a result of the changes to legislation.
• PVG checks are undertaken by the Workforce Resourcing Team for new employees in regulated roles as
part of the pre-employment checks, with valid membership in place prior to individuals commencing their
employment with the Council.
• An exercise was undertaken to process retrospective PVG applications for current employees categorised
in ‘regulated roles’ to ensure that appropriate staff have valid PVG membership.   
Key areas requiring management action (High Priority)
The following key areas requiring urgent management action have been identified:
• There is an urgent need to improve the recording arrangements around PVG membership for employees
and volunteers. 
Other areas for improvement (Medium Priority)
A number of other areas for improvement were also identified: 
• There is a need to review the Policy, processes and governance arrangements to fully reflect current
legislation and expected practice.
• The PVG arrangements and processes in place for school volunteers need to be clearly defined and
implemented.
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5
3. Action Plan Protecting Vulnerable Groups 0900/2026/007 
Ref Finding
1 There is an urgent need to improve the recording arrangements around PVG membership for employees and volunteers.
The new legislation, implemented from April 2025, resulted in a large scale, complex exercise for People Resources to identify newly regulated roles and ensure that the individuals in
those roles obtained PVG membership.  We note that significant work has been undertaken to update and improve the records held to enable easier identification of regulated roles and
confirmation that postholders hold the appropriate PVG membership.  A list of regulated roles has been produced, which details the type of PVG or disclosure check each role requires,
and the requirement for a PVG (child, adult or both) has been added to the relevant posts and positions within iTrent.  Completed and in-progress PVG and disclosure checks for
employees and other parties undertaking regulated work on behalf of the Council are recorded on tracker spreadsheets and an exercise is currently underway to improve the recording
of PVG membership and completed disclosure checks for employees by logging this information against their individual record on iTrent to ensure that a single, complete record is held.  
We obtained a report from iTrent which details all posts and positions within the Council, whether they require a PVG and if so, which type and whether the postholder holds the appropriate
PVG membership.  We undertook a review of this report including comparison against the list of regulated roles and the tracker spreadsheet for recording PVG and disclosure checks
and identified the following issues:
• The iTrent report contains 300 entries where the requirement for/type of PVG required for the post and position do not match.
• The iTrent report contains 1,500 entries where the post/position requires a PVG, but the employee’s iTrent record does not indicate that they have one. We were advised that this gap
was due to the transition of PVG information from the Service files to iTrent, and on completion of the exercise each iTrent record will have been updated.  Our testing on a targeted
sample of 25 of these entries confirmed that PVG membership was held and the details were recorded elsewhere.
• There are instances where the requirement for/type of PVG differs between the iTrent report and list of regulated roles. 
• The list of regulated roles contains a number of posts which no longer exist (e.g. Heads of Service) or the post has been renamed.
• There were inconsistences between the type of PVG required for some posts and the type of PVG held by the postholder.
Whilst we acknowledge that the exercise to record all PVG memberships on iTrent is still ongoing, the issues highlighted above make it difficult to verify the completeness of information
in order to demonstrate that all employees in regulated roles hold the appropriate PVG membership.  We therefore, consider that it is important that these records are updated fully and
accurately as soon as possible.  We were also advised that, once these arrangements are fully implemented, there are plans for ongoing review and update to provide assurance that all
individuals undertaking regulated roles hold a valid and appropriate PVG membership.
Implication Recommendation Priority Management response Implementation
Date
If the arrangements for
recording regulated roles,
the type of PVG
membership required and
individual employees with
PVG membership are not
robust, there is a risk that
an employee may be
employed in a regulated
role without PVG
membership which could
result in placing
vulnerable groups at risk
of harm, reputational
damage or financial risk.
The Chief Officer (People Resources) should:
(1) As a matter of urgency, continue to progress the project for
improving the recording of regulated roles against posts,
positions and individual employees on iTrent, with a view to
holding a complete record of all regulated roles and
associated PVG membership for employees.
(2) Produce and review regular exception reports from iTrent to
identify any anomalies with regulated roles, including those
referred to in the finding above and potential individuals who
do not hold a valid and appropriate PVG membership.  Action
to resolve any issues identified should be taken as
appropriate.
(3) Consider whether a centralised record confirming PVG
membership should be maintained for all parties undertaking
regulated work. 
High 
Agree
Gillian Quinn, Employee Service Centre Manager
The Service agrees that recent and planned future changes
to the scheme now require improvements to previous
arrangements for the recording of PVG’s. Work is well
underway in this regard and will be progressed as quickly as
possible.  Once complete, this will allow for regular exception
reporting to be established to provide ongoing assurance of
compliance with the scheme and the regulations.  Once work
is complete on recommendations 1 and 2, consideration will
be given to recommendation 3, although it is expected that
this will be complex as it involves non-employees. It will not
be possible to hold both non-employee PVG and employee
PVG records on iTrent and therefore other arrangements will
have to be considered. 
December 2026
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6
3. Action Plan Protecting Vulnerable Groups 0900/2026/007 
Ref Finding
2 There is a need to review the Policy, processes and governance arrangements to fully reflect current legislation and expected practice.
The Chief Officer (People Resources), as lead signatory for the Council, has overall responsibility for ensuring that disclosure information is handled properly, with responsibility
for processing PVG applications and ensuring that individuals in regulated roles have the appropriate PVG membership being delegated to relevant teams within Services.  However,
there is no individual officer with overall responsibility for ensuring that all parties undertaking work on behalf of the Council have been considered and that relevant Services have
appropriate arrangements in place for processing applications and recording PVG membership.  
Changes to the core legislation governing the PVG Scheme were implemented from April 2025, with further changes in relation to the movement from lifetime to five-year
membership expected in April 2026. Whilst the Council has a PVG Scheme and Disclosure Information Policy, this was last updated in 2016, and from our review of this Policy, we
noted that it only relates to employees and elected members and does not reflect the governance arrangements for other parties undertaking regulated work on behalf of the
Council (including volunteers, self-employed contractors or agency workers) or details of key contacts.  Additionally, the Policy does not yet reflect the recent legislative changes
or resulting amendments to the Council’s processes and governance arrangements arising from these changes. We recognise, however, that there are further expected changes
to the legislation and Disclosure Scotland guidance and note that People Resources acknowledged the need for the Policy to be updated within their report to CMT in August 2025
which outlined the changes to the PVG scheme.
Implication Recommendation Priority Management response Implementation
Date
If policies do not fully reflect
legislation or expected practice, the
Council may fail to comply with legal
and statutory requirements, which
could result in reputational damage
or financial penalties and there may
be inconsistencies in the way in
which officers carry out required
tasks.
The Chief Officer (People Resources) should:
(1) Undertake a review of the governance
arrangements for PVGs to establish clear roles
and responsibilities and processes, giving due
consideration to the need for an officer with
overall responsibility.
(2) Undertake a review of the Policy to ensure that
it fully reflects the changes arising from the
new legislation and any resultant amendments
to the Council’s processes and governance
arrangements, covers all parties undertaking
regulated work on behalf of the Council and
provides details of key
contacts/countersignatories for processing
applications.
Medium
Agree
Linda Cullen, Employment & Policy Manager
Changes to the scheme are still ongoing. For example, the
implementation of the five-year scheme, which will affect
the majority of Council staff who currently hold a PVG,
does not commence until April 2026. Once all final
changes to the scheme have been implemented, the policy
will be fully updated to reflect all requirements arising from
the new legislation. This will include clear governance
arrangements for the operation of the scheme, including
defined roles and responsibilities going forward. 
January 2027 
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7
3. Action Plan Protecting Vulnerable Groups 0900/2026/007 
Ref Finding
3 The PVG arrangements and processes in place for school volunteers need to be clearly defined and implemented.
From our audit work, we consider that the PVG processes in place for new employees are generally satisfactory, with PVG membership being confirmed by the Workforce
Resourcing Team as part of the pre-employment checks and prior to the employee commencing employment.  There are similar arrangements in place for elected members,
social work carers and ActiveNL volunteers, however, we identified a number of issues with the arrangements for school volunteers as follows:
• At the start of the audit, we had difficulty identifying the arrangements and responsible officer for PVGs for school volunteers.  We were advised that these were previously
undertaken by ActiveNL, however, this was transferred to Education prior to summer 2025 and no alternative responsible officer was identified at that time.  
• We issued a questionnaire to Headteachers to confirm their understanding of the requirement for school volunteers to have PVG membership and the process for requesting
a PVG application.  The outcome of this questionnaire highlighted that there is a lack of understanding around regulated roles and when a PVG is required, there is no clear
process in place for requesting a PVG and there is a lack of awareness of key contacts and countersignatories.
Interim arrangements have now been put in place to undertake retrospective checks, with the longer-term arrangements being progressed and an email has been issued to
Headteachers to provide examples of regulated roles and advise the actions required and nominated key contacts.
Implication Recommendation Priority Management response Implementation
Date
If the processes and arrangements
for PVG are not clear, officers may
not fully understand their
responsibilities, which could lead to
staff and volunteers undertaking
regulated roles not having the
appropriate PVG membership.
The Chief Officers (Education) should ensure
that the retrospective checks for school
volunteers identified as a result of the
communication issued to Headteachers are
progressed promptly and that, as a matter of
urgency, the longer-term arrangements are
fully established, implemented and
communicated to Headteachers.
Medium
Agree
James McParland / Barry Smedley, Chief Officers (Education)
A report will be submitted to the Service SMT meeting on 4
March 2026 which will include reference to the PVG requests
which are currently awaiting a response and will outline
previous practice, issues raised by headteachers, required
changes to practice to address the updated PVG regulations
and the further steps required to develop a formal Service
policy on this subject. The new Service policy will be
operational from the start of the 2026/27 academic term. 
August 2026 
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8
4. Action Plan Protecting Vulnerable Groups 0900/2026/007 
Ref Finding
4 A small number of other areas for improvement in respect of PVGs were identified.
Our testing identified a small number of other areas for improvement as follows:
• The Council has a legal duty to notify Disclosure Scotland of individuals ceasing to undertake regulated work as they are no longer a person of interest.  From our review of
a sample of leavers in regulated roles, we identified one employee where Disclosure Scotland had not been notified, as the People Operations Team were unaware that the
employee held a PVG membership as it was not recorded on the employee’s record on iTrent and they did not undertake any further enquiries.  The Workforce Resourcing
Manager confirmed that Disclosure Scotland has now been notified.
• Whilst employees in newly identified regulated roles were notified that they were now required to have PVG membership, there has been no formal communication from the
Council advising of the changes to the PVG scheme, particularly in relation to advising that it is now a criminal offence for both the organisation and individuals undertaking
regulated work if they do not hold a valid and appropriate PVG membership.
Implication Recommendation Priority Management response Implementation
Date
Delays in notifying Disclosure
Scotland that individuals are no
longer persons of interest could
result in a data protection breach.
Individuals may be unaware that it
is now a criminal offence, for both
individuals and organisation, to
undertake a regulated role without
a valid and appropriate PVG
membership.
The Chief Officer (People Resources) should:
(1) Ensure that, as part of the leavers process, the
People Operations Team establish whether
the position is a regulated role and if so,
promptly notify Disclosure Scotland that the
individual is no longer a person of interest.
(2) Issue a communication to all employees
advising of the legislative changes to the PVG
scheme, particularly the new criminal offence
for individuals. 
Low
Agree
Gillian Quinn, Employee Service Centre Manager
(1) As part of the transfer of PVG records to iTrent, this
work is already underway and all roles within iTrent
that require a PVG are now clearly identified.
Additionally, Disclosure Scotland has recently
provided direct self-service access to its new system,
which will allow the Employee Service Centre to
directly indicate when the Council is no longer an
interested party. This will make the leavers process
significantly more efficient going forward, and the new
facility is currently being tested. Previously, the
Council had to notify Disclosure Scotland in writing
when a staff member left, which was both time
consuming and slow.
(2) A communication will be drafted in March to issue to
all staff, including information on the legal requirement
to hold a PVG and to notify staff of the upcoming
transition from the lifetime scheme to the five-year
scheme. Information will also be included in the
regular People Resources newsletter, which already
goes to managers and staff on a regular basis.
Thereafter, periodic communications will be issued to
staff to remind them of their responsibilities. 
December 2026 
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North Lanarkshire Council
Report
Audit and Scrutiny Panel 
Does this report require to be approved? ☐ Yes   ☒ No
Ref    FS/ASP/PRMay26 Date 14/05/26 
Internal Audit: Progress Report 
From  Francis Scott, Chief Officer (Audit and Risk)  
E-mail scottfr@northlan.gov.uk   
Executive Summary
The purpose of this report is to provide an overview of Internal Audit activity and audit
reports issued since the last update to the Panel in March 2026, namely: 
• Roads and Infrastructure Maintenance and Improvement Services Contract
• Self-Directed Support
• Education Establishment Visits
• Procurement Compliance
• Contract Management
• Clyde Valley Waste Contract 
This report will also provide an update on performance management. 
Recommendations
The Panel is invited to: 
(a) note the content of the Internal Audit reports together with the associated management
responses.
(b) consider whether there are any issues raised by Internal Audit which the Panel
consider are sufficiently significant to require a further report from management to be
submitted to a future meeting of the Panel.
(c) request that Internal Audit report to future meetings of the Panel on the progress in
implementing agreed management actions categorised as ‘High’ or ‘Medium’ priority,
and
(d) otherwise note this report. 
The Plan for North Lanarkshire
Priority  All priorities
Ambition statement All ambition statements
Programme of Work Statutory / corporate / service requirement
Item 5
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1. Background 
1.1 The 2025-26 Internal Audit Plan was approved by the Audit and Scrutiny Panel in May
2025.  The Internal Audit Charter requires that Internal Audit Progress Reports are
presented to each meeting of the Panel, providing an update on the progress against
the Internal Audit Plan and any other Internal Audit activity.   
2. Report 
Audit reviews completed in the period 
2.1 The audit reports summarised below have been completed since the last meeting of
the Panel in May 2026.  Panel should note that two of these reports have been
assessed as providing a limited level of assurance on the control environment. 
Management have responded positively to all reports and satisfactory responses and
commitments to audit recommendations have been received. 
2.2 Appendix 1 provides detailed definitions of the priorities assigned to audit
recommendations, and the factors considered when determining the level of assurance
provided in the audit opinion. Full copies of these audit reports have been included in
the meeting paper in line with the approved reporting protocol. 
Roads and Infrastructure Maintenance and Improvement Services Contract 
Internal Audit Opinion Reasonable assurance
Recommendations High 0 Medium 1 Low 2 
2.3 This audit reviewed the Council’s governance and contract management arrangements
for the mobilisation and implementation of the Roads Contract.  We are generally
satisfied that these arrangements are effective, provide a robust framework for
monitoring and reviewing performance and are broadly consistent with good practice
expectations, relevant council policies, and contractual requirements.   
2.4 The main area for improvement identified relates to the need for robust Key
Performance Indicator (KPI) verification processes to confirm that data is complete,
accurate, aligned with contractual requirements and with sample checks undertaken to
confirm the accuracy of source information. 
Self-Directed Support 
Internal Audit Opinion Limited assurance
Recommendations High 1 Medium 3 Low 1 
2.5 The purpose of this audit was to assess the adequacy and effectiveness of the
Council’s arrangements for ensuring that SDS budgets are calculated fairly and
consistently in line with guidance and are monitored to ensure that they are being used
appropriately by service users.   
2.6 While we found strong financial oversight arrangements and no evidence of incorrect
budgets or misuse of SDS funds, significant weaknesses were identified in the
application of agreed procedures, the retention of key documentation and the
consistency of Direct Payment (DP) monitoring.  These weaknesses could lead to DP
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funds being misused without detection or not being used in line with assessed needs
and agreed outcomes, potentially affecting the support being received by individual
service users and exposing the Council to potential financial loss and reputational
damage. 
2.7 Further areas for improvement were noted relating to the consistent application of DP
management and monitoring procedures across all localities, updating the SDS Good
Practice Guide, strengthening procedures for retaining key documentation and
consistently applying agreed SDS procedures and establishing a formal training
programme.   
Education Establishment Visits 
Internal Audit Opinion Limited assurance
Recommendations High 1 Medium 1 Low 2 
2.7 The purpose of this audit was to provide assurance on compliance with Council policies
and procedures across a sample of schools in respect of financial activities, physical
security, health and safety and information security, and we are generally satisfied that
the procedures and processes in these areas are being followed. 
2.8 However, our review of a sample of schools highlighted significant levels of non-
compliance in relation to school funds procedures, and insufficient oversight and
involvement by Heads of Establishment and school Senior Management.  Although the
Service introduced a framework for monitoring the governance of school funds, this has
not yet been fully implemented due to resource constraints, therefore spot checks are
not being undertaken, and the quality of annual submissions are not being reviewed. 
Weaknesses in the control environment around school funds have been the subject of
repeated Internal Audit activity over the last few years, and these issues have been
referenced in the Chief Officer (Audit and Risk)’s annual report and discussed in detail
by the Audit and Scrutiny Panel. 
2.9 Further areas for improvement were noted relating to authorised signatories, insurance
limits for safes and procedures for inactive petty cash imprest accounts, all of which
have been reported as part of previous audits. 
Compliance with General Contract Standing Orders 
Internal Audit Opinion Reasonable assurance
Recommendations High 0 Medium 1 Low 1 
2.10 This audit aimed to provide assurance that procurement activities across the Council
are being conducted in accordance with the GCSOs, procurement regulations and
guidance.  We were satisfied that procurement and tendering activities are being
undertaken in compliance with these requirements and are generally supported by
appropriate and adequate documentation.  In addition, we found that robust and
appropriate processes are generally in place for inviting contractors, evaluating tenders
and awarding contracts. 
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2.11 The main area for improvement identified relates to the need to strengthen the
arrangements for verifying the authenticity of signatures on key procurement
documentation.   
Contract Management  
Internal Audit Opinion Reasonable assurance
Recommendations High 0 Medium 4 Low 0 
2.12 This audit reviewed the arrangements for reviewing Services’ compliance with the
Council’s Contract and Supplier Management (CSM) guidance.  Based on the results
of our work, we consider that the planned assurance activities set out within the
guidance are appropriate to support the monitoring of CSM activity.  These
arrangements are relatively new and, as a result, are not yet fully embedded. 
2.13 The arrangements do, however, require further development.  Areas for improvement
identified include refining the annual poll used to evidence CSM activity, strengthening
the CSM sample testing process, formal monitoring and reporting of mandatory CSM
training and ensuring that the outcomes of CSM assurance are reported to the senior
management in line with CSM guidance.  
Clyde Valley Waste Contract  
Internal Audit Opinion Substantial assurance
Recommendations High 0 Medium 0 Low 1 
2.14 The Clyde Valley Waste Contract (CVWC) is a partnership between North Lanarkshire
Council (Lead Authority), East Dunbartonshire Council, East Renfrewshire Council,
North Ayrshire Council and Renfrewshire Council for the provision of joint residual
waste treatment and disposal services.   
2.15 The purpose of this audit was to provide assurance on the adequacy and effectiveness
of the Council’s role as Lead Authority for the CVWC.  Based on the results of our work,
we consider that, to date, the CVWC Management Team have discharged their
obligations as expected, with appropriate arrangements in place for monitoring waste
processing information, processing payments and monitoring the contractor’s
performance. 
Performance Management 
2.16 In line with Internal Audit performance management framework, two performance
indicators are subject to quarterly reporting to the Panel.   
2.17 The first indicator is the implementation of agreed actions arising from Internal Audit
reports by the implementation date.  In the period to March 2026, 69% of agreed actions
have been implemented by the implementation date (the previous update for the period
to December 2025 had a 62% completion rate). 
2.18 The second performance indicator measures client satisfaction.  The results received in
the period continue to show positive feedback, with 100% of respondents agreeing that
Internal Audit added value by assisting in providing assurance, that findings were
clearly and accurately communicated and that audit staff were professional and
courteous, and 94% agreeing that the audit reports were relevant and
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constructive.  Appendix 2 provides a summary of the questions we ask audit clients at
the conclusion of each audit.   
3. Measures of success 
3.1  Internal Audit reports annually on its performance to the Panel and is also subject to
review annually by the Council’s appointed external auditors.   
4. Supporting documentation 
Appendix 1 Audit Grading Definitions
Appendix 2 Internal Audit Client Feedback Results 
Francis Scott 
Chief Officer (Audit and Risk) 
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5. Impacts 
5.1 Public Sector Equality Duty and Fairer Scotland Duty 
Does the report contain information that has an impact as a result of the Public
Sector Equality Duty and/or Fairer Scotland Duty? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact? 
If Yes, has an assessment been carried out and published on the council’s
website? https://www.northlanarkshire.gov.uk/your-community/equalities/equality-
and-fairer-scotland-duty-impact-assessments 
Yes ☐ No ☒
5.2 Financial impact 
Does the report contain any financial impacts? 
Yes ☐ No ☒ 
If Yes, have all relevant financial impacts been discussed and agreed with
Finance? 
Yes ☐ No ☐ 
If Yes, please provide a brief summary of the impact? 
5.3 HR policy impact 
Does the report contain any HR policy or procedure impacts? 
Yes ☐ No ☒ 
If Yes, have all relevant HR impacts been discussed and agreed with People
Resources? 
Yes ☐ No ☐ 
If Yes, please provide a brief summary of the impact? 
5.4 Legal impact 
Does the report contain any legal impacts (such as general legal matters, statutory
considerations (including employment law considerations), or new legislation)? 
Yes ☐ No ☒ 
If Yes, have all relevant legal impacts been discussed and agreed with Legal and
Democratic? 
Yes ☐ No ☐ 
If Yes, please provide a brief summary of the impact? 
5.5 Data protection impact 
Does the report / project / practice contain or involve the processing of personal
data?   
Yes ☐ No ☒ 
If Yes, is the processing of this personal data likely to result in a high risk to the
data subject? 
Yes ☐ No ☐ 
If Yes, has a Data Protection Impact Assessment (DPIA) been carried out and e-
mailed to dataprotection@northlan.gov.uk 
Yes ☐ No ☐
5.6 Technology / Digital impact 
Does the report contain information that has an impact on either technology, digital
transformation, service redesign / business change processes, data management,
or connectivity / broadband / Wi-Fi? 
Yes ☐ No ☒  
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If Yes, please provide a brief summary of the impact? 
Where the impact identifies a requirement for significant technology change, has
an assessment been carried out (or is scheduled to be carried out) by the
Enterprise Architecture Governance Group (EAGG)? 
Yes ☐ No ☐
5.7 Environmental / Carbon impact 
Does the report / project / practice contain information that has an impact on any
environmental or carbon matters? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact? 
5.8 Communications impact 
Does the report contain any information that has an impact on the council’s
communications activities? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact? 
5.9 Risk impact 
Is there a risk impact? 
Yes ☒ No ☐ 
If Yes, please provide a brief summary of the key risks and potential impacts,
highlighting where the risk(s) are assessed and recorded (e.g. Corporate or
Service or Project Risk Registers), and how they are managed? 
Effective responses by management to the weaknesses, control issues and/or areas
of improvement identified by Internal Audit will increase the likelihood of the Council
achieving its ambitions by improving control frameworks and more effectively
mitigating potential risks and threats to the achievement of planned outcomes. 
5.10 Armed Forces Covenant Duty 
Does the report require to take due regard of the Armed Forces Covenant Duty (i.e.
does it relate to healthcare, housing, or education services for in-Service or ex-
Service personnel, or their families, or widow(er)s)? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the provision which has been made to
ensure there has been appropriate consideration of the particular needs of the
Armed Forces community to make sure that they do not face disadvantage
compared to other citizens in the provision of public services. 
5.11 Children’s rights and wellbeing impact 
Does the report contain any information regarding any council activity, service
delivery, policy, or plan that has an impact on children and young people up to the
age of 18, or on a specific group of these? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact and the provision that has
been made to ensure there has been appropriate consideration of the relevant
Articles from the United Nations Convention on the Rights of the Child (UNCRC). 
If Yes, has a Children’s Rights and Wellbeing Impact Assessment (CRWIA) been
carried out? 
Yes ☐ No ☐ 
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Appendix 1 Audit Grading Definitions 
Audit reports are graded with an overall assurance opinion, and any issues and associated
recommendations are classified individually to denote their relative importance, in accordance with the
definitions in the tables below. 
Definition of audit assurance and recommendation categories
Assurance Confidence based on sufficient evidence that internal controls are in place, operating
effectively and objectives are being achieved. 
Assurance opinion
Substantial
Assurance
There are minimal or minor control weaknesses that present low risk to the control
environment.  The control environment has substantially operated as intended although
some minor errors have been detected. Very few or no improvements are needed.
Reasonable
Assurance
There are some control weaknesses that present a low to medium risk to the control
environment.  The control environment has mainly operated as intended although errors
have been detected.  Some improvements should be made.
Limited
Assurance
There are significant control weaknesses that present medium to high risk to the control
environment.  The control environment has not operated as intended.  Significant errors
have been detected.  Substantial improvements should be made.
No Assurance
There are fundamental control weaknesses that present an unacceptable level of risk
to the control environment.  The control environment has fundamentally broken down
and is open to significant error or abuse.  Immediate and major changes need to be
made. 
Organisational impact
Major The weaknesses identified during the review have left the Council open to significant
risk.  If the risk materialises it would have a major impact upon the organisation.
Moderate The weaknesses identified during the review have left the Council open to medium risk. 
If the risk materialises it would have a moderate impact upon the organisation.
Minor The weaknesses identified during the review have left the Council open to low risk.  If
the risk materialises it would have a minor impact upon the organisation. 
Recommendation priority
High
Significant control failure or weakness that, if not addressed, may lead to a major
financial, operational or reputational risk to the organisation and/or significantly impact
the successful delivery and achievement of the objectives of the area under review. 
Urgent/Immediate action is required.
Medium
Control failure or weakness that, if not addressed, may lead to a moderate financial,
operational or reputational risk to the organisation.  Weakness may be individually
significant, but it is unlikely to affect the successful delivery and achievement of the
overall objectives of the area under review.  The risk of error would, however, be
significantly reduced if corrective action were taken.  Prompt action is required
Low
Control failure or weakness that may lead to a minor financial, operational or reputational
risk to the organisation.  Weakness does not appear to significantly affect the ability to
meet objectives.  Minor issue raised to improve the efficiency and effectiveness of
controls. 
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Appendix 2 Internal Audit Client Feedback Results 
Responses received in this period from 17 clients related to assignments reported to the Panel
(note these responses primarily relate to audit assignments reported in the Internal Audit
Progress Reports presented to the November 2025 and March 2026). 
Question
Strongly
Agree or
Agree (%)
Neither
Agree nor
Disagree (%)
1. Internal Audit added value to my area by assisting in
providing assurance and/or identifying weaknesses
and/or improvements in relevant governance/business
process and internal controls
100% 0%
2. Internal Audit findings were accurate and clearly
communicated 100% 0%
3. The audit report made relevant, constructive and
practical recommendations to help improve operations 94% 6%
4. Internal Audit staff were professional and courteous
throughout the audit process
100% 0% 
Where management raise concerns over Internal Audit’s work, these matters are discussed
with relevant senior management to fully understand the nature of any concerns and, where it
is considered appropriate, to identify areas for improvement.  We also seek Services’ views on
what they liked or disliked about the audit process and comments received are used to inform
future action plans for improving the service provided by Internal Audit. 
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1   
INTERNAL AUDIT REPORT 
ROADS AND INFRASTRUCTURE MAINTENANCE AND IMPROVEMENT
SERVICES CONTRACT 
Headlines
The Enterprise Project supports delivery of The Plan for North Lanarkshire by creating an integrated approach
to repairs, maintenance and investment for the Council’s housing, corporate and roads and infrastructure
assets.  As part of this project, in March 2024, the Council awarded the Roads and Infrastructure Maintenance
and Improvement Services contract (the ‘Roads Contract’) to Hochtief Ltd.  The contract commenced in
October 2024 and enables the Council to access a range of maintenance, repair and investment services for
its roads and related infrastructure assets.
The purpose of this audit was to provide assurance on the adequacy and effectiveness of the Council’s contract
management arrangements for the mobilisation and implementation of the Roads Contract.  Based on the
results of our work, we have categorised the audit as offering reasonable assurance.  We are generally
satisfied that the governance and contract management arrangements for the Roads Contract are effective,
provide a robust framework for monitoring and reviewing performance and are broadly consistent with good
practice expectations, relevant council policies, and contractual requirements.  As the contract is still at an early
stage, we did not undertake a detailed review of individual performance indicator results. 
The audit did, however, identify some areas for improvement.  These are outlined in section 3 of this report and
include the need for robust Key Performance Indicator (KPI) verification processes to confirm that data is
complete, accurate, aligned with contractual requirements and supported by sample checks to confirm the
accuracy of source information. 
Internal Audit Opinion Reasonable assurance 
Priority of Recommendations
High Medium Low
0  1 2 
Organisational Impact Moderate 
Report status FINAL Audit ref 0900/2026/009 Date issued 21/04/2026
Audit Team Susan Whyte and Lesley Armstrong
Issued To Chief Officer (Community Operations), Chief Officer (Assets and Procurement),
Roads and Asset Services Manager and Contract Performance and Assurance
Manager
Copied To Chief Executive and Depute Chief Executive 
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2
1.  Executive Summary 
Objectives
The audit sought to provide independent assurance on the following areas:
• There are appropriate governance arrangements, with clearly defined roles and responsibilities, for
overseeing the new contract.
• Mobilisation is underpinned by well-structured arrangements including a clear and comprehensive plan
outlining timelines, critical milestones, dependencies, resource requirements and risk management
provisions.
• Contract management arrangements are consistent with contractual terms, council policies and include
appropriate mechanisms for monitoring quality and performance.
• Elected members and senior management receive regular updates on contract management and
performance.
This engagement has been conducted in accordance with the Global Internal Audit Standards.  The Internal
Audit section reports formally on conformance with these standards to the Audit and Scrutiny Panel.
We would like to thank officers involved in this audit for their cooperation and assistance. 
2.  Findings and Recommendations 
Good practice identified
We noted the following areas of good practice during the audit:
• A detailed governance structure has been established which includes five levels of governance groups
with clearly defined roles and responsibilities and which meet regularly to discuss and consider both
strategic and operational issues.  Documented Terms of Reference set out the required frequency,
membership and reporting arrangements for these governance meetings, which are further supported by
structured agendas, formal minutes and clear escalation routes.
• Comprehensive contract management arrangements have been developed including a wide range of
standardised toolkits and templates, such as a change control register, spend tracker, risk register, service
credit calculator and a social value tracker, to support consistent processes.  
• Independent oversight is provided by the Contract Performance and Assurance team, and all contract
documents are held in a central location accessible to relevant officers from both the Council and Hochtief.
• Detailed KPIs and Strategic Performance Indicators (SPIs) have been developed and are fully
documented, both within the contract and within a separately developed Performance Handbook, which
includes definition sheets outlining calculation methodology, data sources and responsibilities.
• Structured change control and risk management processes are in place, with a formal change control
procedure, a change control register, and a live contract risk register which is regularly reviewed through
monthly governance meetings and regular standalone risk sessions.
• Arrangements have been established for regular reporting of performance information to senior officers
through the Contract Service Management Group (Level 3) and Contract Delivery Management Group
(Level 4) governance meetings.  Although not yet fully established, twice-yearly reporting to the
Environment and Climate Change Committee has been agreed, and reports will cover issues including KPI
and SPI performance, social value outcomes, contract expenditure and service credits. 
Key areas requiring management action (High Priority)
No areas requiring urgent management action have been identified. 
Other areas for improvement (Medium Priority)
One other area for improvement was identified:
• There is a lack of independent verification of KPI calculations and underlying source data to confirm the
accuracy, consistency and reliability of reported performance information. 
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3
3. Action Plan Roads and Infrastructure Maintenance and Improvement Services Contract 0900/2026/009 
Ref Finding
1 There is a lack of independent verification of KPI calculations and underlying source data to confirm the accuracy, consistency, and
reliability of reported performance information.
We noted that detailed governance arrangements are in place for the Roads Contract, with contract performance being subject to regular review and discussion through frequent
governance meetings, where issues and performance matters, including KPI-related underperformance, are routinely identified, discussed, and addressed.  However, our review
identified issues in relation to the calculation, verification and reporting of performance indicator data, which is likely to affect assurance over the accuracy and reliability of reported
performance information, including:
• The Council does not currently undertake routine verification, sense-checking, or independent review of source data used to calculate KPI figures to identify, challenge and
correct anomalies or inaccurate entries.  Testing on a sample of two KPIs identified inconsistencies between Hochtief’s reported figures, the underlying source data, and the
performance results calculated by the Council.  Additionally, our review of records extracted from Confirm (the system used for issuing Work Orders and calculating a number
of the KPIs) identified data quality issues including jobs with the same start and completion date and time, jobs recorded as starting before being committed and target dates
that did not align with the priority rating and committed date.  As a result, it is unclear whether performance data currently reported to Committee and governance groups is
accurate, reflects the original source data, or complies with contractual requirements for KPI calculation.
• Two quarterly KPIs (KPI 3.6 – Percentage of routine maintenance work undertaken to date compared to the Contractors Annual Plan and KPI 8.20 – Customer satisfaction
with completed planned schemes achieved through post-scheme surveys over a 12-month rolling period) are not yet being calculated or reported due to lack of available data. 
We noted that this issue has been discussed at governance meetings, with additional sessions held to address gaps in the data and current reporting challenges arising due
to the early stage of the contract and that officers have been assigned to ensure the required data is in place for full reporting from year two of the contract.
We were advised that plans to strengthen the verification and assurance of performance information are being developed by the Contract Performance and Assurance and Roads
teams, in conjunction with Hochtief, however, these arrangements and improvements have not yet been fully established.
Implication Recommendation Priority Management response Implementation
Date
Performance information may be
inaccurate, undermining the
reliability of governance oversight,
Committee reporting and decisions
linked to KPI results.
Incomplete KPI reporting reduces
awareness of contractor
performance and may result in
non-compliance with contractual
monitoring requirements.
The Chief Officer (Community Operations) should ensure
that:
(1) A robust process for regular quality assurance and
verification is developed and implemented which
ensures that all KPI figures are accurate, supported by
source data, and calculated in accordance with contract
requirements.  This should include sample checks of
KPI source data to ensure that any inaccuracies or
errors are promptly identified, challenged and resolved.  
(2) The current work to review and refine KPI data is
finalised, ensuring all required data, including KPIs 3.6
and 8.20, is available, accurate, and fully reported to
senior officers and elected members.
Medium Agree
Scott Walker, Roads and Asset Services
Manager
Work to address this recommendation has
commenced. 
June 2026 
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4
3. Action Plan Roads and Infrastructure Maintenance and Improvement Services Contract 0900/2026/009 
Ref Finding
2 Any future mobilisation exercises should be supported by a complete and up-to-date audit trail, with all actions and risks either
recorded as closed or clearly transferred for ongoing monitoring.
We consider that, generally, appropriate governance arrangements were in place during the mobilisation of the Roads Contract.  These included regular meetings, a detailed
Mobilisation Plan, a risk register, and a Mobilisation Outputs Report that recorded all actions arising from the meetings, the officers responsible, and whether each action remained
open or had been closed/completed.  
From our review of these arrangements, however, we noted that the Mobilisation Outputs Report has not been fully updated and includes a number of mobilisation tasks which
appear to remain outstanding, and the associated mobilisation risk register does not clearly reflect any tasks which have been transferred to the contract risk register.  It is,
therefore, difficult to confirm which, if any, mobilisation issues or risks remain unresolved or to trace a complete audit trail linking outstanding items to current action logs or risk
registers.  We were advised that, following mobilisation, there were changes in key staff within both the Council and Hochtief and, as a result, it is likely that monitoring
documentation was not finalised and updated, rather than the actions themselves not being completed.  Current governance and risk management arrangements in place for the
contract appear robust, and therefore the likelihood of any material mobilisation issues remaining outstanding and unaddressed would generally appear to be low, however, we
consider that opportunities exist to strengthen the mobilisation activity for future contracts. 
Implication Recommendation Priority Management response Implementation
Date
Without a complete and up-to-date
mobilisation audit trail, there is a
risk that important actions or risks
may be overlooked or not fully
handed over to live contract
management, which could lead to
gaps in oversight, unresolved
issues, or reduced assurance over
contract readiness.
The Chief Officer (Community Operations) should
consider incorporating an action into the Lessons
Learned Register to strengthen the handover processes
between mobilisation and ‘business as usual’ contract
management for any future contracts, to ensure that
there is a clear audit trail demonstrating that all tasks,
risks, and responsibilities have either been fully
completed or formally transferred into ongoing contract
management.
Low Agree  
Ross Dunn, Contract Performance and Assurance
Manager 
June 2026 
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5
3. Action Plan Roads and Infrastructure Maintenance and Improvement Services Contract 0900/2026/009 
Ref Finding
3 There is a need to more fully align governance meetings with the agreed framework and record the reasons for any variations.
We consider that the governance arrangements for the Roads contract are generally robust and operating in accordance with contractual arrangements with appropriate
frequency, attendance, and inclusion of expected topics.  We noted, however, a small number of minor issues in relation to the operation of the Contract Delivery Management
Group (Level 4) and Contract Service Delivery Group (Level 5) governance meetings, as follows: 
• Level 5 meetings are not currently being chaired or routinely attended by the officers specified in the contract and several key agenda items (including KPI performance,
change management, and subcontractor monitoring) have not been clearly established as standing agenda items and are therefore not consistently discussed or formally
recorded in meeting minutes.
• One of the required agenda items (sub-contractor monitoring) has not yet been fully incorporated into the Level 4 meeting agendas and is therefore not being routinely
discussed at these meetings.  
The Roads and Asset Services Manager acknowledged these gaps during the audit and has committed to taking appropriate action.
Implication Recommendation Priority Management response Implementation
Date
Incomplete compliance with
governance meeting requirements
may reduce oversight and assurance
over contract performance.
The Chief Officer (Community Operations) should review
and update arrangements to support full compliance with
contractual requirements for Level 4 and Level 5
governance meetings.  This should include ensuring that:
• Officers identified in the contract routinely attend.
• Meetings are chaired in accordance with the contract
schedules.
• All required agenda items are included, discussed and
recorded.
• Any variations to the contract expectations are agreed
and document.
Low Agree
Scott Walker, Roads and Asset Services
Manager 
April 2026 
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6   
INTERNAL AUDIT REPORT 
SELF-DIRECTED SUPPORT 
Headlines
Self-directed support (SDS) empowers individuals to have control over their care and support services, allowing
them to make choices that best suit their needs and preferences.  The Social Care (Self-directed Support)
(Scotland) Act 2013 sets out the duties of relevant authorities to offer choice when arranging care and support. 
The Act is supported by four statutory principles – participation and dignity, involvement, informed choice, and
collaboration.  Service users can choose from four delivery options:
• They receive the money directly to pay and manage their own support (direct payments). 
• They choose the service provider, and the local authority manage the arrangements and payments. 
• The local authority selects, arranges and pays a service provider.
• A mixed approach with a combination of direct payments and council-arranged support.
The purpose of this audit was to assess the adequacy and effectiveness of the Council’s arrangements for
ensuring that SDS budgets are calculated fairly and consistently in line with guidance and are monitored to
ensure that they are being used appropriately by service users.
Based on the results of our work, we have categorised this audit as offering limited assurance.  While we
found strong financial oversight arrangements (including appropriate authorisation of new or amended budgets,
regular reconciliations and robust invoice checks) and no evidence of incorrect budgets or misuse of funds,
significant weaknesses were identified in the application of agreed procedures and the retention of key
documentation across all SDS options, as well as the consistency of monitoring Direct Payment (DP)
expenditure.  Although the Service is progressing the implementation of Mosaic, which is expected to
significantly improve the management of SDS arrangements, a number of areas for improvement are detailed
in the action plan at section 3 of this report.  These include ensuring DP management and monitoring
procedures are applied consistently across all localities to support early identification of issues and timely
corrective action, ensuring the SDS Good Practice Guide is routinely reviewed and updated, strengthening
procedures for retaining key documentation and consistently applying agreed SDS procedures and establishing
a formal training programme with periodic refresher training. 
Internal Audit Opinion Limited assurance 
Priority of Recommendations
High Medium Low
1 3 1 
Organisational Impact Moderate 
Report status FINAL Audit ref 0510/2026/001 Date issued 30/04/2026
Audit Team Susan Whyte and Lesley Armstrong
Issued To Chief Officer (Adult Social Work Services), Senior Manager Adult Social Work and
Business Support and Operations Manager
Copied To Chief Executive and Depute Chief Executive 
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7
1.  Executive Summary 
Objectives
The audit sought to provide assurance on the following areas:
• Appropriate policies, procedures and guidance are in place for SDS budgets and payments, and these have
been provided to staff and service users as appropriate.
• Service users are assessed on a consistent basis, in line with policies and guidance and SDS budgets are
accurately calculated, appropriately authorised and correctly paid.
• Effective monitoring arrangements are in place to ensure that SDS budgets are used properly, in
accordance with service users’ support plans and where they aren’t, appropriate and prompt remedial action
is taken. 
The work included selection of a sample of 15 service users across the six social work localities, supported by
discussions with key staff and a review of relevant documentation and case notes.  The sample included nine
individuals receiving DPs, as these arrangements are more complex, and six supported through other SDS
options.
This engagement has been conducted in accordance with the Global Internal Audit Standards.  The Internal
Audit section reports formally on conformance with these standards to the Audit and Scrutiny Panel.
We would like to thank officers involved in this audit for their cooperation and assistance. 
2.  Findings and Recommendations 
Good practice identified
We noted the following areas of good practice during the audit:
• An SDS Good Practice Guide is in place, which outlines the procedures to be followed and the
documentation that must be retained.  Supplementary guides and process documents have also been
developed to provide additional guidance on specific elements of the SDS framework.
• SDS leaflets have been developed to assist service users in understanding SDS arrangements and to
assist with decision making. 
• Standard forms, including Guided Self Assessments (GSAs) and scoring sheets, have been developed to
support consistent calculation of service user budgets.
• Locality Enablement Group (LEG) meetings are held fortnightly for all localities to review and approve new
or revised service user budgets, and details of discussions are formally recorded.  Senior Managers also
review budgets independently to ensure these reflect LEG discussions.
• Detailed Funding Schedule and DP Masterfile spreadsheets are maintained and updated every four weeks. 
Changes in payments for external providers or DP service users are only made following confirmation and
approval from the Senior Manager Adult Social Work.
• Payments to external providers are reconciled on a four-weekly basis, enabling timely identification and
resolution of any over- or underpayments.
• Robust processes are in place to review, verify and resolve any issues with invoices from external providers
before they are authorised for payment. 
Key areas requiring management action (High Priority)
One key area requiring urgent management action has been identified:
• There is an urgent need to strengthen arrangements for managing and monitoring direct payments made
to service users. 
Other areas for improvement (Medium Priority)
A number of other areas for improvement were also identified:
• The SDS Good Practice Guide should be regularly reviewed and updated to ensure it remains accurate,
comprehensive and aligned with current legislation and good practice.
• There is scope to improve the arrangements for retention of key documentation and consistent application
of agreed SDS practices.
• A formal training programme and arrangements for periodic refresher training should be established. Page 62 of 238

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8
3. Action Plan Self-Directed Support 0510/2026/001 
Ref Finding
1 There is an urgent need to strengthen arrangements for managing and monitoring direct payments made to service users.
Documented procedures are in place which outline the arrangements for regularly reviewing DP spending to confirm that funds are used appropriately and support continues to
meet service user needs.  We were advised that management recently reviewed compliance with these procedures, including whether DP Returns were being submitted regularly
and whether allocated workers were monitoring DP arrangements in line with required processes and timescales.  This review highlighted significant issues and associated risks
with the application of the expected procedures for managing and monitoring DP arrangements and as a result, the Service has recently introduced additional training and
implemented quarterly management review arrangements.  
Our review of a sample of service users in receipt of a DP supports Service management’s findings and confirms that significant issues remain in this area.  We noted the following
issues: 
• DP Returns are not being submitted consistently every four weeks as required, and arrangements for addressing non-submission of DP Returns, including issuing reminders
and taking follow-up action, are not being applied consistently across all localities.
• Where returns were provided, several were incomplete or contained errors, such as incorrect balances, and there was no evidence that these issues had been followed up
or resolved.
• Reviews of expenditure and supporting documentation, such as bank statements and receipts, are not being undertaken regularly in line with agreed procedures to enable
early identification of unusual or unapproved spending or to confirm that DP funds continue to be used in accordance with each service user’s Support Plan. 
• Documentation supporting the set-up or review of DP arrangements, including new DP forms, DP Review forms and Bank Mandate forms, was not always available, and in
some cases, did not reflect the most recent budget changes. 
• For one service user, the balance held in the DP bank account exceeded the agreed limit, however, there was no evidence that this had been reviewed or discussed with
the service user or their representative, no evidence of a justification for the additional funds being held and no action being taken to recover unused funds in the absence of
a valid reason for retaining these.
Although our testing identified a number of issues, there was no evidence of misuse of direct payment funds by our small sample of service users.
Implication Recommendation Priority
The absence of regular and consistent submission
of DP Returns, combined with limited review of
expenditure and supporting documentation,
increases the risk that DP funds may be misused
without detection or may not be used in line with
assessed needs and agreed outcomes, potentially
affecting the quality and appropriateness of support
being received by individual service users and
exposing the Council to potential financial loss and
reputational damage.
The Chief Officer (Adult Social Work Services) should, as a matter of urgency: 
(1) Continue to monitor and evaluate the arrangements to strengthen the management of DPs to ensure that reviews
of DP expenditure and supporting documentation are carried out consistently, regularly, and in line with agreed
procedures.  This should include the timely identification and robust follow-up of any errors, unusual or
unapproved transactions, or surplus balances until fully resolved.  Relevant supporting documentation and
evidence confirming completion of the reviews should also be consistently recorded and retained.
(2) Reinforce established arrangements across all localities for addressing non-submission of DP documentation,
including issuing reminders, escalating concerns and taking proportionate action where issues persist.
(3) Provide additional guidance or targeted support to service users or workers where recurring issues or non-
compliance with agreed procedures are identified.
High  
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9
3. Action Plan Self-Directed Support 0510/2026/001 
Management response Implementation
Date
Agree
Claire Leslie, Service Manager and Andrea Breen, Senior Manager Adults
(1) The Area Wide Social Work Service will continue its improvement activity from April 2025, with a focus on compliance with DP returns.  Quarterly, area-wide
reviews of DP returns have been undertaken, with early findings identifying ongoing issues with the quality and timeliness of DP returns across all areas.  In
response, additional awareness sessions were delivered to support staff in meeting required standards, however, subsequent audits have not demonstrated
sustained or significant improvement.
(2) In response to the ongoing issues, contractual arrangements have been strengthened in conjunction with Legal Services and Quality Assurance.  A revised
DP contract has been developed and issued to all DP holders which sets out clear and explicit obligations regarding the submission of DP returns, including
timescales and evidential requirements.  This process will be fully completed by June 2026.  Following completion of the contract rollout, DP returns will be
monitored over a 12-week period.  If there are no improvements, a further formal letter will be issued to all DP holders, reiterating mandatory requirements
and the potential consequences of non-compliance.
(3) Existing training materials will be reviewed and updated.  Targeted training and mentoring will also be provided to social workers undertaking assessment and
review, with a focus on identifying errors or omissions in DP returns, ensuring returns are consistent with approved support plans, and issues are addressed
at an early stage.  Clear guidance and practical support will also be provided to all relevant staff to strengthen practice and improve oversight of DP monitoring.  
Audit findings and improvement actions will be formally reported to the Senior Management Team.  Additionally, due to the ongoing risks identified, DP returns
will be added to the Social Work Risk Register to ensure appropriate corporate oversight and escalation where necessary. 
December 2026 
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10
4. Action Plan Self-Directed Support 0510/2026/001 
Ref Finding
2 The SDS Good Practice Guide should be regularly reviewed and updated to ensure it remains accurate, comprehensive and aligned with current
legislation and good practice.
The Health and Social Care North Lanarkshire (HSCNL) SDS Good Practice Guide, which was last updated in September 2021, and supplementary guidance (including process
maps, flowcharts and checklists) have been developed to provide guidance for staff to be followed when establishing or reviewing individual SDS arrangements.  Whilst there
have been no significant legislative changes since this date, key Scottish Government policy updates, such as the SDS Framework of Standards and the National SDS
Improvement Plan, have been introduced, therefore the current Good Practice Guide does not yet fully reflect these developments.  In addition, the Good Practice guidance
contains references to outdated processes, forms and enablement group arrangements which no longer align with current expectations.  We noted that work to review and align
the Good Practice Guide with updated policy requirements is underway and has been significantly progressed, however, this had not been fully completed at the time of the audit
and as a result, current guidance does not fully reflect the most up to date policy expectations or good practice requirements.  
There is also no formal, scheduled review cycle in place for the SDS Good Practice Guide or related documentation.  Updates are generally reactive and driven by significant
changes in legislation rather than through regular planned review.  We were advised that the Quality Assurance team, within HSCNL, is currently progressing a project to establish
a single, centralised location for procedural documentation which will include assigning document owners who will have responsibility for regularly reviewing and ensuring
procedures are up to date.  As this project has not yet been completed, arrangements for retaining and updating procedures and guidance are not always consistent, increasing
the risk that staff may be unable to access the most up-to-date information when required.
Implication Recommendation Priority Management response Implementation
Date
If procedures are not up-to-
date or readily accessible,
there is a risk that staff may
rely on outdated guidance or
fail to apply current legislative
and good-practice
requirements. This could lead
to non-compliance,
inconsistent practices being
applied across different
localities, adverse outcomes
for service users, and
potential reputational
damage to the Council.
The Chief Officer (Adult Social Work Services)
should ensure that: 
(1) The ongoing review of the SDS Good
Practice Guide is completed to ensure it
is aligned with current Scottish
Government policy, including the SDS
Framework of Standards and the National
SDS Improvement Plan.  Once updated,
the Guide should be shared with relevant
staff and be subject to regular review to
ensure ongoing alignment with legislative
and policy developments.
(2) The project to establish a central area for
all key procedural documentation
continues to be progressed and
completed, with clear ownership and
effective processes for ongoing review
and updating of all procedures.
Medium Agree
Lisa Barbour, Service Manager and Andrea Breen, Senior Manager
Adults
(1) The revised Good Practice Guide for SDS is in draft and
progressing through senior management sign-off.  The updated
guide reflects the new SDS operating model, revised processes,
and key developments, including the SDS Framework of
Standards and the SDS Improvement Plan.  Once approved, the
guide will be formally shared across the workforce to ensure
consistent understanding and application in practice.
To ensure ongoing accuracy and relevance, review timescales
have been incorporated into the document, with the area-wide
team undertaking annual or, where required, more frequent
reviews, for example in response to significant service changes
such as the full implementation of Mosaic.
(2) Management will continue to work in partnership with Quality
Assurance colleagues to ensure the Good Practice Guide is
stored centrally, version-controlled, and accessible to all staff. 
The documentation will also be made available to staff via MyNL,
providing a single point of access to current SDS guidance. 
September 2026  
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3. Action Plan Self-Directed Support 0510/2026/001 
Ref Finding
3 There is scope to improve the arrangements for retention of key documentation and consistent application of agreed SDS practices.
We recognise that the Service is in the process of implementing a new system, Mosaic, which is intended to significantly strengthen the management of SDS arrangements by
providing a single system for recording case information, storing key documentation and tracking, monitoring and approving budgets.  However, as Mosaic is not yet fully
developed or implemented, staff continue to rely on multiple interim systems and arrangements, including an Access database for recording minutes and decisions made at LEG
meetings, SWIS for case information, elements of Mosaic, and SharePoint folders for storing key service user documentation.
Testing on a sample of service users in receipt of SDS, to confirm whether they were assessed in line with policies and guidance, identified several issues in relation to the
availability of key documentation to support the assessment and annual review processes, which were exacerbated by the continued reliance on multiple interim systems whilst
Mosaic is under development.  The absence of such documentation made it difficult to verify decisions made including whether budgets accurately reflected assessments
undertaken or had been calculated consistently and in line with expected practice.  We noted the following:
• Key documentation, including Guided Self Assessments (GSAs), scoring sheets, Support Plans and evidence of annual Community Care Reviews was frequently missing
or out of date.  
• For one service user, there were several differences between responses recorded on the GSA and associated scoring sheet.
• For several service users, budget figures on scoring sheets did not align with those approved at LEG meetings. 
• Annual reviews were either not being completed or had no evidence confirming that they had been completed in line with expected timescales and although LEG minutes
record the dates that annual reviews were due, reviews were often deferred with no clearly recorded explanation or revised date.
Management have recently introduced independent, second officer checks to confirm whether DP Returns are being submitted in line with agreed timescales, however, there are
currently no equivalent arrangements to periodically review other key aspects of the SDS process, such as the completion and retention of required documentation or the
timeliness of annual reviews.
Implication Recommendation Priority
Failure to retain complete, accurate and up-to-date
documentation could undermine the Council’s ability to
demonstrate compliance with statutory requirements and
internal procedures, increasing the risk of decisions being based
on incomplete information and the potential for inconsistent or
unfair outcomes for individual service users, which could expose
the Council to potential challenge, financial loss and reputational
damage.
If regular reviews of service user circumstances are not
consistently completed, and routine second-officer checks are
not undertaken to identify when these reviews are missed,
material changes in circumstances may not be detected
promptly potentially leading to prolonged over- or
underpayments, or support that no longer meets service user’s
needs.
The Chief Officer (Adult Social Work Services) should:
(1) Ensure that the development of the Mosaic system is finalised and once implemented, is used as the
single system for managing SDS and retaining supporting documentation.
(2) Ensure that, in the interim, adequate and appropriate documentation is retained, to provide a clear
and complete audit trail of all decisions made.
(3) Ensure that periodic reviews of service users’ needs, circumstances and outcomes are completed
within required timeframes, with results fully recorded and retained.
(4) Remind relevant staff of the requirement to follow procedures and retain appropriate documentation
to support conclusions and decisions made.
(5) Consider undertaking periodic second officer quality checks on various aspects of the SDS process
to ensure that assessments have been undertaken in line with procedures and decisions made are
fully supported by appropriate documentation.
Medium  
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12
3. Action Plan Self-Directed Support 0510/2026/001 
Management response Implementation
Date
Agree
Claire Leslie, Service Manager, Lisa Barbour, Service Manager and Andrea Breen, Senior Manager Adults
(1) The development and configuration of the Mosaic system for SDS has been prioritised to ensure it is fully functional and capable of holding all relevant
assessments, decisions, reviews and supporting documentation.  Once implemented, Mosaic will be used as the single system of record for the management
of SDS cases.  This will provide a consistent, secure and auditable approach to SDS case management, reducing duplication and risk associated with parallel
systems.
(2) Until Mosaic is fully implemented, it will be reiterated area wide that adequate and appropriate documentation needs to be retained within the areas of Mosaic
which are currently available to provide a clear, complete and chronological audit trail of all SDS-related decisions, including rationale, authorisation and
supporting evidence.  This will provide assurance that decisions are transparent, defensible and compliant with audit requirements during the transition period. 
Interim operational guidance will be developed in the meantime. 
(3) Procedures will be reinforced to ensure that reviews of service users’ needs, circumstances and outcomes are completed within required timescales.  Review
outcomes, decisions and any changes to support arrangements will be fully recorded and retained.  This will provide assurance that SDS packages remain
responsive, proportionate and outcomes-focused, with risks identified and addressed promptly.  Practitioners and Team Managers will be overseen through
routine case supervision and performance monitoring.
(4) All assessing staff will be reminded of the requirement to follow SDS procedures and to retain appropriate documentation that clearly evidences assessments,
professional judgement, conclusions and decision-making.  To achieve this, all senior social work managers will be fully briefed.  This will be supported through
team briefings and management communications, supervision discussions and access to updated procedural guidance which will provide improved
consistency in practice and stronger evidential standards across SDS activity.
(5) Consideration will be given to introducing periodic second officer quality assurance checks on key aspects of the SDS process.  These checks will focus on
compliance with assessment and review procedures, quality and sufficiency of recorded evidence and alignment between assessed needs, outcomes and
approved decisions.  Findings from these checks will be used to inform learning, improvement activity and targeted support for practitioners or teams where
required.  This will provide increased confidence that SDS decisions are consistent, proportionate and fully supported by appropriate documentation.   
August 2027 
December 2026 
December 2026 
December 2026 
December 2026 
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3. Action Plan Self-Directed Support 0510/2026/001 
Ref Finding
4 A formal training programme and arrangements for periodic refresher training should be established.
Given the complex nature of SDS procedures and processes, it is important that staff responsible for undertaking SDS reviews and assessments are fully aware of, and
understand, their roles and responsibilities.  Our review identified some issues in relation to training as follows:
• While it is noted that the ethos of SDS is incorporated into mandatory Assessment and Care Planning and specific training is offered when requested by individual localities
or when specific performance issues are identified, there are currently no arrangements for consistently and systematically identifying the need for, and delivering, periodic
refresher training across the Service.
• While attendance at individual training sessions is recorded and locality management is responsible for identifying staff training needs and facilitating access to training where
required, there is currently no systematic process to identify training gaps or monitoring whether all relevant staff across the Service have undertaken appropriate training to
ensure that they are aware of their responsibilities to consistently and accurately follow required SDS procedures.   We noted that, for the most recent training held on DP
Return monitoring arrangements, approximately only half of relevant staff appear to have attended.
A comprehensive training programme which will reflect the Council’s approach to SDS is currently being prepared however is not yet finalised or fully implemented.  
Implication Recommendation Priority
Without appropriate training, staff responsible for
establishing and reviewing SDS arrangements
may not fully understand their roles and
responsibilities, increasing the risk of errors,
inconsistent decision-making, and potential non-
compliance with agreed internal procedures,
legislative requirements or good practice.
The Chief Officer (Adult Social Work Services) should:
(1) Finalise and fully implement the comprehensive training programme for SDS, which covers core processes, good
practice, expectations regarding the completion and retention of essential documents and DP monitoring
requirements.  The programme should include arrangements for monitoring attendance and periodic refresher
training to enable timely identification and resolution of any training gaps and ensure ongoing awareness of
responsibilities and continued compliance with legislation, internal procedures, and good practice. 
(2) Consider whether SDS training, covering the key requirements and expectations in relation to SDS procedures,
should be made mandatory for relevant staff. 
Medium 
Management response Implementation
Date
Agree - Claire Leslie, Service Manager, Lisa Barbour, Service Manager and Andrea Breen, Senior Manager Adults
(1) Assessment and Care Planning training has been co-produced to embed SDS principles and ensure staff understand SDS legislation, values, and good
practice. This establishes a consistent, compliant, and person-centred baseline across the service.  Building on this, enhanced SDS training will be rolled out
to address more complex areas, including General Support Assessment completion, support planning and review, and the set-up, monitoring, and governance
of DPs, including scrutiny of DP returns and alignment with approved support plans.  This enhanced SDS training will be delivered on a routine and ongoing
basis, ensuring staff have regular access to up-to-date information and guidance.  The approach is intended to mitigate risks relating to inaccuracies in practice,
non-compliance with documentation requirements, and weaknesses in DP monitoring and returns.  The training programme will support staff to understand
not only how to complete required documentation, but also why accurate completion and effective monitoring are essential to legislative compliance, financial
governance, and positive outcomes for individuals.  We will link with our training department to ensure this is fully tracked and feedback available.
(2) In recognition of the responsibilities associated with SDS delivery, this training will be mandatory for all social work staff who undertake roles involving SDS
assessments, support planning, and DP monitoring.  Attendance will be monitored, and completion reinforced through line management and supervision
arrangements.  This mandatory SDS training will ensure staff have the required skills and knowledge and support consistency of practice, and ongoing
compliance with legislation, procedures, and good practice. 
May 2027
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3. Action Plan Self-Directed Support 0510/2026/001 
Ref Finding
5 A small number of other minor issues in respect of SDS were also identified. 
During the course of our review, we identified the following minor issues where we consider there is scope for improvement:
• We noted that the SDS information on the Council website includes a link to outdated Scottish Government guidance issued during COVID.  Although the Children and
Families SDS page on the Council website contains a link to current legislation, a range of other relevant and up-to-date SDS resources are available across various external
websites but these are not specifically referenced or linked from the Council’s webpages.
• Although standard DP contracts generally appear to be robust and sufficiently detailed, the information currently provided to SUs does not fully or clearly state that SUs must
promptly inform HSCNL of relevant or significant changes in their circumstances including health, support needs, or hospital admissions that could affect their funding
entitlement.
Implication Recommendation Priority Management response Implementation
Date
Links to outdated SDS guidance and
legislation on the Council website may
increase the risk of service users or
carers misunderstanding their rights,
responsibilities, and available options.
If changes in circumstances are not
reported promptly, there is an
increased risk of service users
continuing to receive DP payments
which do not accurately reflect their
support needs, increasing the risk of
public funds being misused.
The Chief Officer (Adult Social Work Services)
should consider updating:
(1) The SDS information and links on the Council
website to ensure they are current and direct
service users to the most relevant and
up-to-date guidance.
(2) Information and guidance provided to service
users to clearly state their responsibility to
promptly notify HSCNL of any changes in
circumstances that may affect their DP
entitlement.
Low Agree
Lisa Barbour, Service Manager and Andrea Breen,
Senior Manager Adults
(1) Immediate action has been taken to remove the
outdated link to COVID-19 guidance from the
Council website.
As part of the SDS Improvement Plan, a robust
and systematic review of all website content
relating to SDS is being undertaken to ensure all
information, guidance and links are accurate,
current and fully aligned with the most up to date
legislation and statutory guidance.  This ongoing
work informed our self-evaluation, capturing
what information people value and how they
want to access it.
(2) As part of the development and implementation
of the new operating model, it was considered
essential that refreshed website content
consistently aligns with the new service
approach, including the use of appropriate
language, accessibility requirements and
supporting graphics.  This will ensure that
published information is clear, consistent and
reflects current practice.  Completing the review
will provide assurance that content is up to date,
compliant, and supportive of those accessing
SDS. 
August 2026
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15   
INTERNAL AUDIT REPORT 
EDUCATION ESTABLISHMENT VISITS 
Headlines
North Lanarkshire Council’s school estate comprises secondary, primary and additional support needs schools
as well as family learning centres. Whilst Heads of Establishment are the leaders of learning and teaching in
their school, they also have operational responsibilities to ensure that appropriate arrangements are in place
to manage the school’s financial activities including Establishment Funds (also known as school funds) and
that Council policies and procedures are properly implemented and followed by all staff and pupils as
appropriate.  
The purpose of this audit was to provide assurance on schools’ compliance with Council policies and
procedures in respect of financial activities, physical security, health and safety and information security.
Weaknesses in the control environment around school funds have been the subject of repeated Internal Audit
activity over the last few years, and these issues have been referenced in the Chief Officer (Audit and Risk)’s
annual report and discussed in detail by the Audit and Scrutiny Panel.
Based on the results of our work, we are generally satisfied that the procedures and processes in these areas
are being followed.  We have, however, categorised this audit as offering limited assurance.  While the Service
has prepared and implemented Educational Establishment Fund Financial Procedures, our review of a sample
of schools highlighted a diverse range of compliance with expected practice, with some schools having
significant levels of non-compliance with important aspects of the procedures and insufficient oversight and
involvement in the management of the school fund by Heads of Establishment and school Senior Management. 
Additionally, although the Service introduced a framework for monitoring the governance of school funds, we
noted that this has not yet been fully implemented due to resource constraints, therefore spot checks are not
being undertaken, and the quality of annual submissions are not being reviewed.  
We have highlighted a number of areas for improvement, which are detailed in section 3 of this report.  In
addition to the need for the Service to review, strengthen and fully implement the governance, oversight, and
operational arrangements relating to school funds, a number of other areas of concern, some of which have
been reported previously by Internal Audit, require to be addressed. 
Internal Audit Opinion Limited assurance 
Priority of Recommendations
High Medium Low
1  1 2 
Organisational Impact Moderate 
Report status FINAL Audit ref 0450/2026/001 Date issue 20/04/26
Audit Team Lynn McCrum and Lesley Armstrong
Issued To Chief Officers (Education – North and Education – South) and Senior Education and
Families Manager
Copied To Chief Executive and Depute Chief Executive  
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1.  Executive Summary 
Objectives
The audit sought to assess the adequacy and effectiveness of controls in place within schools and the extent
to which these comply with Council policies and procedures.  The audit involved unannounced visits to a sample
of five schools, to observe practices and undertake testing on financial activities (including Establishment
Funds), physical security, health and safety and information security.
This engagement has been conducted in accordance with the Global Internal Audit Standards.  The Internal
Audit section reports formally on conformance with these standards to the Audit and Scrutiny Panel.
We would like to thank officers involved in this audit for their cooperation and assistance. 
2.  Findings and Recommendations 
Good practice identified
We noted the following areas of good practice during the audit:
• The Council and Service have policies and procedures in place with regards to security, health and safety
and financial management which all Services and their employees must adhere to. 
• The Council has mandatory training modules in place in relation to information security and data protection,
and Heads of Establishment monitor completion of these by their staff.
• The Service has implemented Educational Establishment Fund Financial Procedures which provide
guidance and expected practice to Heads of Establishment in the administration and management of school
funds.  These procedures are supported by a short e-learning module to help them understand their role
and responsibilities with regards to Establishment Funds.
• The Education and Families Managers are required to complete a Link Visit Record during in-year
discussions with the Heads of Establishment. This includes specific questions designed to confirm that the
processes and guidance outlined in the Establishment Fund Financial Procedures are being implemented
and record detail of barriers faced and action being taken where there are areas of non-compliance.   
• Heads of Establishment are required to submit a Compliance Checklist, Annual Income and Expenditure
Statement, Independent Reviewer’s Report, year-end bank reconciliation and associated bank statement
to Education and Families HQ by 31st October each year. Reminders for submission of this documentation
are included within the Education and Families Newsletter.
• Establishment Funds is a standing agenda item at the Head Teachers’ Resources Briefings. 
• The annual submissions received from Heads of Establishment are monitored and an update provided to
the Education and Families Senior Management Team, highlighting the level of returns received and
providing detail on those education establishments with either a partial or nil return, including narrative on
why all required documentation has not been submitted.   
Key areas requiring management action (High Priority)
The following key area requiring urgent management action has been identified:
• There is an urgent need for the Service to fully implement the governance, oversight, and operational
arrangements relating to the management of school funds across educational establishments and
appropriately challenge where these arrangements are not operating effectively in practice. 
Other areas for improvement (Medium Priority)
One other area for improvement was also identified as detailed below:  
• A number of other areas of concern, which have been reported previously by Internal Audit, require to be
addressed. 
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5. Action Plan Education Establishment Visits  0450/2026/001 
Ref Finding
1 There is an urgent need for the Service to fully implement the governance, oversight, and operational arrangements relating to the
management of school funds across educational establishments and appropriately challenge where these arrangements are not
operating effectively in practice. 
Many educational establishments operate school funds in addition to their delegated school budget. These monies are generated by schools through donations, fundraising,
uniforms, payments for school trips and excursions, etc. Although school funds are not Council monies, the Council has a responsibility to ensure adequate stewardship of these
monies, therefore, the Establishment Fund Procedures, which provide guidance and expected practice to Heads of Establishment in the administration and management of school
funds, have been prepared and implemented.  As at November 2025, the school funds for all establishments totalled almost £2.5 million.
Despite the Service creating and implementing Establishment Fund procedures, delivering training and establishing a governance and oversight framework for monitoring
adherence to the procedures, our testing identified a number of instances where the issues previously identified have not yet been resolved or are not operating effectively in
practice.
Heads of Establishment are now required to submit documentation (compliance checklist, Annual Income and Expenditure Statement, Independent Reviewer’s Report, year-end
bank reconciliation and corresponding bank statement) annually to Education and Families HQ.  We were pleased to note that the annual submissions from the Heads of
Establishment are monitored and an update on the status of such returns is provided to the Education and Families Senior Management Team, with the most recent update
reporting that 76% had submitted fully completed returns for session 2024/25, with most other establishments providing part completed returns. However, as recognised by the
Service, whilst the information submitted gives a broad indication that establishments are adhering to their governance responsibilities, it does not provide assurance on the
quality or accuracy of the information received.  Furthermore, whilst the Service has previously acknowledged the need for spot checks and has secured approval for a small
resources team to undertake such checks, the planned programme of spot checks has not yet been delivered due to resource constraints as this team has not yet been established,
limiting the capacity for effective monitoring and support.
Our review of the annual returns submitted for 2024/25 also identified areas of non-compliance with expected practices and procedures, including financial information being
submitted for the incorrect period; balances per the bank reconciliation not agreeing to those recorded on the Annual Income and Expenditure Statement; and the Annual Income
and Expenditure Statement not being presented in prescribed format, not providing the necessary information (e.g. opening and closing balances) or containing errors or incorrect
entries.    
Additionally, during our unannounced visits to a sample of schools, we noted a diverse range of compliance with the procedures.  Of the five schools visited, two were generally
adhering to the procedures, however, the remaining three had differing levels of non-compliance, some of which were significant.  The issues identified over all five schools
included weaknesses in Establishment Committee arrangements and constitutions, income recording, cash handling, banking practices, record-keeping, reconciliations, and
overall management oversight. Errors, omissions, inconsistent practices, and inadequate separation of duties were also noted, including an Independent Reviewer at one school
visited being directly involved in the day-to-day financial processes that they were responsible for reviewing. Further details of the issues identified are contained at Appendix 2
with Head Teachers being notified under separate cover of those issues specific to their school.
Operational challenges were also identified and reported by Heads of Establishment regarding banking processes, particularly the declining acceptance of cheques and practical
difficulties in cashing cheques for school fund petty cash, which has contributed to some schools adopting workarounds that are inconsistent with expected procedures.  Current
guidance does not fully reflect these practical constraints, therefore we consider that it requires review to ensure that transactions are properly recorded and accounted for. 
These issues have highlighted a need for training and support for all staff responsible for managing school funds to ensure that they are fully aware of their responsibilities and
requirements.  
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4. Action Plan Education Establishment Visits 0450/2026/001 
Implication Recommendation Priority Management response Implementation
Date
Non-compliance with
financial management
procedures, inconsistent
financial practices and a
lack of management
oversight of school funds
could increase the risk of
errors, irregularities and
potential misappropriation
of school fund monies
going undetected.
If establishments are not
notified of areas of non-
compliance and no action
is taken to address these
issues, there is a high
probability that errors or
malpractices will be carried
forward and repeated in
future years which
increases the potential risk
of theft or misappropriation
of funds.
The Chief Officers (Education - North and Education -
South) should, as a matter of urgency:
(1) Ensure that the governance and monitoring
framework for school funds is fully implemented
including completion of spot checks and a robust
review of the quality, accuracy and completeness of
annual submissions with any areas identified for
improvement being monitored to ensure that they
have been understood and are being effectively
implemented.
(2) Reinforce to Heads of Establishment that they have
ultimate responsibility for ensuring that the school
fund is appropriately managed and the Establishment
Fund Procedures are fully adhered to.
(3) Review, update and communicate the Establishment
Fund Procedures and associated Compliance
Framework to reflect current operational challenges
(e.g. reduced acceptance of cheques and practical
issues with petty cash) and to provide clearer
guidance on expected processes, recording
requirements and separation of duties.
(4) Develop and deliver appropriate training and
awareness raising sessions on all relevant aspects of
the Establishment Fund Procedures for Heads of
Establishment and other staff members who are
involved in the operation, management and oversight
of the school fund.
(5) Ensure that appropriate action is taken to resolve the
issues identified within the individual schools visited
(as reported under separate cover).
High
Agree 
Barry Smedley, Chief Officer (Education North)
(1) A job description has been prepared for a new post
whose responsibilities will include establishment fund
spot checks and ongoing support, guidance and
training for school staff. This job description is
awaiting formal HR job evaluation prior to being
advertised.  The monitoring framework will fully
commence following appointment of the postholder,
with a summary report to SMT in February 2027.
(2) and (3) Further instruction will be provided to Heads of
Establishment at the next quarterly briefing session.
(4) Following appointment of the postholder per
recommendation 1 above, a further training
programme will be rolled out to school staff during
academic session 2026/27.
(5) A report will be submitted to the next Service
Management Team incorporating recommended
actions to be implemented in respect of individual
establishments identified by Internal Audit. 
May 2026 (approval
of post)
February 2027 (spot
checks and annual
review) 
June 2026 
August 2026 – June
2027 
May 2026 
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19
3. Action Plan Education Establishment Visits 0450/2026/001 
Ref Finding
2 A number of other areas of concern, which have been reported previously by Internal Audit, require to be addressed.
During the course of the audit, we identified the following other areas of concern:
• The authorised signatories for the school fund bank account for three schools visited did not match the records held by the Council’s Treasury Management section, with the
latter including staff who were no longer employed in the school/nursery.
• Staff within two of the schools visited were unaware of the insurance limits for their safe.  On one occasion, this was due to the school having moved premises and now
having a new safe. 
• The petty cash imprest accounts for two of the schools visited, had little, or no, activity in recent years. Records held show that the last imprest claims were September 2018
and April 2024 (albeit an imprest claim form for the latter had been completed but not yet submitted at the time of our visit).
These issues have been reported as part of previous audit reports and whilst appropriate action to address the findings raised was taken, the issues do not appear to have been
fully resolved.
Implication Recommendation Priority Management response Implementation
Date
Inefficiently managed bank
signatories may result in fraudulent
activity and delays in transactions
being processed. 
If schools are unaware of the safe
limits, then the balance of cash held
may be in excess of these limits and
would not be covered by the Council’s
insurance policies. 
Holding an unused imprest account
could lead to an increased risk of
fraudulent activity and/or
misappropriation of funds. 
The Chief Officers (Education - North and Education -
South) should: 
(1) Ensure that the signatories for all school funds are
reviewed on an annual basis to determine whether
these remain appropriate and agree with the list of
signatories held by the Treasury Management
section. Any changes should be promptly notified to
the Treasury Management section.
(2) Review and update the list of safes and other secure
facilities held at all educational establishments to
ensure that the information held is accurate and fully
reflective of any change in premises.  The updated
list should be passed to the Insurance section to
enable them to determine and advise on the level of
insurance cover required and provided for each
establishment and thereafter, Heads of
Establishment should be advised of their safe limits.  
(3) Advise Heads of Establishment that, where their petty
cash imprest account has remained inactive for an
extended period, they should liaise with the Treasury
Management section with a view to arranging for the
closure of the account. 
Medium
Agree 
Barry Smedley, Chief Officer (Education North)
(1) The list of authorised signatories was
previously reviewed and updated in
September 2025. Going forward, the
Service will ensure this exercise is formally
undertaken on an annual basis.
(2) A review of establishment safes and other
secure facilities was previously
undertaken and forwarded to the
Insurance Section in July 2025. Going
forward, the Service will ensure this
exercise is formally undertaken on an
annual basis.
(3) Further instruction on the management of
petty cash will be provided to Heads of
Establishment at the next quarterly briefing
session. 
September 2026 
September 2026 
June 2026 
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20
3. Action Plan Education Establishment Visits 0450/2026/001 
Ref Finding
3 Security issues identified during the audit visits require to be considered and addressed.
For the sample of school visits carried out, we identified, or were advised of, the following safety and security issues:
• Upon arrival at each of the schools, we were asked to identify ourselves and sign the visitor’s log, however, on three occasions we were not asked to provide identification
prior to being granted access to the school.
• The Heads of Establishment at three of the schools visited expressed various security concerns regarding access to/from the building, playground and/or car park areas. We
understand that these concerns have previously been raised with the Service, however, no action to rectify the concerns has been taken to date.
• The inventory of electronic devices (iPads, laptops, etc.) held for one school recorded items in bulk by device type and the department in which they were held.  As a result,
it did not capture key details, including serial numbers for individual devices or to whom each was allocated.
Implication Recommendation Priority Management response Implementation
Date
There may be significant safeguarding
and security risks as unauthorised
individuals could gain access to pupils
and staff.
Unless combination codes are
changed when a staff member leaves,
there is an increased security risk as
former employees could gain
unauthorised access to cash or
confidential documents.
If a register of devices does not record
who each device is allocated to, there
is a risk that such devices cannot be
accounted for resulting in an
increased likelihood of loss or theft.
The Chief Officers (Education - North and Education - South)
should:
(1) Liaise with the Heads of Establishment at each of the
three schools to discuss areas of concern and
determine what, if any, action can be taken to alleviate
these concerns and ensure the safety and security of
both pupils and staff.
(2) Remind staff of the importance of ensuring that: 
(a) Identification is requested and checked prior to
visitors being allowed access to the school.
(b) The inventory of electronic devices (iPads, laptops
etc.) clearly records each device individually,
including key details such as serial numbers and
the name of the individual to whom each device has
been allocated.
Low
Agree 
Barry Smedley, Chief Officer (Education
North)
(1) A meeting has been convened with the
three Heads of Establishment to gain a
full understanding of their concerns and
confirm what short and long actions can
be implemented.
(2) Further instruction will be provided to
Heads of Establishment at the next
quarterly briefing session. 
April 2026 
June 2026 
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21
3. Action Plan Education Establishment Visits 0450/2026/001 
Ref Finding
4 There is a need for action to resolve ongoing banking issues and the lack of clerical support within one school.
In one of the schools visited, the Head Teacher advised that the school’s only member of clerical staff (who is responsible for the day-to-day administration of the school fund
and petty cash imprest etc. and is the only person with access to the safe and its contents) has been absent since October 2025.  As neither the Head Teacher or Deputy Head
Teachers have access to the safe or financial records for the petty cash imprest or school fund, we were unable to carry out verification checks on the petty cash or school fund
during out visit.  Although the Head Teacher advised that activity within the school fund is minimal, with income being restricted to fundraising and donations, we consider that at
least two people should have access to the safe and financial records.
The Head Teacher also advised that the school had relocated and changed its name in August 2025 and that prior to the move, the school’s safe, and its contents (small cash
balance, cheque books and pay-in books) was stolen from the previous premises.  Whilst the cheque and pay-in books were cancelled, the school is experiencing difficulties in
updating the new name, address and signatories and is therefore not receiving bank statements and are having issues changing signatories and obtaining replacement cheque
and pay-in books.  
Implication Recommendation Priority Management response Implementation
Date
Without adequate clerical
support and access to financial
records, there is a risk that the
petty cash imprest and school
fund are not being properly
administered, recorded or
monitoring which could result in
increased errors, irregularities or
potential misappropriation going
undetected.
The absence of bank statements
and cheque and pay-in books
may result in establishments
being unable to bank cash
promptly, issue payments and
carry out timely bank
reconciliations all of which may
increase the potential risk of theft
or misappropriation of funds
remaining unidentified. 
The Chief Officer (Education - South) should liaise with the
Head Teacher at the school referred to in the finding:
(1) To ensure that appropriate access and business
continuity arrangements are put in place for the
management of the school fund and petty cash imprest,
with at least two members of staff having access to the
safe and financial records and interim clerical support
being put in place whilst the substantive postholder
remains absent.
(2) To signpost the school to the Treasury Management
section for assistance in resolving the outstanding
banking issues, including updating the bank with the new
school name, address and authorised signatories,
arranging for replacement cheque and pay-in books and
ensuring the school receives regular bank statements,
including copy bank statements for those not received.   
Low
Agree 
Barry Smedley, Chief Officer (Education North)
A meeting has been convened with the Head of
Establishment, HQ officers and Treasury Section
to gain a full understanding of the outstanding
actions required to restore the establishment
fund, petty cash and banking arrangements to
standard operational functionality as outlined in
recommendations 1 and 2. 
May 2026
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22 
INTERNAL AUDIT REPORT 
COMPLIANCE WITH GENERAL CONTRACT STANDING ORDERS 
Headlines
Section 81 of the Local Government (Scotland) Act 1973 requires councils to have contract standing orders to
regulate procurement activity and the award of contracts to ensure that procurement is controlled and managed
effectively and strives to achieve best value. The Council’s General Contract Standing Orders (GCSOs) set out
the procedures, controls and responsibilities that apply to the procurement of supplies, services and works
across the organisation.  The GCSOs are reviewed regularly to reflect legislative and organisational changes,
with the latest update being April 2025. For the period under review (January 2024 to August 2025), the Council
awarded 128 contracts totalling almost £4 billion (excluding VAT).
The purpose of this audit was to provide assurance that procurement activities across the Council are being
conducted in accordance with the GCSOs and procurement regulations and guidance.  Based on the results
of our work, we have categorised the audit as offering reasonable assurance. Overall, we were satisfied that
procurement and tendering activities are being undertaken in line with corporate requirements and are
generally supported by appropriate and adequate documentation, as required by the Council’s GCSOs and
related procurement guidance.  In addition, we found that robust and appropriate processes are generally in
place for inviting contractors, evaluating tenders and awarding contracts in accordance with established
procedures and corporate expectations.
We have identified a small number of areas for improvement, however, which are detailed at Section 3 of this
report and include the need to strengthen the arrangements for verifying the authenticity of signatures on key
procurement documentation. 
Internal Audit Opinion Reasonable assurance 
Priority of Recommendations
High Medium Low
0  1 1 
Organisational Impact Minor 
Report status FINAL Audit ref 0900/2026/008 Date issued 30/04/26
Audit Team Euan Campbell and Lesley Armstrong
Issued To Chief Officer (Assets and Procurement) and Procurement and Support Manager
Copied To Chief Executive and Depute Chief Executive 
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23
1.  Executive Summary 
Objectives
The objective of this audit was to provide assurance that procurement activities across the Council are
conducted in accordance with the GCSOs and procurement regulations and guidance. Specifically, the review
sought to confirm whether goods, services and works have been procured consistently, and whether appropriate
processes are being applied for inviting competition, evaluating tenders, and awarding contracts.
Audit work involved examining a sample of eight completed regulated procurements recorded in the Council’s
contract register between January 2024 and August 2025, covering a range of Services and contract values
and delivered through a range of procurement routes (e.g. open procedure, direct award and mini-competition).
Each procurement was assessed against checklists prepared using the requirements set out within the GCSOs.  
The audit did not consider the procurement with suppliers not included in the contract register as this was
covered during the recent audit on non-contract spend.  
This engagement has been conducted in accordance with the Global Internal Audit Standards.  The Internal
Audit section reports formally on conformance with these standards to the Audit and Scrutiny Panel.
We would like to thank officers involved in this audit for their cooperation and assistance. 
2.  Findings and Recommendations 
Good practice identified
We noted the following areas of good practice during the audit:
• The Council has GCSOs and associated procurement guidance in place which set out the internal rules for
the procurement of supplies, services and works.  
• The Council has a well-established, comprehensive procurement toolkit and supporting procedures, which
are maintained by the Corporate Procurement Team (CPT). The toolkit includes procurement journey maps,
workflows and standard documents and provides a consistent approach to regulated procurement activity.
• For procurements with an estimated value exceeding £50,000 for supplies and services and £500,000 for
works:
o Prior to commencing the procurement process, Services are required to notify the CPT to ensure that
the procurement is included on the contract register.
o A Contract Strategy is required to be approved by the Chief Officer (Assets and Procurement) prior to
the commencement of the procurement exercise.  The Contract Strategy sets out the key details of the
procurement, including budget and timetable, the proposed procurement approach and options
appraisal, anticipated benefits and evaluation methodology.
o Details of the contract award are required to be reported to committee, either in the form of a summary
report by the Chief Officer (Assets and Procurement) or a detailed report from the appropriate Chief
Officer (depending on the contract value).
• The e-mailbox containing submitted tenders are opened promptly after the tender deadline by two officers
within the CPT ensuring appropriate separation of duties from those evaluating the tender.
• The CPT has developed an Open Procedure Tender Evaluation Matrix that consolidates all evaluation
information and scores into a single document.  The matrix incorporates automated formulae to calculate
price and evaluation scores, ensuring accuracy of calculations and promoting a consistent evaluation
approach across contracts. 
Key areas requiring management action (High Priority)
No areas requiring urgent management attention have been identified. 
Other areas for improvement (Medium Priority)
One other area for improvement was also identified: 
• There is scope to strengthen the arrangements for verifying the authenticity of signatures on key
procurement documentation. 
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6. Action Plan Compliance with General Contract Standing Orders  0900/2026/008 
Ref Finding
1 There is scope to strengthen the arrangements for verifying the authenticity of signatures on key procurement documentation.
The Council has longstanding requirements for evidencing authorisation of key procurement and tender evaluation documentation.  Historically, this was achieved through printed
documents bearing ‘wet’ signatures, which were scanned and retained on the Council’s IT network to evidence responsibility, ownership and authenticity.  Since the transition to
MS Teams and the shift to hybrid working, obtaining physical signature has become increasingly challenging.
This issue has previously been reported by Internal Audit on more than one occasion and, as a result, the CPT issued several Procurement Advisory Notices outlining acceptable
approaches for confirming authorisation, including the use of supporting emails where wet signatures or appropriate e-signature solutions were not available. This issue was
further considered by a short life working group, chaired by the Depute Chief Executive and comprising several senior managers, resulting in the introduction of a corporate
signature protocol which was approved by CMT in March 2024.  This protocol consists of four tiers of authorisation including system-based authorisation (e.g. PECOS, iTrent),
‘wet’ signatures, auditable electronic signatures (e.g. Adobe Acrobat, Docusign or equivalent) and emails being retained to support typewritten or cut and paste signatures in
Word or Excel documents.
Our review of the procurement and tender documentation for the eight contracts selected, again identified a number of instances where documents were not appropriately signed
or the documentation held did not provide sufficient evidence of authenticity of signatures.  Several documents contained either typewritten or electronic signatures which could
easily be copied and pasted into other documentation, providing no assurance over the integrity of authorisation.  This indicates that the corporate signature protocol has not yet
embedded effectively in practice and that the underlying control weakness remains.
We also noted that some of the templates and working documents used within the procurement process, in particular, the recently introduced Open Tender Procedure Summary
Matrix, do not include a section for formal sign-off as confirmation of agreement of the final price/quality assessment and approval of the recommended contract award by the
evaluation team.  Whilst we consider that authorisation of all procurement documentation would be disproportionate, we consider there to be key decision points during the
procurement and tender evaluation process where formal documented approval is necessary to evidence governance and accountability.
Implication Recommendation Priority Management response Implementation
Date
Without clear evidence of
authorisation, the Council
may not be able to
demonstrate that
procurement decisions have
been properly reviewed and
agreed by appropriate
officers.
The Chief Officer (Assets and Procurement) should:
(1) Review the procurement process and supporting
templates to identify key stages where formal officer
sign-off is required to confirm the accuracy and
integrity of procurement outcomes and thereafter,
update the relevant templates. 
(2) Reinforce expectations to Services regarding the
expected methods and standards for completing,
authorising and retaining procurement
documentation, to ensure that all staff clearly
understand their responsibilities throughout the
procurement process.
Medium
Agree
Brian Ferguson, Procurement and Support Manager 
(1) The procurement process and supporting templates
will be reviewed, with regards to GCSOs, to identify
the necessary checkpoints requiring authorisation. 
CPWG will be asked to review and agree the
signatory checkpoints.
The relevant documents will then be updated to
include the most appropriate ‘tier of authorisation’ with
regards to the corporate signature protocol.
(2) A procurement advisory notice will be published to
reinforce the protocols for authorisation of specific
procurement documents, and the roles and
responsibilities. 
October 2026 
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25
3. Action Plan Compliance with General Contract Standing Orders  0900/2026/008 
Ref Finding
2 A number of areas of non-compliance with the Council’s GCSOs were identified.
Whilst our review of a sample of eight procurements confirmed that key procurement expectations as set out in the Council’s GCSOs and procurement procedures were generally
being complied with by Services, we identified a small number of instances of non-compliance, as follows:
• GCSO 4.4.2 states that a contract award procedure should not commence until the Contract Strategy is completed and approved by the appropriate Chief Officer (Assets
and Procurement), however, for one contract, the Procurement Engagement Document and Contract Strategy were not fully completed and signed as approved by the
appropriate Chief Officers. 
• For two contracts, there were no complete Conflict of Interest Declaration forms for some members of the evaluation team.
• One contract where the price of the winning tender exceeded the budgeted contract value recorded in the Contract Strategy and, whilst the budget was increased to a value
higher than the price of the winning tender, there was no evidence of approval being sought to increase the budget.
• Whilst procurement guidance states that the price evaluation should be undertaken by two evaluators, we identified one contract where the price evaluation was undertaken
by only one evaluator. 
• The contract award for one contract for supplies and services with a value of over £500,000 was not reported to the Service committee in line with GCSO 21.3.  The contract
was awarded in May 2025, and the next appropriate committee meeting was not until August 2025, however, despite a contract award report being prepared, it was not
presented to committee. 
• GCSO 21.13.1 states that the Chief Officer (Assets and Procurement) should publish a Contract Award Notice no later than 30 days after the issues of the letter of award of
the contract, however, for one contract the Contract Award Notice was not published until 81 days after the award letter was issued.
Implication Recommendation Priority Management response Implementation
Date
The absence of consistently
complete, properly
authorised and well-retained
procurement documentation
increases the risk of gaps in
the audit trail and may reduce
assurance that procurement
decisions are transparent,
compliant and supported by
appropriate oversight. 
The Chief Officer (Assets and Procurement) should
remind officers responsible for undertaking procurements
of the need to ensure that all aspects of the Council’s
GCSOs and procurement procedures are complied with,
specifically highlighting the issues outlined in the finding
above. 
Low
Agree
Brian Ferguson, Procurement and Support Manager 
The ‘procuring officer’ in each procurement process should
use a checklist to ensure procedural steps are followed,
including relevant authorisation; this would improve
compliance.
The Procurement and Support Manager will review the
findings from the audit sample and create a ‘lessons
learned’ procurement advisory to cover the issues
identified.  Thereafter, officers will be reminded of
expected practice and a template checklist to assist the
procuring officers will be established. 
January 2027 
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26 
INTERNAL AUDIT REPORT 
CONTRACT MANAGEMENT – QUALITY ASSURANCE ARRANGEMENTS 
Headlines
Effective contract management arrangements increase the likelihood that the Council’s contracts are
sustainable, achieve expected outcomes and represent best value.  An Internal Audit report issued in April
2023 identified the need for a formal mechanism for assessing whether effective Contract Supplier
Management (CSM) is being undertaken across the Council.  In response to this, the Corporate Procurement
Team (CPT) developed a CSM assurance framework, designed to monitor and evaluate CSM activities and
assess the level of compliance across Services with key corporate expectations.  Details of this framework,
together with the principles and requirements underpinning proportionate and effective CSM, are set out in the
Contract and Supplier Management Key Principles and Guidance document, developed by the CPT and
approved by the Corporate Procurement Working Group (CPWG) in February 2025.  
The purpose of this audit was to provide assurance on the adequacy and effectiveness of the arrangements
for reviewing Services’ compliance with the Council’s CSM guidance.  Based on the results of our work, we
consider that the planned assurance activities set out within the CSM assurance framework are appropriate to
support the review and monitoring of CSM activity.  We recognise that the arrangements are relatively new
and, at the time of the audit, only one full assurance cycle had been completed.  As a result, they are not yet
fully embedded.  
Although we have categorised this audit as providing reasonable assurance, we consider that the
arrangements require further development to fully demonstrate compliance with the General Contract Standing
Orders (GCSOs) and CSM guidance.  A number of areas for improvement are detailed in the action plan at
section 3 of this report and include refining the CSM assurance poll to enhance its effectiveness, strengthening
the CSM sample testing process to provide sufficient and reliable assurance of compliance with corporate
expectations, introducing formal monitoring and reporting of mandatory CSM training and ensuring that the
outcomes of CSM assurance activity are reported to the CPWG and Chief Officers in line with CSM guidance. 
Internal Audit Opinion Reasonable assurance 
Priority of Recommendations
High Medium Low
0  4 0 
Organisational Impact Moderate 
Report status FINAL Audit ref 0600/2026/002 Date issued 30/04/26
Audit Team Euan Campbell and Lesley Armstrong
Issued To Chief Officer (Asset and Procurement) and Procurement and Support Manager
Copied To Chief Executive and Depute Chief Executive 
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27
1.  Executive Summary 
Objectives
The audit sought to provide assurance on the following:
• A framework for monitoring compliance with the CSM principles and guidance has been established and
this covers all aspects of the guidance.
• The compliance framework is being operated in line with Council expectations.
• There is evidence that timely and appropriate management action has been taken where the compliance
framework highlights areas of potential concern.
• There is periodic reporting to key stakeholders on the outcome of the assurance work undertaken as part
of the compliance framework.
This engagement has been conducted in accordance with the Global Internal Audit Standards.  The Internal
Audit section reports formally on conformance with these standards to the Audit and Scrutiny Panel.
We would like to thank officers involved in this audit for their cooperation and assistance. 
2.  Findings and Recommendations 
Good practice identified
We noted the following areas of good practice during the audit:
• The Service has implemented a multi-layered assurance framework incorporating Chief Officer
declarations, Contract Manager attestations, sample-check activity and mandatory training, providing a
structured foundation for assessing and monitoring compliance with the CSM guidance.
• The CPT has produced Contract and Supplier Management Key Principles and Guidance which outlines
the process for contract management assurance, including standards and roles and responsibilities.
• Mandatory CSM e-learning has been introduced for all staff assigned Contract Management Authority,
establishing a consistent baseline of competency across services. 
Key areas requiring management action (High Priority)
No areas requiring urgent management attention have been identified. 
Other areas for improvement (Medium Priority)
A number of other areas for improvement were also identified: 
• There is scope to refine the CSM assurance poll to enhance its effectiveness.
• There is a need to strengthen the CSM sample checking process to provide sufficient and reliable
assurance of compliance with corporate expectations.
• There is a need to introduce formal monitoring and reporting of mandatory CSM training. 
• There is a need to ensure that the outcome of CSM assurance activity is reported to the CPWG and Chief
Officers in line with CSM guidance.
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7. Action Plan Contract Management Quality Assurance Arrangements  0600/2026/002 
Ref Finding
1 There is scope to refine the CSM assurance poll to enhance its effectiveness.
GCSO 23.1 requires Services to put appropriate arrangements in place for managing contracts. It states that the Contract Manager, who has a Contract Manager Assurance
(CMA) role, is responsible for monitoring and managing the contract and sets out the minimum aspects to be addressed (i.e. contractor’s performance, compliance with
specification and contract terms, cost, Best Value requirements, risk and compliance with any guidance issued by the Chief Officer (Assets and Procurement)).  The requirements
are supplemented by part 3 of the CSM guidance, which provides further detail on the expectations associated with each aspect. 
As part of the CSM Assurance Framework, the CPT committed to issuing an annual poll to officers assigned a CMA role to confirm the CSM activities which are undertaken and
can be evidenced.  This poll includes questions to confirm whether the respondent is the Contract Manager, which of the CSM requirements set out in GCSO 23.1 they can
evidence and whether they have completed the CSM e-learning modules.  The first poll was issued in November 2024 to officers identified as Contract Managers for contracts
awarded during 2023/24, with the process completed in January 2025.  At the time of our audit fieldwork, the equivalent exercise for contracts awarded during 2024/25 had not
been completed and was behind schedule.  
Our review of the poll for contracts awarded during 2023/24 identified the following issues:
• The aspects stated in GCSO 23.1, the CSM guidance and the poll are not fully aligned.  While they broadly cover similar areas, the CSM guidance includes an aspect relating
to delivery of community benefits and social value that is not reflected in the poll.  Conversely, the poll includes two additional aspects relating to the use of CSM guidance
(such as balanced scorecards) and any Service-specific CSM practices, which are not explicitly referenced in GCSO 23.1.
• Officers who undertake the CMA role for multiple contracts are required to complete the poll only once, with their responses applied to all contracts for which they are
responsible.  Given the diverse range of values, durations, risk profiles and terms and conditions of contracts, this approach does not provide assurance that the CSM
requirements are being consistently met for each individual contract.  We consider that separate responses should be obtained for each contract.
• Section E of the Contract Strategy sets out the intended CSM approach for the contract.  Given that this is a mandatory element of the procurement toolkit for all contracts
included on the Council’s contract register, the poll does not include any question to confirm whether the CSM approach set out in the Contract Strategy is being implemented
in practice.
• The guidance note issued alongside the poll stated that it applied to contracts and frameworks awarded during the 2023/24 financial year and provided a list of agreements
requiring Contract Manager response.  However, comparison of this list with the spreadsheet of collated responses identified inconsistencies, including contracts included in
the spreadsheet of collated responses that were not on the original list provided, and vice versa.  This indicates that not all relevant Contract Managers were identified or
responded to the poll.  
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5. Action Plan Contract Management Quality Assurance Arrangements 0600/2026/002 
Implication Recommendation Priority Management response Implementation
Date
If minimum CSM
requirements are not
clear and fully aligned
across documents, they
may not be applied
consistently or sufficiently
across contracts. 
The Council may be
unable to demonstrate
compliance with the
minimum CSM
requirements for all
contracts which could
result in increased non-
compliance which may go
undetected. 
The Chief Officer (Assets and Procurement) should:
(1) Review and update the GCSO 23.1 requirements,
CSM guidance and annual poll to ensure that all
documents are fully aligned and consistently reflect
the minimum CSM requirements. 
(2) Update the arrangements for completing the CSM
assurance poll to require completion on a contract
basis rather than a single response covering
multiple contracts.
(3) Consider updating the CSM assurance poll to
include specific questions confirming whether the
CSM approach set out in the Contract Strategy is
being implemented in practice and if not, to provide
an explanation and any mitigating actions.
(4) Review the arrangements for identifying in-scope
contracts and assigned Contract Manager prior to
issuing the annual poll and ensuring that all Contract
Managers complete the poll.  This should include
validation checks to ensure that all relevant
contracts and Contract Managers are included in the
exercise and have submitted a response.
Medium 
Agree
Brian Ferguson, Procurement and Support Manager
(1) A Practice Note per GCSO 2.8 will be put in place to cover
an interim update to the wording in GCSO 23.1 on
Contract Management which will align with the clearer
wording in the CSM Guidance document to improve
consistency. The actual GCSO 23.1 update will be
changed at next full GCSO review (likely within 2027 to
tie in with expected changes to national procurement
thresholds).
(2)  This will be updated in the CSM assurance poll to be
conducted at the end of 2026.
(3)  This will be updated in the CSM assurance poll to be
conducted at the end of 2026.
(4)  In advance of the next annual CSM Assurance Poll, CPT
will review the arrangements for identifying in-scope
contracts and ensuring that the most up to date
information on Contract Managers is held.  Where
responses are not received, these will be referred to the
relevant Chief Officer. 
September 2026
(Practice note)
December 2027
(GCSO update) 
December 2026 
December 2026 
September 2026 
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3. Action Plan Contract Management Quality Assurance Arrangements 0600/2026/002 
Ref Finding
2 There is a need to strengthen the CSM sample checking process to provide sufficient and reliable assurance of compliance with
corporate expectations.
As part of the CSM Assurance Framework, the CPT committed to undertaking annual checks on a sample of 5% (or minimum 10) of contracts included in the Procurement
Register to obtain assurance that appropriate CSM practices are in place, and can be evidenced, to satisfy GCSO 23.1.  Our review of the sample checking process undertaken
for the initial poll covering 2023/24 contracts identified a number of issues in the design and operation of the sample checking process.
The sample reviewed was not selected in line with the agreed methodology, as contracts were drawn from responses to the CSM assurance poll rather than the Procurement
Register and the sample size did not meet the minimum requirements, with only 8 contracts selected from a population of 69.  Additionally, the approach to sample selection was
not risk-based, with contracts selected randomly and no consideration given to Service area, contract characteristics, risk profile or responses provided in the poll. 
While sample checks were undertaken, these largely focused on confirming the existence of documentary evidence declared as available by the Contract Managers.  There was
limited challenge of the quality, completeness or appropriateness of the evidence provided, or of whether it was sufficient to demonstrate compliance with GCSO 23.1 and CSM
guidance.  There was also no evident follow-up of negative responses to the assurance poll.  Despite variations in the level and quality of supporting documentation, including
one instance where no supporting evidence was held, all contracts in the sample were assessed as fully compliant.
The recording of sample checks was also limited, with the summary spreadsheet used to record results stating only that contracts were fully compliant, with no clear commentary
or rationale supporting these conclusions.  Although a working version contained some additional detail, this was inconsistently applied and did not form part of the formal
assurance record.
Furthermore, there are no formal arrangements in place for providing feedback to Contract Managers on the outcome of sample checks, or for identifying, recording and monitoring
improvement actions arising from the review process.  While management advised that feedback is provided informally, no evidence was seen of issues being identified or raised,
or improvement actions being agreed or tracked.  As a result, the current process provides limited assurance and does not fully support the identification or remediation of
weaknesses in contract management practices.
Implication Recommendation Priority Management response Implementation
Date
Deficiencies in sampling
methodology, scrutiny of
evidence, documentation, and
feedback arrangements limit the
effectiveness of the assurance
process and reduce confidence
in reported compliance with
GCSO 23.1. As a result,
weaknesses in contract
management practices may not
be systematically identified,
escalated, or rectified. 
The Chief Officer (Assets and Procurement) should
review and update the CSM sample checking process,
taking cognisance of the issues highlighted in the finding
above, to ensure that it is consistently applied,
adequately documented and includes appropriate
challenge, feedback and follow-up and therefore,
provides sufficient and reliable assurance over
compliance with CSM requirements and corporate
expectations. 
Medium 
Agree 
Brian Ferguson, Procurement and Support Manager
The CSM sample checking process will be reviewed
for the next assurance exercise to address the findings
and improve the reliability of the assurance process.
Approval will be sought from CPWG prior to any
updates. 
March 2027  
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31
3. Action Plan Contract Management Quality Assurance Arrangements 0600/2026/002 
Ref Finding
3 There is a need to introduce formal monitoring and reporting of mandatory CSM training.
Section 5 of the CSM guidance states that, from 2025/26, officers assigned a CMA role will be required to complete mandatory e-learning modules via the NLC Procurement
Training and Development Programme on LearnNL, which cover the fundamental requirements of CSM outlined in GCSO 23.1, together with guidance, templates and examples
on how to undertake each of the required CSM activities.  The purpose of this training is to ensure that Contract Managers have a current knowledge and understanding of the
minimum standards for CSM.
From our review of the e-learning modules, we consider that the content is informative and would assist both experienced and inexperienced Contract Managers to understand
the expectations and requirements of the CMA role and how these should be applied to contracts.  However, we noted that, despite the modules being mandatory, there has
been limited uptake to date, with only 33% of officers identified as Contract Managers for the 2024/25 assurance exercise being recorded on LearnNL as having completed the
training.  Additionally, the CPT does not currently obtain or review reports from LearnNL to monitor completion rates or escalate non-compliance. 
Implication Recommendation Priority Management response Implementation
Date
Insufficient monitoring of
mandatory training and low
completion rates reduce
assurance that contract managers
have the necessary knowledge to
apply required standards,
increasing the risk of inconsistent
or non‑compliant contract
management practices.
The Chief Officer (Assets and Procurement) should
establish and implement a process for routinely
monitoring completion of CSM training and following-up
non-completion, including targeted reminders and
escalation as appropriate, to ensure that all relevant
officers complete the training within a defined
timeframe.  Consideration should be given to reporting
the uptake of training to CPWG to enable them to
identify and inform Contract Managers within their
Service of the requirement to undertake the training.
Medium 
Agree
Brian Ferguson, Procurement and Support Manager
The Procurement and Support Manager will liaise with
colleagues in Talent and Organisational Development
to establish:
(a) A process for providing the names of officers
nominated as Contract Managers or with a CMA
role for one or more live contracts who are
required to undertake the training.
(b) Setting the eLearning as a mandatory training
requirement for those specified officers with a
CMA role.
(c) Associated reporting. 
December 2026 
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32
3. Action Plan  Contract Management Quality Assurance Arrangements 0600/2026/002 
Ref Finding
4 There is a need to ensure that the outcome of CSM assurance activity is reported to the CPWG and Chief Officers in line with CSM
guidance.
Section 5 of the CSM guidance states that it is necessary to have organisational assurance that there is effective CSM in place for all live contracts and outlines the methods that
the Council has established for obtaining assurance for CSM.  This includes the CPT administering a poll for completion by officers assigned a CMA role and sample checks on
contracts awarded and logged in the Procurement Register to ensure that CSM practice, which satisfies the requirements of GCSO 23.1, can be evidenced.  The CSM guidance
also states that the results of both exercises will be repeated annually for all live contracts and that the results will be reported to the CPWG and Chief Officers.  The initial poll
and spot checks were undertaken for contracts awarded during 2023/24, with the exercise being completed in February 2025, however, we noted that no reporting of the outcome
of these exercises has been undertaken to date.
Implication Recommendation Priority Management response Implementation
Date
Inadequate reporting of CSM
activity limits organisational
oversight, resulting in reduced
assurance that contract
management performance,
compliance with GCSOs and CSM
guidance and capability gaps are
being effectively identified,
monitored and addressed.
The Chief Officer (Assets and Procurement) should
ensure that, in line with the requirements of CSM
guidance, a report should be submitted to the CPWG
and Chief Officers on an annual basis, confirming the
CSM assurance activity undertaken during the year,
together with the outcome, areas of non-compliance
and any required improvement actions.
Medium 
Agree
Brian Ferguson, Procurement and Support Manager
The CPWG will be updated annually on the results of
the CSM Assurance Poll and sample checks.  Chief
Officers will also be updated on the outcome of the
sample checks in their Service. 
September 2026 
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33   
INTERNAL AUDIT REPORT 
CLYDE VALLEY WASTE CONTRACT 
Headlines
The Clyde Valley Waste Contract (CVWC) is a partnership between North Lanarkshire Council (Lead
Authority), East Dunbartonshire Council, East Renfrewshire Council, North Ayrshire Council and Renfrewshire
Council for the provision of joint residual waste treatment and disposal services.  As Lead Authority, the Council
was responsible for the procurement and award of the contract. Viridor was appointed in 2019, and the
contractual arrangements are documented within the Project Agreement and supporting Authority Requirement
between North Lanarkshire Council and Viridor Clyde Valley Limited.  
The terms of the partnership are contained in the Inter Authority Agreement (IAA), which sets out the scope of
the agreement and the key obligations of the Lead Authority and the Partner Authorities.  A Variation Agreement
relating to the IAA was approved by the Partner Authorities in April 2026 to reflect variations and updates to
these arrangements, and to ensure ongoing compliance with legislation requirements and to support the
effective management of the contract.
The purpose of this audit was to provide assurance on the adequacy and effectiveness of the Council’s role as
Lead Authority for the CVWC.  Based on the results of our work, we consider that, to date, the CVWC
Management Team (CMT) have discharged their obligations as expected, with appropriate arrangements in
place for monitoring waste processing information, processing payments and monitoring the contractor’s
performance.  We have therefore, categorised the audit as offering substantial assurance.  
In accordance with the IAA, the Lead Authority’s Internal Audit service is required to provide a biennial
statement of assurance regarding the project’s governance arrangements relating to payment processes and
project monitoring, to confirm compliance with the IAA, the Project Agreement and other contract documents. 
Based on the results of this audit, we intend to return this assurance statement to the Joint Steering Board
(JSB) stating that there are no significant matters that require to be raised which could have a material impact
on the delivery of the Project Agreement or compliance with the IAA for 2025-26. 
Internal Audit Opinion Substantial assurance 
Priority of Recommendations
High Medium Low
0  0 1 
Organisational Impact Minor 
Report status FINAL Audit ref 0800/2026/002 Date Issued 30/04/26
Audit Team Elaine MacDonald, Lynn McCrum and Lesley Armstrong
Issued To Depute Chief Executive, Chief Officer (Community Operations) and Contract Manager
(Clyde Valley)
Copied To Chief Executive 
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34
1.  Executive Summary 
Objectives
This audit sought to provide assurance on the extent to which the Council, as Lead Authority, has managed
payment processes and project monitoring arrangements in line with key expectations laid out in the IAA.  It
involved reviewing invoices from the Contractor and recharge invoices for the Partner Authorities to ensure that
the revised budget proportions have been accurately calculated and comply with the requirements set out in
the IAA, and completion of a checklist to ensure that contract performance is being monitored on a regular basis
and in line with key expectations.
This engagement has been conducted in accordance with the Global Internal Audit Standards.  The Internal
Audit section reports formally on conformance with these standards to the Audit and Scrutiny Panel.
We would like to thank officers involved in this audit for their cooperation and assistance. 
2.  Findings and Recommendations 
Good practice identified
We noted the following areas of good practice during the audit:
• The Council has appointed a Project Director, Contract Manager and supporting Contract Management
Team, with responsibility for monitoring and reviewing performance and delivery.
• A JSB has been formed to oversee the operation and performance of the Project, and Terms of Reference
outline the role and remit for the Board.  The Board meets regularly and is attended by key contract
representatives, including a nominated party from each Partner Authority.  The Contract Manager submits
a service report to each Board meeting.
• Contractor monthly unitary charge invoices are supported by the contractor’s monthly performance report,
spreadsheets of monthly waste activity and weighbridge turnaround times.  Costs are promptly and
accurately recharged to each Partner Authority in line with the contract.
• The contractor produces monthly and annual performance reports in line with the Performance
Measurement Framework as set out in the Authority Requirements document which forms part of the
contract.
• The Contract Management Team undertake monthly site visits to satisfy themselves of the adequacy and
accuracy of the contractor’s performance monitoring processes.  A checklist based upon the KPIs is
populated for each visit and retained as evidence. 
Key areas requiring management action (High Priority)
No key areas requiring urgent management action have been identified. 
Other areas for improvement (Medium Priority)
There were no other areas for improvement identified. 
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35
8. Action Plan Clyde Valley Waste Contract  0800/2026/002 
Ref Finding
1 Some minor areas for improvement were identified.
A JSB has been established to oversee and monitor the operation and performance of the CVWC. The IAA, which sets out the scope of the agreement and key obligations of the
Lead Authority and Partner Authorities, includes a number of tasks that the JSB is required to complete within specified timescales.  Our review of the IIA identified a small number
of instances where these were not completed within the timescales prescribed.  These include:
• Section 7.5 of the IAA requires the JSB to consider and approve the Annual Budget for the following financial year by 30 November each year, however, the 2026/27 Annual
Budget was not approved until December 2025.  
• Section 10.3 of the IAA requires that the JSB approve the Contract Management Plan (CMP) no later than 31 December in each contract year. We noted that neither the
2025/26 nor 2026/27 CMPs were approved in accordance with this requirement.  The 2025/26 CMP, due for approval in December 2024, was not approved until December
2025 and the 2026/27 CMP, due for approval in December 2025, was not approved until March 2026. 
Additionally, the contractual arrangements with the contractor, Viridor are set out in a Project Agreement and supporting Authority Requirement agreed between North Lanarkshire
Council and Viridor. We noted that, in recent years, changes to certain aspects of the contractual arrangements have been agreed with Viridor and the Partner Authorities and
subsequently implemented, however, a formal deed of variation to reflect these changes has not yet been finalised and approved. We understand that this was delayed to allow
for recent legislative changes to be incorporated. 
Similar issues relating to non-compliance with the timescales set out in the IAA and delays in formally documenting changes through a deed of variation have been reported
previously. 
Implication Recommendation Priority Management response Implementation
Date
If key documentation is not presented
to the JSB for review and approval in
line with the IAA, this may impact on
the ability of the JSB to properly
discharge its duties and this may lead
to decisions being made or agreed
without full awareness of the budget
and/or key outcomes.
Changes to the Project Agreement
may not be contractually binding
despite being operationally applied.
The Depute Chief Executive, as Contract Director, should
ensure that:
(1) Going forward, the Annual Budget and CMP are
presented to, and approved by, the JSB in accordance
with the timescales set out in the IAA.
(2) Ensure that all agreed changes to the Project
Agreement are formally captured in a deed of variation
and that this is approved by all parties at the earliest
opportunity. 
Low
Agree 
Jackie Lytlle, Contract Manager (Clyde Valley)
Steering Group meetings are now (and have
been since November 2025) booked in at least
6 months in advance to ensure deadlines for
approvals are met. 
April 2026 
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North Lanarkshire Council
Report
Audit and Scrutiny Panel
Does this report require to be approved? ☐ Yes   ☒ No
Ref FS/LM/ASP/May 2026    Date 14/05/26
Internal Audit: Follow-up of implementation of audit
recommendations 
From  Francis Scott, Chief Officer (Audit and Risk)
E-mail ScottFr@northlan.gov.uk   
Executive Summary
The purpose of this report is to update the Panel on the progress made by management in
the implementation of Internal and External Audit recommendations.
In the period to 31 March 2026, of the 29 High and Medium priority recommendations that
were due, 20 have been fully implemented and nine remain outstanding.  Of the nine
recommendations that remain outstanding, two have an implementation date which is more
than 12 months overdue.
Since April 2021, 97% of all relevant audit recommendations have been satisfactorily
implemented by Services, meaning that only 3% of these audit recommendations remain
outstanding.
In respect of recommendations from External Audit reports, nine of the 20 agreed actions
have been completed, four are partially implemented, one is no longer relevant and six are
not yet due.
Recommendations
The Panel is invited to:
(a) Note the contents of this report.
(b) Consider whether there are any issues arising from this report on which they wish to
receive further information from relevant management.
The Plan for North Lanarkshire
Priority  All priorities
Ambition statement All ambition statements
Programme of Work All Programmes of Work
Item 6
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1. Background
1.1 This report presents an overview of the progress of all High and Medium priority Internal
Audit recommendations in the period to 31 March 2026.  
1.2 This report also provides an update on progress made in addressing recommendations
arising from External Audit reports issued as part of the 2022-23, 2023-24 and 2024-
25 audits.
1.3 The updates from management on progress to date have been verified on a sample
basis by Internal Audit as part of the preparation of this report.  However, it should be
noted that this review has focused on whether planned actions have been completed
and has not included detailed substantive testing of whether the implemented actions
have been effective in addressing previously identified weaknesses. 
2. Report
Internal Audit recommendations
2.1 Table 1 below summarises the progress of all High and Medium priority
recommendations which were due to be completed in the period to 31 March 2026. 
Overall, 20 of the agreed actions have been completed and nine remain outstanding.
Table 1
Completed No Longer
Relevant Outstanding Total
Chief Officer Area
Asset and Procurement 3 0 0 3
Community Operations 4 0 2 6
Education 0 0 2 2
Finance and Technology 2 0 0 2
Housing and Communities 3 0 3 6
Legal, Democratic and
Strategy 3 0 1 4
People Resources 5 0 1 6
TOTAL 20 0 9 29
2.2 For the nine outstanding recommendations, revised implementation dates have been
agreed.  Appendix 1 provides detail of these recommendations with an update on
progress provided by service management. Appendix 1 also references instances
where the original implementation date of a recommendation was more than 12 months
overdue.  In this period there are two such actions, referenced 1.1 - 1.2 in the appendix. 
Relevant Chief Officers have been invited to attend the Panel meeting to provide
explanations. 
2.3 As at 31 March 2026, 97% of all relevant audit recommendations, where the original
agreed implementation date was either due or had passed, have been fully
implemented by Services, meaning that the percentage overall of all audit
recommendations made since April 2021, which remain outstanding, is 3%.  This
shows an increase in performance since the last period when 94% were complete and
6% were outstanding.   
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External Audit recommendations
2.5 Table 2 shows the status of actions agreed by management in response to External
Audit reports issued as part of the 2022-23, 2023-24 and 2024-25 audits. As at 31
March 2026, nine of these recommendations are complete, four are partially
implemented, six are not yet due and one is no longer relevant. Appendix 2 provides
detail on the status of these recommendations with an update on progress provided by
service management.
Table 2
Completed Partially
implemented
Not yet
due
No longer
relevant Total
Report Title
2022-23
Annual Report 2021/22 1 1 0 1 3
Best Value Thematic Report 3 0 0 0 3
2023-24
Annual Report 2 2 1 0 5
Best Value Thematic Report 2 1 0 0 3
2024-25
Annual Report 1 0 3 0 4
Best Value Thematic Report 0 0 2 0 2
TOTAL 9 4 6 1 20 
2.6 The action reported as no longer relevant refers to issues relating to capital processes.
Two of the three points made within this action have been implemented and the third
has been superseded by an action raised in the 2024-25 External Audit Annual Report. 
3. Measures of success
3.1  Internal Audit reports each cycle to the Audit and Scrutiny Panel on the progress made
by management in implementing actions in response to Internal and External Audit
reports.   
4. Supporting documentation
Appendix 1 Register of Outstanding Internal Audit Recommendations 
Appendix 2 External Audit Recommendations 
Francis Scott 
Chief Officer (Audit and Risk) 
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5. Impacts 
5.1 Public Sector Equality Duty and Fairer Scotland Duty 
Does the report contain information that has an impact because of the Public Sector
Equality Duty and/or Fairer Scotland Duty? 
Yes ☐ No ☒
5.2 Financial impact 
Does the report contain any financial impacts? 
Yes ☐ No ☒
5.3 HR policy impact 
Does the report contain any HR policy or procedure impacts? 
Yes ☐ No ☒
5.4 Legal impact 
Does the report contain any legal impacts (such as general legal matters, statutory
considerations (including employment law considerations), or new legislation)? 
Yes ☐ No ☒
5.5 Data protection impact 
Does the report / project / practice contain or involve the processing of personal
data?   
Yes ☐ No ☒
5.6 Technology / Digital impact 
Does the report contain information that has an impact on either technology, digital
transformation, service redesign / business change processes, data management,
or connectivity / broadband / Wi-Fi? 
Yes ☐ No ☒
5.7 Environmental / Carbon impact 
Does the report / project / practice contain information that has an impact on any
environmental or carbon matters? 
Yes ☐ No ☒
5.8 Communications impact 
Does the report contain any information that has an impact on the council’s
communications activities? 
Yes ☐ No ☒
5.9 Risk impact 
Is there a risk impact? 
Yes ☒ No ☐ 
If Yes, please provide a summary of the key risks and potential impacts, highlighting
where the risk(s) are assessed and recorded (e.g. Corporate or Service or Project
Risk Registers), and how they are managed?
Failure by Services to address previously identified issues and/or weaknesses will
impact on the effectiveness of the relevant control framework.  This, depending on
the nature of the issue, will be captured and should be reflected in the relevant
service risk register or the corporate risk register (as appropriate).
5.10 Armed Forces Covenant Duty 
Does the report require to take due regard of the Armed Forces Covenant Duty (i.e.
does it relate to healthcare, housing, or education services for in-Service or ex-
Service personnel, or their families, or widow(er)s)? 
Yes ☐ No ☒
5.11 Children’s rights and wellbeing impact 
Does the report contain any information regarding any council activity, service
delivery, policy, or plan that has an impact on children and young people up to the
age of 18, or on a specific group of these? 
Yes ☐ No ☒ Page 94 of 238

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APPENDIX 1 – Register of Outstanding Internal Audit Recommendations  
Ref.  Report Details Recommendation Original & revised
timescales Management update
1.1 Chief Officer
(Education)
School Excursions
(October 2023)
The Chief Officers of Education (North and South) should ensure that:
(1) A comprehensive formal review of both the Council’s Educational
Excursions and Outdoor Activities Policy and the Risk Assessment
Guidance on Educational Excursions and Outdoor Activities is
undertaken to revisit and refresh all aspects of these documents
with a view to improving the robustness of the Council’s
arrangements associated with school trips and excursions.  This
should take account of, but not limited to, the information contained
in Appendix 2 and the need for roles and responsibilities of all
relevant parties, including those within other Council services to be
clearly documented in the revised guidance.
(2) Any revised arrangements are fully communicated to all Council
Services with a role in the process.
(3) They explore how best to gather/record details of all school trips
and excursions and thereafter monitor compliance with the
Council’s expected arrangements associated with such trips and
excursions.
Priority: High
April 2024
March 2025
September 2025
June 2026 
(>12 months
overdue) 
A review has been undertaken by HQ officers to re-assess the
scope and delivery time of the project.  This review identified a
number of technical tasks which require to be undertaken,
including systems reviews and alignment with other Service and
Council policies. 
The Head Teachers have been briefed on the requirement to
undertake a review of the policy, and a short life working group
has been created.  Due to the nature of the task, and to comply
with all of the Internal Audit recommendations, this work will now
be undertaken in line with the Council’s project management
arrangements/guidelines.  A project outline, work plan and risk
register has been developed with formal working group
meetings meeting on a number of occasions since January
2026. The working group have considered National Guidance
and critically reviewed the existing policy to identify information
which needs to be either updated or amended. Consideration is
also being given as to whether cash receipts should continue
versus an online only system.
In the interim, best practice advice has, and will, continue to be
given to schools based on the existing policy.
The delay in implementation is largely due to staff resources
being allocated to responding to school transport issues and
enquiries.
Going forward, there will be greater clarity regarding the post(s)
within the Resources Team which will have HQ governance
responsibility for overseeing school trip/excursion policy and
activity. 
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Ref.  Report Details Recommendation Original & revised
timescales Management update
1.2 Chief Officer
(Education)
School Excursions
(October 2023)
The Chief Officers of Education (North and South) should:
(1) as part of the formal review referenced at Action Plan point 1 above,
ensure that this includes the creation of a dedicated section within
the policy and/or associated procedures which outlines clear
expectations around the financial aspects associated with the
organisation and execution of trips.  This should include, but not be
limited to:
(a) A clear and detailed protocol for booking trips where a travel
company/tour operator is not going to be used ensuring
arrangements minimise the risks associated with such
payments and ensure that the use of personal credit cards to
book trips is prohibited.
(b) Consideration to promoting iPay Impact as the primary means
for collecting monies in schools thus reducing cash payments
and the subsequent flow of physical cash in the school.
(c) Determining the additional checks/monitoring that need to be
carried out at establishment level to ensure all monies due are
received and duly banked in line with Council policy.
(d) clear guidance on the levels of physical cash that can/should
be taken on a trip/excursion, the required records to be
completed and documentary evidence required/expected to
support any such spend.
Priority: High
April 2024
March 2025
September 2025
June 2026 
(>12 months
overdue) 
A review has been undertaken by HQ officers to re-assess the
scope and delivery time of the project.  This review identified a
number of technical tasks which require to be undertaken,
including systems reviews and alignment with other Service and
Council policies. 
The Head Teachers have been briefed on the requirement to
undertake a review of the policy, and a short life working group
has been created.  Due to the nature of the task, and to comply
with all of the Internal Audit recommendations, this work will now
be undertaken in line with the Council’s project management
arrangements/guidelines.  A project outline, work plan and risk
register has been developed with formal working group
meetings meeting on a number of occasions since January
2026. The working group have considered National Guidance
and critically reviewed the existing policy to identify information
which needs to be either updated or amended. Consideration is
also being given as to whether cash receipts should continue
versus an online only system.
In the interim, best practice advice has, and will, continue to be
given to schools based on the existing policy.
The delay in implementation is largely due to staff resources
being allocated to responding to school transport issues and
enquiries.
Going forward, there will be greater clarity regarding the post(s)
within the Resources Team which will have HQ governance
responsibility for overseeing school trip/excursion policy and
activity.
1.3 Chief Officer
(Community
Operations)
Fleet
Management
(October 2025)
The Chief Officer (Community Operations) should:
(1) Consider introducing second-officer verification for critical data
inputs into Freeway, particularly during vehicle profile setup, to
improve data accuracy and reliability. 
(2) Consider expanding the existing compliance audit process
currently used in waste management to cover the wider fleet,
ensuring consistent oversight and promoting continuous
improvement across all service areas.
Priority: Medium 
October 2025
August 2026
Compliance checks across the entire fleet are still in progress
and have not yet been completed.  The process is expected to
be fully completed in line with the revised timescale.
Delay in implementation is largely due to this action requiring a
significant resource commitment. 
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Ref.  Report Details Recommendation Original & revised
timescales Management update
1.4 Chief Officer
(People
Resources)
ESC: Selected
Controls
(July 2025)
The Chief Officer (People Resources) should identify and correct any
issues/errors arising from the finding, particularly in relation to casual
worker payments being allocated to posts with contracted hours and/or
casual/sessional workers in receipt of payments which they are not
entitled to.
Priority: Medium
October 2025
July 2026
Due to staffing changes, there was a delay in actioning this
recommendation.
Going forward, each of the cases identified will be individually
reviewed to determine the inaccuracies. 
The values involved are likely to be minimal and as such any
inaccuracies resulting in overpayments will not be pursued as
they will fall under the threshold set by Finance for economical
recovery.  
Any resultant underpayments will be calculated and paid to the
relevant employees. Discussions are ongoing to determine the
most practical method of doing so. 
1.5 Chief Officer
(Housing and
Communities)
Community
Assets Transfer
(October 2025)
To take cognisance of the areas for improvement highlighted in the
finding, the Chief Officer (Strategy and Engagement) should:
(1) Ensure the guidance notes are finalised and issued, and that formal
written policies are developed and implemented to guide officers in
reviewing and assessing CAT applications. 
(2) Implement a conflict of interest declaration process for all officers
involved in assessing and making decisions on CAT applications.
Priority: Medium
December 2025
March 2026
September 2026
A review of the documentation is underway, and early meetings
have taken place with key Services to consider the best
approach.  
A report was presented to the Community Asset Leadership
Group in April 2026, to agree the process for review of CAT
assessment and decision-making processes. This will now be
taken forward.
There has been an element of challenge in securing dates for
review meetings within the original timescales which has led to
a delay in the implementation of the recommendation.  Such
meetings are required to ensure that the approach is
collaborative and meets the needs of the key Services.  Those
involved are keen to ensure that the review is robust.
1.6 Chief Officer
(Legal,
Democratic and
Strategy)
Information
Governance
(October 2025)
The Chief Officer (Legal and Democratic), in conjunction with the Data
Governance Board (DGB), should continue to review/enhance the
information governance arrangements. This should include, but not be
limited to, ensuring that: both the reviews of the Council’s Data Sharing
agreements, Third Party Processing Agreements, Retention Plans and
Retention Schedules; and development and update of information on
the Council’s Information Asset Register are completed within a
reasonable timescale.
Priority: Medium
January 2026
September 2026
Reviews of the Council’s Data Sharing, Third Party Processing
and Retention Reviews are currently underway and are being
progressed through the DGB and DMCG.  Agreement has been
reached with the DGB to change the completion dates for
review to June 2026.  A final review report will thereafter be
presented at DGB.
An improvement plan has been developed which identifies
actions to be delivered with regards to the Information Asset
Register. This will include refining the list, developing
procedures and reviewing the role of the Information Asset
Owner document. 
Delay in implementation is largely due to responsibility for
managing the Information Asset Register only transferring to
Legal and Democratic Services at the end of January 2026.
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Ref.  Report Details Recommendation Original & revised
timescales Management update
1.7 Chief Officer
(Community
Operations)
Fleet
Management
(October 2025)
The Chief Officer (Community Operations) should undertake a
reconciliation or fact-finding exercise across all Council Services, to
identify any additional vehicles acquired through informal means that
may not yet be known to Fleet Management.  The outcome of this
exercise should be used to update Freeway records and ensure that all
vehicles are brought under appropriate inspection, certification and
maintenance regimes.
Priority: High
March 2026
August 2026
The Service have undertaken a review of all light fleet vehicles
which included evaluating service patterns, identifying
responsible officers for each vehicle and confirming the
assigned drivers within each department. The vehicles have
been added to the fleet system but due to staff shortages the
system has not been updated to include the service and
inspection intervals. 
1.8 Chief Officer
(Housing and
Communities)
Community Asset
Transfers 
(October 2025)
The Chief Officer (Strategy and Engagement) should update the Policy
to clearly state whether and how the Leadership Group should be
notified of CAT enquiries and that submission of a risk assessment or
risk management plan is a mandatory requirement for all applications.
The policy should also be updated to include clear eligibility
requirements and the required essential criteria to support consistent
CAT applications.
Priority: Medium
March 2026
July 2026
The Community Ownership and Management of Assets Policy
is currently under review, specifically around the Common
Good Assets and approach to standard securities and
protections. A desktop review is underway to identify policy
improvements and additions, and this will reflect audit
recommendations. A report will be presented to Policy and
Strategy Committee in June 2026. 
The delay in implementation was due to a wider review of the
Policy being needed and this being presented to the Policy and
Strategy Committee in June 2026.
1.9 Chief Officer
(Housing and
Communities)
Community Asset
Transfers 
(October 2025)
The Chief Officer (Strategy and Engagement) should: 
(1) Update the log of enquiries and applications for CATs to provide
more detailed information on the progress of each CAT
application, including, but not limited to, the areas highlighted in
the finding.
(2) Consider introducing a process for monitoring the log on a regular
basis to ensure that it is fully and promptly updated for all
applications and chasing up any outstanding information.
Priority: Medium
March 2026
September 2026
A review of the documentation is underway, and early meetings
have taken place with key Services to consider the best
approach.  
A report was presented to the Community Asset Leadership
Group in April 2026, to agree the process for review of CAT
assessment, decision-making processes and associated logs
and paperwork. This will now be taken forward.
There has been an element of challenge in securing dates for
review meetings within the original timescales which has led to
a delay in the implementation of the recommendation.  Such
meetings are required to ensure that the approach is
collaborative and meets the needs of the key Services.  Those
involved are keen to ensure that the review is robust. 
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Page 99

APPENDIX 2 – External Audit recommendations
Ref Recommendation Agreed Management Action Responsible
Officer Due Date Update
2022/23 – Annual Report
2.1 Land and Buildings Valuations
The Council should continue to consider its
approach to the valuation of land and
buildings going forward and continue to
ensure this is appropriate to assess whether
asset values have moved materially in year
and as at 31 March. The Council should work
with its valuers to ensure valuations are in
accordance with accounting code
requirements. Appropriate scrutiny of the
valuation work completed should be
undertaken to ensure these are consistent
with the Council’s records. 
The Council will continue to review its
revaluation policy in line with code
requirements and in conjunction with the
professional valuers. This will take
cognisance of the recommended
actions from the Audit Scotland round
table discussion including that ‘where
the valuation exercise is carried out in-
year but earlier than 31 March for
reasons of expediency, any material
changes in value in the interim should
be adjusted for’. The Council will give full
consideration to the practicalities of
undertaking valuations at 31 March to
ensure this will not impact the annual
statutory requirement to submit the
unaudited accounts by 30 June. The
Council will also continue to assess
whether there is a material difference
between the carrying value in the fixed
asset register and current value, and
ensure the accounts are code
compliant.
Chief Officer
(Finance) 
Chief Officer
(Asset and
Procurement)
June 2024 
June 2025 
Ongoing
Ongoing.
Audit Scotland 2024-25 Annual Audit report has this item
categorised as ‘Work in progress’ as the Council team has
arrangements in collaboration with the external valuers to
make an assessment of any material change in value
between 1 February and 31 March to ensure that the
carrying value of land & buildings is accurate and is not
materially mis-stated. Recent history has shown there has
not been any material movement to the carrying value.
This will continue to be considered in light of potential
future changes to accounting requirements around
valuations of non-current assets.
The valuation date used is under continual review in
discussion with Council’s appointed valuation team, taking
into consideration the practicalities and impacts of moving
to a 31 March valuation date on the process and timely
production of the unaudited accounts. Any material
changes in value between the valuation date and 31
March will continue to be assessed and adjusted for, as
appropriate. This practice has been acceptable by
external auditors for the last two annual valuations. 
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Page 100

Ref Recommendation Agreed Management Action Responsible
Officer Due Date Update
2.2 Capital Processes
The Council should review a number of its
capital processes to ensure the value of
assets is correctly held in the accounts,
including: 
• The Council should review the revaluations
provided by its valuers to ensure all assets
have been included. 
• The Council should review its capital
impairment process to ensure it is robust
enough to identify potential indicators of
impairment across all assets. 
• The Council should also consider how
assets are held on its fixed asset register to
ensure compliance with the
componentisation requirements of the Code. 
The Council will: 
• review the revaluation practices to
ensure all relevant assets are
incorporated 
• review the process of identifying
impairments to ensure all assets are
considered 
• review and consider how assets are
held on its fixed asset register to
ensure full compliance with the
componentisation aspects of the code 
Chief Officer
(Finance) 
Chief Officer
(Asset and
Procurement)
June 2024 
June 2025
No longer relevant.
While the first two points have been fully implemented (see
narrative below), the third has been superseded by the
Replacement of Assets recommendation made in the
2024/25 External Audit Annual Report.
• Complete - reviews are undertaken of Fixed Asset
Register (FAR) when selecting the representative
sample of 20% across all asset categories to ensure that
all assets that required to be incorporated (e.g. last
valuation was 5 years ago etc) are included in the
valuation programme. 
• Complete - a revised process has been established.  A
list of all assets within the FAR is provided to Chief
Officers as part of the year-end exercise to ensure full
consideration of assets within service. Any impairments
are considered as part of the valuations process.
2.3 Significant Trading Operation
The Council should review the trading
operation to examine the cost effectiveness
of the service provided to ensure that it
continues to represent best value for the
Council. 
As currently presented the Trading
Account shows a rolling three-year
deficit. However, this performance
incorporates non-cash adjustments for
Employee Benefits. Following the same
accounting treatment as Council, these
costs would be reversed back out
resulting in a cumulative three-year
surplus being reported, demonstrating
continued value for money in the
operation of the Council's Trading
Account. The Council will seek to amend
the presentation of the Trading Account
note for the 2023/24 annual accounts to
reflect the cash and non-cash elements
of Trading Account operations. 
Chief Officer
(Finance)
June 2024 Complete.  Reported to Panel in August 2024.
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Page 101

Ref Recommendation Agreed Management Action Responsible
Officer Due Date Update
2022/23 – Best Value Thematic Report
2.4 Involvement of Members in Strategic
Planning
The Council should look to improve its
existing processes for engaging elected
members on the overall strategic planning
process. 
As part of its scheduled annual review,
we will refresh the narrative presently
contained within the Strategic Policy
Framework in respect of elected
members’ strategic planning role and
will thereafter emphasise through the
CMT and Community Co-ordinator role
the importance of engaging elected
members on the strategic elements of
the integrated Programme of Work
Delivery Plan. Elected member role in
strategic planning to also be clearly
documented in the developing
Programme of Work Governance
Framework.
Chief Officer
(Business and
Digital)
September
2024
Complete.  Reported to Panel in November 2024.
2.5 Engagement with Communities
The Council should consider how it measures
the level of engagement with communities
and equalities groups.   
This will be aligned with actions arising
from new communication strategy to be
considered by council in March 2024.
The strategy will also define what is
meant by seldom-heard communities
and groups.
Chief Officer
(Strategic
Communication
and
Engagement)
March 2024 Complete. Reported to Panel in August 2024.
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Page 102

Ref Recommendation Agreed Management Action Responsible
Officer Due Date Update
2.6 Elected Members Training and
Development Programme
The Council should work with members to
understand the reasons for the poor
attendance to ensure its training and
development programme is fit for purpose.   
The number of attendees at
development sessions has been low,
however there has been a slight
increase in numbers attending recent
events.  The Talent and Organisational
Development Team will continue to
communicate regularly with Political
Group Business Managers to
encourage discussions around training,
low attendance and engagement to be
included on business meeting agendas. 
A survey will be sent to all Elected
Members to help identify any restrictions
and reason for low attendance. 
Development of the Elected Members
area on LearnNL will continue, with all
development session recordings and
presentation slides being uploaded for
members to access at any time.  A
monthly communication is sent to all
Elected Members with direct links to
new recorded sessions.
Chief Officer
(People
Resources)
November
2023
Complete. Reported to Panel in February 2024.
2023/24 – Annual Report 
2.7 Replacement of Assets
Management should establish a process to
ensure assets replaced are appropriately
removed from the asset register and
accounted for as a disposal appropriately.   
In the absence of componentisation, it is
unclear as to how we can put in place a
process to remove the value of elements
of assets which have been replaced.
However, we will commit to a review of
expectations around componentisation
with a view to future discussions with
External Audit.
Chief Officer
(Finance)
June 2025 Complete. Reported to Panel in November 2025. 
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Page 103

Ref Recommendation Agreed Management Action Responsible
Officer Due Date Update
2.8 Statutory Override
The Council should proactively work with
CIPFA and the wider local government sector
to arrive at appropriate solution for the
implementation of accounting for
infrastructure assets.
The Council will work with CIPFA and
the wider Local Government sector as
appropriate to inform a decision on the
accounting treatment for infrastructure
assets.
Chief Officer
(Finance)
Ongoing Not yet due.  Position as at May 2026.
CIPFA/LASAAC issued a consultation for the 2025/26
accounting code which includes the proposal to extending
the statutory override within the UK.  The statutory
override has been extended until 2026/27 in Scotland and
208/29 in England and Wales.
The Council will continue to work with CIPFA and the wider
Local Government sector, as appropriate, to inform a
decision on the accounting treatment for infrastructure
assets over the longer term. 
2.9 Reinforced Autoclave Aerated Concrete
(RAAC)
For those properties where RAAC was
confirmed, the Council should determine a
more accurate measure of the level, of
impairment in line with the requirement of
accounting standards.
Further engagement with the Council’s
valuers is required to determine an
appropriate methodology, subject to full
investigation being carried out to
determine the extent of costs/remedial
works required.
Chief Officer
(Finance) 
Chief Officer
(Asset and
Procurement)
June 2025 Complete. Reported to Panel in November 2025. 
2.10 Continuity and Security of IT Operations
The Council should ensure that there is
appropriate oversight of its continuity and
security of IT operations and ensure the
necessary assurances are obtained for
externally hosted systems. 
Services will continue to own and
manage their Business Continuity
arrangements – with support and
guidance from the Resilience Planning
Team. Business Continuity testing
framework has been implemented. It is
recommended that Services test their
plans annually and a corporate test will
be arranged every 3 years.   
Depute Chief
Executive 
November
2026 
Complete. Reported to Panel in May 2025.
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Ref Recommendation Agreed Management Action Responsible
Officer Due Date Update
2.10 Continuity and Security of IT Operations
The Council should ensure that there is
appropriate oversight of its continuity and
security of IT operations and ensure the
necessary assurances are obtained for
externally hosted systems. 
Oversight of IT security and IT Disaster
Recovery will continue to be managed
through established corporate working
groups and Service Management
Teams. Development of assurances on
externally hosted systems will be
monitored through the established
arrangements of the Digital North
Lanarkshire Programme of Work.  
Chief Officer
(Business &
Digital)
April 2025 
Ongoing
Business and Digital 
Ongoing.
A project to formally improve DR planning management
practices has commenced, with phase one focusing on the
Council’s in-house IT estate.
Integration with business continuity planning management
processes is under way. An exercise has been undertaken
to identify the IT systems used to support the delivery of
critical Council functions. The Council’s IT service
management system is being evaluated to record DR-
specific information. New DR templates for individual
systems will be developed as part of this project.
New software for Business Continuity Planning has been
procured which will enable the Council to better manage
arrangements. Roll out of the new software will be in a
phased integration approach with services between June
- December 2026.
The exercise to obtain assurances on the reviewing and
updating of existing DR plans is scheduled to complete at
the end of March 2026. These arrangements, however,
will be superseded by the improvements being made
through the adoption new DR planning management
processes.
A new cyber incident response plan has been approved
by the Data Governance Board. This updates incident
management arrangements specified as part of DR
planning arrangements. This will be supported by specific
playbooks being developed over the course of 2026/27
which are based on the Scottish Government’s Cyber
Incident Response Toolkit.
The Council is currently onboarding the Scottish
Government-sourced supply chain cyber assurance
software provided by Supply25. Further refinements of
supply chain assurance processes continue to take place
as per the Council’s Programme of Work ambitions.
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Page 105

Ref Recommendation Agreed Management Action Responsible
Officer Due Date Update
2.11 Public Performance Reporting
The Council should improve its public
performance reporting to provide its citizens
and communities with a clear summary of
performance. 
Following various programme of work
reports to each committee cycle
throughout the year, regular news
articles and updates on delivery and
performance are reported through the
council’s website. With the Programme
of Work to 2028 and its associated
governance arrangements well
established, work will be undertaken
during 2025/26 to formally review and
redevelop public performance reporting
arrangements.
Chief Officer
(Strategic
Communication
and
Engagement)
March 2026 
June 2026
Ongoing.
The Council is in the process of creating a bespoke
landing page on its website to publicly report service
delivery performance. This will include an overview of the
strategic alignment of The Plan for North Lanarkshire and
other major strategies and updates on the agreed health
check indicators. There will be links to performance
outcomes for other high-level strategies. 
As part of this piece of work, the Council will include the
reporting of progress against its 28 Health Check
Indicators to ensure it is more accessible to the public. 
It is anticipated that this page will be live by 30 April 2026.
Although the 28 health check indicators section will be
complete by 30 June 2026. 
In addition, an annual update on performance over
2025/26 will be produced, which will also sit on this
performance landing page. 
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Page 106

Ref Recommendation Agreed Management Action Responsible
Officer Due Date Update
2023/24 – Best Value Thematic Report
2.12 Acting on Staff Engagement Feedback
As the council develops its staff engagement
approach, it should ensure that as well as
providing information to staff on council
decisions, it also incorporates the views of
staff and trade unions to support transparent
decision making, and evidence how it is
acting on findings from the Summer 2024
Roadshow sessions.
There are several strands of work
underway which will allow the council to
progress this recommendation,
including a refreshed staff survey and a
review of trade union consultation
arrangements. These will be taken
forward along with the feedback from
our 2024 Roadshow sessions to deliver
an improved engagement approach.
Chief Officer
(People
Resources)
December
2025 
May 2026
Refresh of staff survey – Complete 
The Councils revised staff survey based on the fair work
first framework, has now been developed and launched
across all services. The survey was piloted in three
services initially, covering more than 800 staff, with a
summary of the results reported to Policy & Strategy
Committee in December 2025. 
A further revised staff survey was launched in March 2026
and will be open to all staff until August 2026, with regular
updates to Chief Officers with completion levels in their
Service. A full update will be presented to Committee in
December 2026. 
Review of trade union consultation arrangements –
Ongoing 
The revised Trade Union Recognition Agreement was
approved at the Joint Consultative Committee for Local
Government Employees (JCC) on 24 March 2026. It will
now be submitted to the Finance and Resources
Committee on 27 May 2026, in line with the updated
constitutional requirements. Following approval, the
agreement will be published, and the revised consultation,
negotiation, and collective bargaining processes will take
effect immediately.
2.13 Hybrid Working Policy
The council should continue to monitor the
impact of its hybrid working approach. It
should continually assess the impact of
increasing the number of office days, in terms
of performance, staff wellbeing, and
recruitment and retention.
The council will continue to monitor the
impact of its permanent Hybrid Working
Scheme, through both manager and
staff surveys, and in terms of
performance, recruitment and retention
in hybrid roles.
Chief Officer
(People
Resources)
January
2026
Complete.
A staff survey was issued in October 2025 and the
responses received were positive with staff content with
the current Hybrid Working Scheme.
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Ref Recommendation Agreed Management Action Responsible
Officer Due Date Update
2.14 Temporary Workforce
The council should include data reporting on
its temporary workforce as part of published
workforce data, and once available it should
include data on agency workers.
Work is underway to implement a more
centralised approach to reporting on
and managing temporary workforce
resources, including agency workers.
This work will be fully progressed to
improve future reporting.
Chief Officer
(People
Resources)
December
2025
Complete. 
Data on temporary workforce is now included within the
Workforce Dashboard which was presented to both CMT
and Policy & Strategy Committee in December 2025.   
Data regarding agency workers (non-payroll) is now being
gathered and reported on with oversight and governance
through the Workforce Steering Group. This includes
approval for agency spend. The Steering Group will also
be provided with regular reports detailing consolidated
spend on agency workers to ensure that this is being
tracked.  
2024/25 – Annual Report
2.15 Fixed Asset Register
The Council should undertake a review of the
fixed asset register to assess its capability to
support accurate reporting.
The Council fully reviews and reconciles
all fixed asset transactions within the
overall Fixed Asset Register to the
financial ledger and financial statements
to ensure accurate reporting.  
However, the Council will review the
specific summary FAR extract report
and reporting tool mechanics relating to
depreciation charged to enhance
reconciliations processes.  
Chief Officer
(Finance and
Technology)
June 2026 Complete.
The Council has reviewed and updated its specific
summary Fixed Asset Register extract reports to now
incorporate current year depreciation figures from the
financial ledger which will enhance reconciliation
processes of the FAR to the financial statements.
2.16 Common Good Assets
The Council should continue to review
requirements to disclose Common Good
assets separately from council assets.
The Council agrees to continue to
review the disclosure requirements in
respect of Common Good assets.
Chief Officer
(Finance and
Technology)
June 2026 Not yet due. Position as at May 2026.
In preparing its 2025/26 draft accounts, the Council will
ensure the value of common good assets held on the
balance sheet are fully disclosed within the notes to the
accounts.
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Ref Recommendation Agreed Management Action Responsible
Officer Due Date Update
2.17 Strategic Use of Reserves
The Council should undertake a review of its
reserves to determine what the planned or
targeted level of reserves is appropriate. It
should also look to define when certain
earmarked reserves such as those
earmarked for future budget pressures would
be utilised as it is unclear whether these
would be used to address short term
pressures or to support investment to support
long-term sustainability and improved
outcomes. 
The Council will undertake a review of
its reserves to determine a
planned/target level appropriate and
timing of use.
Chief Officer
(Finance and
Technology)
June 2026 Not yet due. Position as at May 2026.
A revised Reserves Policy was approved by Policy and
Strategy Committee on 4th December 2025. This revised
policy includes targets for the level of reserves held in
relation to both Contingency Fund and Future Budget
Pressures.
2.18 Exit Packages
There are opportunities for the council to
enhance the standard of documentation of
early retirement decisions. The council
should also review its policies and
procedures to ensure that exit packages of
senior officers are subject to additional
scrutiny.  
The Council intends to undertake a
wider review of its democratic,
committee and decision-making
governance procedures with a report
due to be presented to Policy and
Strategy Committee on 25 September
2025. Phase 4 of this review includes a
review and update of the Scheme of
Administration and Delegation, which
will now incorporate consideration of the
governance around early release of
senior staff.
Chief Officer
(Legal and
Democratic)
December
2026
Not yet due. Position as at May 2026.
An update on the review of the Council’s democratic,
committee, and decision-making governance procedures
was presented to Policy and Strategy Committee on 19
March 2026. Phase 4 of the review includes a review and
update of the Scheme of Administration and Delegation is
still scheduled to be completed by December 2026. 
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Page 109

Ref Recommendation Agreed Management Action Responsible
Officer Due Date Update
2024/25 – Best Value Thematic Report
2.19 Benefits Realisation
The Council should prioritise completion of its
benefits realisation framework and
incorporate reporting on both financial and
non-financial benefits into regular monitoring
reports. Given the financial challenges the
council is facing there is a need to
increasingly monitor and track cost and
benefits of transformation projects. This will
help inform officers and members of the
extent to which transformation projects are
delivering their intended benefits. 
Following the Framework to the One
Service Board in March 2025,
arrangements are being made to roll this
out to all of the other Programme of
Work Boards.
Chief Officer
(Strategy and
Engagement)
June 2026 Not yet due. Position as at May 2026.
Work is ongoing to implement this recommendation in line
with the agreed action.
2.20 Improving Public Reporting of Progress
Against the 28 Health Check Indicators
The council should ensure that the reporting
of progress against its 28 Health Check
Indicators is more accessible to the public.  
There is a dedicated section within the
Programme of Work pages on the
website for “Performance”, however this
is under re development to ensure it
captures, and provides access to, all
relevant and already existing Council
and Programme of Work performance in
one place.  This will include regular
updates on the 28 health check
indicators in a way that is meaningful to
the reader.
Chief Officer
(Strategy and
Engagement)
June 2026 Not yet due. Position as at May 2026.
The Council is in the process of creating a bespoke
landing page on its website to publicly report service
delivery performance. This will include an overview of the
strategic alignment of The Plan for North Lanarkshire and
other major strategies and updates on the agreed health
check indicators. There will be links to performance
outcomes for other high-level strategies. 
As part of this piece of work, the Council will include the
reporting of progress against its 28 Health Check
Indicators to ensure it is more accessible to the public. 
It is anticipated that this page will be live by 30 April 2026.
Although the 28 health check indicators section will be
complete by 30 June 2026. 
In addition, an annual update on performance over
2025/26 will be produced, which will also sit on this
performance landing page. 
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Page 110

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Page 111

North Lanarkshire Council
Report
Audit and Scrutiny Panel 
Does this report require to be approved? ☒ Yes   ☐ No
Ref    FS/ASP/Charter2026 Date 14/05/26 
Internal Audit Charter 
From  Francis Scott, Chief Officer (Audit and Risk)  
E-mail scottfr@northlan.gov.uk   
1. Background
1.1 The Internal Audit Charter is a formal document that defines Internal Audit’s purpose,
mandate, authority and responsibility.  It establishes Internal Audit’s position within the
Council, including detailing the nature of the Chief Officer’s (Audit and Risk) functional
reporting relationship with senior management and the Panel, authorising access to
records, personnel and physical properties relative to the performance of audit
engagements, and defining the scope of Internal Audit activities.  
1.2 As part of the requirements of the Global Internal Audit Standards, the Charter should
be approved by the Panel on an annual basis. 
Executive Summary
The purpose of this report is to seek approval for the Internal Audit Charter, which sets out
the purpose, mandate, authority and principal responsibilities of the Council’s Internal Audit
function.
The content of the revised Internal Audit Charter has been agreed with the Chief Executive
and the Chief Officer (Finance and Technology) (as the Council’s Section 95 officer).    
In line with the Global Internal Audit Standards, the Internal Audit Charter will be revised
and updated annually and submitted to the Panel for consideration and approval.   
Recommendations
The Panel is invited to approve the revised Internal Audit Charter at Appendix 1.
The Plan for North Lanarkshire
Priority  All priorities
Ambition statement All ambition statements
Programme of Work Statutory / corporate / service requirement
Item 7
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2. Report
2.1 From 1 April 2025, Internal Audit teams across the UK are working to new mandatory
professional standards, replacing the previous Public Sector Internal Audit Standards
(PSIAS).  These standards will be a combination of:
• The Global Internal Audit Standards (GIAS).
• The Application Note “Global Internal Audit Standards in the UK Public Sector”.
• For Local Authorities, the Code of Practice on the Governance of Internal Audit. 
Together, these standards are referred to as the GIAS (UK Public Sector). 
2.2 Although the GIAS are now effective, Internal Audit teams are not expected to
demonstrate full compliance immediately but must work in accordance with the new
standards to build up their conformance, and progress against this will be presented to
future meetings of the Panel.    
2.3 A key requirement of the GIAS (UK Public Sector) is the inclusion of a specific Internal
Audit Mandate setting out the authority, roles and responsibilities of Internal Audit.  This
is included within the Charter document.
2.4 The revised Internal Audit Charter document is included at Appendix 1, and it is a
requirement that it is approved annually by the Panel.  The previous version was
approved by the Panel in May 2025, and there have been no significant amendments
arising from this annual review.  
2.5 The content of the Internal Audit Charter has been agreed with the Chief Executive and
the Chief Officer (Finance and Technology), as the Council’s Section 95 officer. 
3. Measures of success
3.1  The Council is required to ensure that it has an effective internal audit function which
conforms with the GIAS.  Conformance is self-assessed on an annual basis, with an
independent external quality assessment being undertaken at least every five years.   
4. Supporting documentation
4.1 Appendix 1 – Internal Audit Charter 
Francis Scott
Chief Officer (Audit and Risk) 
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5. Impacts 
5.1 Public Sector Equality Duty and Fairer Scotland Duty
Does the report contain information that has an impact because of the Public Sector Equality
Duty and/or Fairer Scotland Duty?
Yes ☐ No ☒
5.2 Financial impact
Does the report contain any financial impacts?
Yes ☐ No ☒
5.3 HR policy impact 
Does the report contain any HR policy or procedure impacts?
Yes ☐ No ☒
5.4 Legal impact
Does the report contain any legal impacts (such as general legal matters, statutory
considerations (including employment law considerations), or new legislation)?
Yes ☐ No ☒
5.5 Data protection impact 
Does the report / project / practice contain or involve the processing of personal data?  
Yes ☐ No ☒
5.6 Technology / Digital impact
Does the report contain information that has an impact on either technology, digital
transformation, service redesign / business change processes, data management, or
connectivity / broadband / Wi-Fi?
Yes ☐ No ☒
5.7 Environmental / Carbon impact
Does the report / project / practice contain information that has an impact on any
environmental or carbon matters?
Yes ☐ No ☒
5.8 Communications impact
Does the report contain any information that has an impact on the council’s communications
activities?
Yes ☐ No ☒
5.9 Risk impact
Is there a risk impact?
Yes ☐ No ☒
If yes, please provide a summary of the key risks and potential impacts, highlighting where
the risk(s) are assessed and recorded (e.g. Corporate or Service or Project Risk Registers),
and how they are managed?
.
5.10 Armed Forces Covenant Duty
Does the report require to take due regard of the Armed Forces Covenant Duty (i.e. does it
relate to healthcare, housing, or education services for in-Service or ex-Service personnel, or
their families, or widow(er)s)?
Yes    ☐                No ☒
5.11      Children’s rights and wellbeing impact
Does the report contain any information regarding any council activity, service delivery, policy,
or plan that has an impact on children and young people up to the age of 18, or on a specific
group of these?
Yes ☐         No ☒ 
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INTERNAL AUDIT
CHARTER  
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Document control
Title Internal Audit Charter
Owner Francis Scott, Chief Officer (Audit and Risk) Contact scottfr@northlan.gov.uk
Governance Group Audit and Scrutiny Panel
Author Francis Scott, Chief Officer (Audit and Risk) Contact scottfr@northlan.gov.uk 
Revision History
Number Originator Date Review Commenced Revision description/record of change
1.0 Ken Adamson August 2021 Review and update to confirm consistent with
PSIAS which had been updated
2.0 Paula Hendry July 2024 Update and refresh of document
3.0 Francis Scott March 2025 Updated to reflect the requirements of the
Global Internal Audit Standards (UK Public
Sector)
4.0 Francis Scott March 2026 Update document for annual approval 
Document Approvals
Number Governance
Group
Date approval granted Date approval to be requested 
(if document still draft)
1.0 Audit and
Scrutiny Panel
February 2018 
2.0 Audit and
Scrutiny Panel
September 2021 
3.0 Audit and
Scrutiny Panel
August 2024 
4.0 Audit and
Scrutiny Panel
May 2025 
5.0 Audit and
Scrutiny Panel 
14 May 2026 
Consultation Record (for most recent update)
Status of document consulted upon N/A
Stakeholders consulted/date Chief Executive, Chief Officer (Finance and Technology) – March 2026 
Strategic Alignment
The Internal Audit Charter is a formal document that defines Internal Audit’s purpose, mandate, authority and
responsibility and establishes Internal Audit’s position within the Council. 
Next review date
Review Date March 2027, then annually thereafter
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CONTENTS
1 Introduction 4
2 Purpose of Internal Audit 4
3 Internal Audit Mandate 5
4 Definitions 5
5 Independence, Positioning and Reporting Relationships 6
6 Internal Audit Authority and Oversight 7
7 Internal Audit Objectives and Responsibilities 8
8 Management Responsibilities 12
9 Scope and Types of Internal Audit Services 12
10 Internal Audit Plan 13
11 Resourcing 14
12 Prevention and Detection of Fraud and Corruption 15
13 Follow-up of Audit Recommendations 15
14 Quality Assurance and Improvement Programme 16
15 Annual Reporting and Overall Opinion 16
16 Communication and Reporting 17
17 Approval and Changes to the Internal Audit Mandate and Charter 18
18 Approvals 18 
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1. INTRODUCTION
1.1 The Local Authority Accounts (Scotland) Regulations 2014 require the Council to
operate a professional and objective internal auditing service in accordance with
recognised standards and practices.  
1.2 The Global Internal Audit Standard (GIAS) came into effect in January 2025 and
together with the Application Note: GIAS in the UK Public Sector, provides the
framework for the practice of internal auditing in the UK Public Sector.  For UK Local
Authorities, the CIPFA Code of Practice on the Governance of Internal Audit in
Local Government also provides guidance on the interpretation of the essential
conditions of the GIAS.
1.3 The GIAS require the Chief Audit Executive (CAE) to implement and maintain an
Internal Audit Charter, which sets out the Purpose of Internal Audit, the Internal Audit
Mandate, and the position and scope of Internal Audit in the Council.  The Internal
Audit Charter is reviewed and approved annually by the Corporate Management
Team and the Audit and Scrutiny Panel. 
2. PURPOSE OF INTERNAL AUDIT
2.1 In line with the GIAS, the purpose of Internal Audit is to strengthen the Council’s ability
to create, protect and sustain value by providing the Council and management with
independent, risk-based and objective assurance, advice, insight and foresight.
2.2 Internal Audit enhances the Council’s successful achievement of its objectives, its
decision making and oversight, and the governance, risk management and control
processes.  In doing so, Internal Audit contributes to the Council’s reputation and
credibility with its stakeholder and its ability to serve the public interest.
2.3 The Council’s Internal Audit function is most effective when:
• It is performed by competent professionals in conformance with the GIAS (UK
Public Sector).
• It is independently positioned with direct accountability to the Audit and Scrutiny
Panel.
• Internal Auditors are free from undue influence and committed to making
objective assessments.
2.4 Internal Audit assurance is provided by delivering an annual programme of audit work
that independently and objectively assesses the design and effectiveness of the
controls established to manage the Council’s most significant risks.  The scope of
Internal Audit covers all Council activities.
2.5 The CAE will report annually to the Audit and Scrutiny Panel and the Corporate
Management Team on the function’s conformance with the GIAS (UK Public Sector),
which will be assessed through a Quality Assurance and Improvement Programme
(QAIP).
2.6 In addition to their primary role, the CAE will also support the Council’s Chief
Executive, the Section 95 Officer and the statutory Monitoring Officer in undertaking
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their duties.  The CAE will also advise on the control implications of system or process
changes, assist management in their duties to prevent and detect fraud and
corruption, and aim to add value to the Council in all its undertakings. 
3. INTERNAL AUDIT MANDATE
3.1 The authority for Internal Audit is derived from the Local Authority Accounts (Scotland)
Regulations 2014.  This mandate sets out the authority, roles and responsibilities, and
empowers Internal Audit to provide the Audit and Scrutiny Panel and senior
management with independent, risk-based, and objective assurance, advice, insight
and foresight.  
3.2 Internal Audit’s authority is created by its direct reporting relationship to the Audit
and Scrutiny Panel.  Such authority allows for unrestricted access to the Audit and
Scrutiny Panel, and authorises Internal Audit to:
• Have full and unrestricted access to all functions, data, records, information,
physical property, and personnel pertinent to carrying out Internal Audit
responsibilities.
• Allocate resources, set frequencies, select subjects, determine scopes of work,
apply techniques and issue communications to accomplish Internal Audit’s
objectives.
• Obtain assistance from the necessary personnel of the Council, and services from
within or outside the Council to complete Internal Audit services.
3.3 Internal Auditors are accountable for confidentiality and safeguarding records and
information.  The GIAS set out the duty on Internal Auditors to be faithful custodians
of the information they gather, sharing only in limited, defined and controlled ways,
and describes the need for awareness of responsibilities in protecting information
and demonstrating respect for the confidentiality, privacy and ownership of
information.
3.4 In line with GIAS (UK Public Sector), Internal Auditors must also be aware of
circumstances under which sharing or publication of information will be required. 
They must be aware of their Council’s policies and procedures for routine publication
of certain information and where there are statutory obligations to share or publish
information (for example, Freedom of Information requests). 
4. DEFINITIONS
4.1 The following definitions have been adopted as set out in the GIAS 2024 Glossary:
• Internal Audit – an independent, objective assurance and advisory service
designed to add value and improve an organisation’s operations.  It helps an
organisation establish its objectives by bringing a systematic approach to evaluate
and improve the effectiveness of risk management, control and governance
processes.
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assessments to provide assurance.  The nature and scope of assurance services
are determined by Internal Audit.
• Advisory Services – Services through which Internal Auditors provide advice to
an organisation’s stakeholders without providing assurance or taking on
management responsibilities.  The nature and scope of advisory services are
subject to agreement with relevant stakeholders.
• Independence – Freedom from conditions that threaten the ability of the Internal
Audit activity to carry out Internal Audit responsibilities in an unbiased manner.
4.2 In addition, key roles within the Council are fulfilled as follows:
• Chief Audit Executive (CAE) is fulfilled by the Chief Officer (Audit and Risk).
• Chief Financial Officer (CFO), is the designated statutory Section 95 Officer and
is fulfilled by the Chief Officer (Finance and Technology).
• Senior Management, is fulfilled by the Council’s Chief Executive, the Corporate
Management Team (CMT) (for all-service approval) and the Business
Management Team (BMT) (in relation to oversight, monitoring and
implementation of outcomes of the annual plan).
• The role of the Board, is undertaken by the Audit and Scrutiny Panel. 
5. INDEPENDENCE, POSITION AND REPORTING RELATIONSHIPS
5.1 The GIAS state that the CAE should be positioned at a level in the Council that enables
Internal Audit services and responsibilities to be performed without interference from
management, thereby establishing the independence of the Internal Audit function.  
5.2 As CAE, the Chief Officer (Audit and Risk) reports functionally to the Audit and Scrutiny
Panel, administratively to the Chief Executive and is a member of the Corporate
Management Team.  This positioning provides the organisational authority and status
to bring matters directly to senior management and escalate matters to the Audit and
Scrutiny Panel, when necessary, without interference, and supports the Internal
Auditors’ ability to maintain objectivity.  
5.3 The CAE is required to confirm to the Audit and Scrutiny Panel, at least annually, the
organisational independence of Internal Audit.  If the governance structure does not
support organisational independence, the CAE must document the characteristics of
the governance structure limiting independence and any safeguards employed to
achieve the principle of independence.  The CAE must disclose to the Audit and
Scrutiny Panel any interference Internal Auditors encounter related to the scope,
performance or communication of Internal Audit work and results.  The disclosure will
include communicating the implications of such interference on Internal Audit’s
effectiveness and ability to fulfil its mandate.
5.4 To ensure that Internal Audit independence and objectivity is maintained for
assurance services, Internal Audit will remain free from interference from anyone
within the Council in relation to audit selection, scope, procedures, frequency, timing
and report content.
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5.5 Where Internal Audit also has responsibility for non-audit activities, the GIAS require
that appropriate arrangements are established to avoid conflicts of interest.  The CAE
has operational responsibility for the Council’s Risk Management team, and suitable
mitigations are in place to ensure the independence and robustness of future audits
of risk management. This involves the Audit Manager (who has no responsibility for
risk management) managing the whole audit process without input from the CAE, with
the CAE solely being the audit client. 
5.6 Additionally, Internal Audit will not be permitted to audit any activities for which they
have previously been responsible within a period of one year and will not engage in
any other activity that may impair judgement or independence.
5.7 For advisory (including critical friend services), the Internal Audit role will be
specifically restricted to providing guidance, views and opinions.  To comply with
independence requirements, Internal Audit will not be involved in any aspects of
operational decisions subsequently taken by management. 
6. INTERNAL AUDIT AUTHORITY AND OVERSIGHT
6.1 To establish, maintain and ensure that the Council’s Internal Audit function has
sufficient authority to fulfil its duties, the Audit and Scrutiny Panel will approve:
• The Internal Audit Charter, which includes the Internal Audit Mandate and scope
and types of Internal Audit Services.
• The risk-based annual Internal Audit plan.
6.2 The Internal Audit Charter will be updated on an annual basis to consider changes
affecting the Council, such as changes in the type, severity and interdependencies of
risk.  Following this, the Internal Audit Charter will be submitted to the Audit and
Scrutiny Panel for review and approval.
6.3 Additionally, the Audit and Scrutiny Panel will:
• Consider with the CAE and senior management, the appropriate authority, role,
responsibilities, scope and services (assurance and/or advisory) of the Internal
Audit function.
• Ensure the CAE has unrestricted access to, and communicates and interacts
directly with, the Audit and Scrutiny Panel, including in private meetings without
senior management present.
• Consider, with the CAE and senior management, any other topics that should be
included in the Internal Audit Charter.
• Participate in discussions with the CAE and senior management about the
‘essential conditions’ described in the GIAS which establish the foundation that
enables an effective Internal Audit function.
• Review the Internal Audit function’s budget and other resources.
• Provide input to senior management on the appointment and removal of the CAE,
ensuring adequate competencies and qualifications, and conformance with the
GIAS (UK Public Sector).
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• Review and provide input to senior management on the CAE’s performance.
• Receive communications from the CAE about the Internal Audit function,
including its performance relative to its plan.
• Ensure that a Quality Assurance and Improvement Programme (QAIP) has been
established and review the results annually.
• Make appropriate inquiries of senior management and the CAE to determine
whether scope or resource limitations are appropriate.
6.4 The Audit and Scrutiny Panel, CAE and senior management will ensure that Internal
Audit at all times:
• Has unrestricted access to all Council records, cash, property, assets and people,
where necessary on demand and without prior notice.
• Can obtain explanations as is required to satisfy the probity of any matter under
consideration.
• Can require the production of any records and other such property as is deemed
necessary.
6.5   All senior officers must report to the CAE at the earliest opportunity all actual or
perceived losses (cash, stock, equipment or data), all suspected or actual instances of
theft, embezzlement, fraud, corruption or any other impropriety.  This is set out in the
Council’s Corporate Fraud Policy. 
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7. INTERNAL AUDIT OBJECTIVES AND RESPONSIBILITIES
7.1 Ethics and Professionalism
The CAE will ensure that Internal Auditors:
• Conform with the GIAS (UK Public Sector) including the principles of Ethics and
Professionalism – integrity, objectivity, competency, due professional care,
confidentiality and the Seven Principles of Public Life.
• Understand, respect, meet and contribute to the legitimate and ethical
expectations of the Council, and can recognise conduct that is contrary to those
expectations.
• Encourage and promote an ethics-based culture in the Council.
• Report organisational behaviour that is inconsistent with the Council’s ethical
expectations, as described in applicable policies and procedures.
7.2 Objectivity
The CAE will ensure that the Internal Audit function remains free from all conditions
that threaten the ability of Internal Auditors to carry out their responsibilities in an
unbiased manner, including matters of engagement, selection, scope, procedures,
frequency, timing and communication.  If the CAE determines that objectivity may be
impaired in fact or appearance, the details of the impairment will be disclosed to
appropriate parties.
Internal Auditors will maintain an unbiased mental attitude that allows them to
perform engagements objectively such that they believe in their work product, do not
compromise quality and do not subordinate their judgement on audit matters to
others, either in fact or appearance.
Internal Auditors have no direct operational responsibility or authority over any of the
activities they review.  Accordingly, Internal Auditors will not implement internal
controls, develop procedures, install systems or engage in other activities that may
impair their judgement, including:
• Assessing specific operations for which they had responsibility in the previous
year.
• Performing operational duties for the Council or its affiliates.
• Initiating or approving transactions external to the Internal Audit function.
• Directing the activities of any employee that is not employed by the Internal Audit
function, except to the extent that such employees have been appropriately
assigned to Internal Audit teams or to assist Internal Auditors.
Internal Auditors will:
• Disclose impairments of independence or objectivity, in fact or appearance, to the
CAE as soon as possible.
• Exhibit professional objectivity in gathering, evaluating and communicating
information.
• Make balanced assessments of all available and relevant facts and circumstances.
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• Take necessary precautions to avoid conflicts of interest, bias and undue
influence.
The CAE will disclose impairments of independence or objectivity to the Audit and
Scrutiny Panel at least annually.
7.3 Managing the Internal Audit Function
The CAE has the responsibility to:
• At least annually, develop a risk-based Internal Audit plan that considers the input
of the Audit and Scrutiny Panel and senior management.
• Discuss the plan with the Audit and Scrutiny Panel and senior management and
submit the plan to the Audit and Scrutiny Panel for review and approval.
• Communicate the impact of resource limitations on the Internal Audit plan to the
Audit and Scrutiny Panel and senior management.
• Review and adjust the Internal Audit plan as necessary in response to changes in
the Council’s business, risks, operations, programmes, systems and controls.
• Communicate with the Audit and Scrutiny Panel and senior management if there
are significant interim changes to the plan.
• Ensure Internal Audit engagements are performed, documented and
communicated in accordance with the GIAS.
• Follow up on audit findings to confirm the implementation of significant
recommendations or action plans and communicate the results of Internal Audit
services to the Audit and Scutiny Panel and senior management.
• Ensure that the Internal Audit function collectively possesses or obtains the
knowledge, skills and other competencies and qualifications needed to meet the
requirements of the GIAS and fulfil the Internal Audit mandate.
• Identify and consider trends and emerging issues that could impact the Council
and communicate these to the Audit and Scrutiny Panel and senior management
as appropriate.
• Consider emerging trends and successful practices in internal auditing.
• Establish and ensure adherence to methodologies designed to guide the Internal
Audit function.
• Ensure adherence to the Council’s relevant policies and procedures unless such
policies and procedures conflict with the Internal Audit Charter or GIAS.  Any such
conflicts will be resolved or documented and communicated to the Audit and
Scrutiny Panel and senior management.
• Coordinate activities and consider relying upon the work of other internal and
external providers of assurance and advisory services.  If the CAE cannot achieve
an appropriate level of coordination, the issue must be communicated to senior
management and if necessary, escalated to the Audit and Scrutiny Panel.
7.4 Communication with the Audit and Scrutiny Panel and Senior Management
The CAE will report to the Audit and Scrutiny Panel and senior management on:
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• The Internal Audit function’s mandate.
• The Internal Audit plan and performance.
• Internal Audit resources.
• Significant revisions to the Internal Audit plan and resources.
• Potential impairments to independence, including relevant disclosures as
applicable.
• Results from the QAIP, which include the Internal Audit function’s conformance
with the GIAS (UK Public Sector) and action plans to address the Internal Audit
function’s deficiencies and opportunities for improvement.
• Significant risk exposures and control issues, including fraud risks, governance
issues and other areas of focus for the Audit and Scrutiny Panel that could
interfere with the achievement of the Council’s strategic objectives.
• Outcomes of assurance and advisory services.
• Management’s responses to risk that the Internal Audit function determines may
be unacceptable, or acceptance of a risk that is beyond the Council’s risk appetite. 
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8. MANAGEMENT RESPONSIBILITIES
8.1 Management will cooperate with Internal Audit on audits and provide access to
records, systems and personnel as required within a reasonable timeframe following
the request. 
8.2 Assurance engagements will be subject to a written terms of reference and report. 
Advisory and agile engagements will be agreed in writing (for example, via email or
written terms of reference) and a relevant output agreed (for example, full report,
summary findings, focussed feedback or an action plan). 
8.3 Draft reports will be shared with management for agreement as to the factual
accuracy of draft findings raised and understanding of Internal Audit
recommendations designed to address the control weaknesses identified.  The
opportunity to have a clearance meeting to discuss the findings will be offered to
management when issuing the draft report.
8.4 It is management’s responsibility to agree to either:
• Accept and fully implement all Internal Audit recommendations.
• Address the risks identified by adopting an alternative approach to that
recommended by Internal Audit.
• Accept the risk associated with not implementing Internal Audit
recommendations with supporting rationale.
8.5 When a draft report is delivered, management are required to agree to the
recommendations in the action plan, including specifying officer responsibility and
anticipated dates for implementation of the recommendations.  Internal Audit will
consider the timeliness of implementation dates according to the associated risk level
identified.
8.6 Management is responsible for ensuring that the agreed management actions are
implemented in full and effectively sustained.
8.7 The GIAS require the CAE to report to both senior management and the Audit and
Scrutiny Panel, details of management’s response to risk that (based on the CAE’s
judgement) may be unacceptable to the Council.  Consequently, any Internal Audit
findings where management has accepted the risk will be highlighted in the Internal
Audit reports. 
9. SCOPE AND TYPES OF INTERNAL AUDIT SERVICES
9.1 The scope of Internal Audit services covers the entire breadth of the Council’s services,
and includes all functions, activities, assets, data, projects and personnel. 
9.2 The scope of Internal Audit activities also encompasses, but is not limited to, objective
examinations of evidence to provide independent assurance and advisory services to
the Audit and Scrutiny Panel and management on the adequacy and effectiveness of
governance, risk management and control processes for the Council.  
9.3 The nature and scope of any advisory services will be agreed with the party requesting
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the service, provided that the Internal Audit function does not assume management
responsibility.  Opportunities for improving the efficiency of governance, risk
management and control processes may be identified during advisory engagements. 
These opportunities will be communicated to the appropriate level of management.
9.4 Internal Audit engagements may include evaluating whether:
• Risks relating to the achievement of the Council’s strategic objectives are
appropriately identified and managed.
• The actions of Council officers, Chief Officers, management, employees and
contractors (or other relevant parties) comply with the Council’s policies and
procedures, and applicable laws, regulations and governance standards.
• The results of operations, projects and programmes are consistent with
established goals and objectives.
• Operations, projects and programmes are being carried out effectively, efficiently,
ethically and equitably.
• Established processes and systems enable compliance with the policies,
procedures, laws and regulations that could significantly impact the Council.
• Fraud risks are being managed effectively.
• The integrity of information and the means used to identify, measure, analyse,
classify and report such information is reliable.
• Resources and assets are acquired economically, used efficiently and sustainably,
and protected adequately. 
10. INTERNAL AUDIT PLAN
10.1 The CAE will submit an annual Internal Audit Plan to the Audit and Scrutiny Panel for
review and approval, which is designed to support the provision of an evidence based
annual opinion.  The Plan will be developed using a risk-based methodology.  The CAE
will seek input from a range of key stakeholders including Elected Members, the Chief
Executive, senior management and the Corporate Risk Management team.
10.2 The nature of evolving risks makes it likely that the audit assignments included in the
Internal Audit Plan may be subject to change.  Consequently, the Internal Audit Plan
will be subject to regular review by the CAE and any proposed changes to the
approved plan (due to emerging risks, suspected fraudulent activity, or other issues
or factors that result in changes to the planned Internal Audit activities) will be
communicated to senior management and approved by the Audit and Scrutiny Panel.
10.3 The GIAS (UK Public Sector) requires the CAE to coordinate with internal and external
assurance providers to consider relying on their work and minimise duplication of
effort.
10.4 The GIAS (UK Public Sector) recognises that there are various relevant outside
assurance providers whose authority flows from separate legal or regulatory sources
beyond the control or influence by the CAE, and they may not have any ability to
access the work of those assurance providers or gain insight into the scope and timing
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of their work.  Under these circumstances, the CAE must consider whether it is
possible or practical to coordinate.     
10.5 Where adopted, a consistent process for the basis of reliance should be established
as, where reliance is placed on the work of others, the CAE remains accountable and
responsible for ensuring that there is adequate support for conclusion and opinions
reached where reliance has been placed on work performed by other assurance
providers.
10.6 Therefore, when dealing with an external party, Internal Audit will clearly define the
respective roles, responsibilities and other expectations (including restrictions on
distribution of results of the engagement and access to engagement records).
10.7 Internal Audit also reserves the right to raise findings on areas that have not been
specifically included in the Internal Audit Plan where significant or systematic control
gaps are evident. 
11. RESOURCING
11.1 The GIAS (UK Public Sector) requires the CAE to effectively deploy and manage
financial, human and technological resources to implement the Internal Audit
Strategy and achieve the Internal Audit Plan and Mandate.   The Application Note:
GIAS in the UK Public Sector notes that funding processes for Internal Audit
functions in the public sector vary and may prevent the CAE from being able to seek
or obtain additional funding due to other funding priorities within the Council.  This
may impact the way in which the CAE uses resources.  In line with the GIAS (UK Public
Sector) the basis for conformance is:
• Where there are constraints on resources, the CAE must develop a resource
strategy which suggests practical approaches for consideration by the Audit and
Scrutiny Panel.
• The CAE must inform the Audit and Scrutiny Panel of the impact of insufficient
resources and any options available to mitigate that impact.
• Where there are no constraints, the CAE must set out what alternative
approaches apply to the Internal Audit service and then seek to manage financial,
human and IT resources within those constraints.
11.2 The CAE must inform the Audit and Scrutiny Panel of any resource management
arrangements at the Council that may put at risk the ability of the Internal Audit
function to fulfil its mandate.
11.3 The Council’s Internal Audit Plan will include the budgeted resource requirements
needed to deliver the proposed audit engagements.  It will also include a contingency
to address unplanned work.  Should circumstances arise during the year that suggest
that available resource levels appear to be falling below the level required to deliver
the Internal Audit Plan, the CAE will communicate the impact of resource limitations
to senior management and the Audit and Scrutiny Panel. 
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12. PREVENTION AND DETECTION OF FRAUD AND CORRUPTION
12.1 Council management is responsible for the prevention and detection of fraud or
corruption.  Internal Audit will assist management in the discharge of this
responsibility.  Audit procedures alone, even when performed with due professional
care, cannot guarantee that fraud or corruption will be detected.  Internal Audit will
however exercise an appropriate level of professional scepticism during audit work
and be alert to risks and exposure that could allow the opportunity for fraud or
corruption to occur.
12.2 Managers, staff and elected members must always be alert to the risk of fraud, theft,
bribery and corruption.  Discovery of any suspected or actual fraud or irregularity that
affects the Council should be reported immediately to the CAE and information on
suspected or actual fraud may inform the annual audit opinion and the risk-based
Internal Audit Plan.  The CAE may then direct Internal Audit resources to investigate,
or assist management investigations, into suspected or actual cases.
12.3 The Council has a zero-tolerance attitude and will not accept any level of fraud, bribery
or corruption.  The Council’s Corporate Fraud Policy sets out clear procedures for
the reporting and investigation of actual or suspected fraud. 
13. FOLLOW-UP OF AUDIT RECOMMENDATIONS
13.1 Management is responsible for implementing audit recommendations with agreed
timescales.  Management should inform Internal Audit of the progress of
implementation and providing appropriate evidence to support closure of each
recommendation.  Internal Audit will review the evidence provided, and where
necessary may undertake proportionate reperformance testing to confirm that the
recommendations have been effectively implemented and sustained.
13.2 Internal Audit will report on the progress made by management in the
implementation of recommendations to each regular meeting of the Audit and
Scrutiny Panel.
13.3 Following initial agreement to implement a recommendation, management may
subsequently inform Internal Audit that the action cannot be implemented as agreed
and decide to accept the risk associated with the original audit finding. Management
should inform Internal Audit of the justification for this decision and detail any
mitigating actions and residual risks and monitor the ongoing risk through the
appropriate risk management process (for example, corporate or service risk
registers).  Internal Audit will note the recommendation as ‘Closed – Management
Accepts Risk’, and all risk acceptances will be reported to the Audit and Scrutiny Panel. 
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14. QUALITY ASSURANCE AND IMPROVEMENT PROGRAMME (QAIP)
14.1 The CAE is responsible for ensuring the quality of audit work and that the Internal
Audit function is continuously seeking improvement.  The GIAS (UK Public Sector)
defines quality as a combined measure of conformance with the GIAS and
achievement of the Internal Audit function’s performance objectives.
14.2 The CAE will develop, implement and maintain a Quality Assurance and Performance
Programme (QAIP) that covers all aspects of the Internal Audit function.  The QAIP will
include external and internal assessments of Internal Audit’s conformance with the
GIAS (UK Public Sector), as well as performance measurement to assess Internal
Audit’s progress towards achievement of its objectives and promotion of continuous
improvement.  If applicable, the assessment must include plans to address the
function’s deficiencies and opportunities for improvement.
14.3 The CAE will report annually to the Audit and Scrutiny Panel and senior management
on progress with the QAIP, including the results of internal assessments (ongoing
monitoring and periodic self-assessments) and external assessments.
14.4 External assessments will be conducted at least once every five years by a qualified,
independent assessor or assessment team from outside the Council, whose
qualifications must meet the requirements set out in the GIAS (UK Public Sector).  The
Council’s next external assessment is due to take place in late 2028.
14.5 Compliance with the CIPFA Code of Practice on the Governance of Internal Audit
in Local Government must also be reflected in internal and external quality
assessments. 
15. ANNUAL REPORTING AND OVERALL OPINION
15.1 In line with the GIAS (UK Public Sector) the CAE must, at least annually:
• Conclude on the overall adequacy and effectiveness of the Council’s framework
of governance, risk management and control (the Annual Internal Audit Opinion).
• Include a statement on conformance with the GIAS (UK Public Sector) and the
results of the QAIP.
15.2 The Internal Audit Annual Report and Opinion for the Council is based on the
outcomes of the audits included in the Internal Audit Plan, progress in addressing any
prior year significant issues, progress with the implementation of agreed audit actions
by management, the result of any other Internal Audit activities that have identified
control gaps exposing the Council to risk, and the professional judgement of the CAE. 
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16. COMMUNICATION AND REPORTING
16.1 The CAE will report regularly to the Audit and Scrutiny Panel on the progress with, and
the results of the work of Internal Audit, enabling review and scrutiny of the following
areas as required by GIAS.
REPORT FREQUENCY
Internal Audit Charter Annually
Internal Audit Strategy Annually
Annual Internal Audit Plan Annually
Internal Audit Progress Reports 
(including planned audits, other Internal Audit
activity and recommendation follow-up reports) 
Each meeting of
Audit and Scrutiny
Panel
Proposed material changes to the Annual Internal
Audit Plan
At least six-monthly
Internal Audit Annual Report and Opinion, including:
• Effectiveness of the governance, risk
management and control framework.
• Internal Audit independence.
• Conformance with the GIAS (UK Public Sector)
including ethics and professionalism
requirements.
Annually
Internal Quality Assessments
(including results of assessments, progress of
collective action points and compliance with the
CIPFA Code of Practice for the Governance of
Internal Audit in the UK)
Annually
External Quality Assessments At least every five
years
16.2 Progress against the work in the Internal Audit Plan, and the outputs of this work will
also be reported to appropriate meetings of the BMT and CMT. 
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17. APPROVAL AND CHANGES TO THE INTERNAL AUDIT MANDATE AND CHARTER
17.1  The Internal Audit Charter is subject to approval by the Chief Executive, Section 95
Officer and Audit and Scrutiny Panel on an annual basis.  Approval is evidenced
through the CMT and Audit and Scrutiny Panel meeting papers and minutes, and the
approval in Section 18 below.
17.2 Circumstances may justify a discussion between the CAE, the Audit and Scrutiny Panel
and senior management on the Internal Audit Mandate or other aspects of the
Internal Audit Charter.  Such circumstances may include but are not limited to:
• A significant change in the GIAS.
• A significant reorganisation within the Council.
• Significant changes in the CAE, the Audit and Scrutiny Panel and/or senior
management.
• Significant changes to the Council’s strategies, objectives, risk profile or the
environment in which the Council operates.
• New laws or regulations that may affect the nature and/or scope of Internal Audit
services. 
18 APPROVALS
Approved by the Audit and Scrutiny Panel  Date: 
Audit & Scrutiny Panel (minutes available) 14 May 2026
Approved by the Chief Executive Date: 
31 March 2026
Approved by the Chief Officer (Finance & Technology)
(Section 95 Officer)
Date: 
31 March 2026
Approved by the Chief Officer (Audit and Risk) Date: 
31 March 2026 
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North Lanarkshire Council
Report
Audit & Scrutiny Panel 
Does this report require to be approved? ☒ Yes   ☐ No
Ref    FS/ASP/Strategy2026 Date 14/05/26 
Internal Audit Strategy 
From  Francis Scott, Chief Officer (Audit and Risk)  
E-mail scottfr@northlan.gov.uk   
Executive Summary
The Internal Audit Strategy sets out the strategic objectives of the Council’s Internal Audit
section and how these will be delivered.
The purpose of this report is to seek endorsement of the attached Internal Audit Strategy
for 2026-27 to 2028-29 (at Appendix 1) which has recently been reviewed and revised to
conform with the Global Internal Audit Standards.  In updating the Strategy, consideration
has been given to how the Internal Audit team will operate going forward to best meet our
audit objectives.
Recommendations
The Audit and Scrutiny Panel is invited to approve the revised Internal Audit Strategy at
Appendix 1.
The Plan for North Lanarkshire
Priority  All priorities
Ambition statement All ambition statements
Programme of Work Statutory / corporate / service requirement
Item 8
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1. Background
1.1 The Internal Audit Strategy is a formal document that defines Internal Audit’s strategic
objectives and outlines how these will be achieved.
1.2 The most recent Internal Audit Strategy was approved by the Panel in November 2024. 
This report outlines the outcome of the most recent review and update of the Strategy
for 2026-27 to 2028-29 to ensure compliance with the Global Internal Audit Standards. 
2. Report
2.1 From 1 April 2025, Internal Audit teams across the UK are working to new mandatory
professional standards, replacing the previous Public Sector Internal Audit Standards
(PSIAS).  These standards will be a combination of:
• The Global Internal Audit Standards (GIAS).
• The Application Note “Global Internal Audit Standards in the UK Public Sector”.
• For Local Authorities, the Code of Practice on the Governance of Internal Audit. 
Together, these standards are referred to as the GIAS (UK Public Sector). 
2.2 Although the GIAS are now effective, Internal Audit teams are not expected to
demonstrate full compliance immediately but must work in accordance with the new
standards to build up their conformance, and progress against this will be presented to
future meetings of the Panel.    
2.3 The GIAS (UK Public Sector) requires that the Chief Officer (Audit and Risk) develops
and implements a strategy for the internal audit function that supports the strategic
objectives and success of the organisation and aligns with the expectations of the
Panel, senior management and other key stakeholders.  The revised Internal Audit
Strategy is included at Appendix 1.
2.4 Although the period covered by the Strategy is three years with the next version due
for approval in 2029, the Chief Officer (Audit and Risk) may decide to undertake a more
frequent review of the Strategy where there are changes in the Council’s strategic
objectives or stakeholders’ expectations.  All future revisions of the Strategy will be
presented to the Audit and Scrutiny Panel for approval. 
3. Measures of success
3.1 The Council is required to ensure that it has an effective internal audit function which
conforms with the GIAS.  Conformance is self-assessed on an annual basis, with an
independent external quality assessment being undertaken at least every five years.       
4. Supporting documentation
4.1 Appendix 1 – Internal Audit Strategy 
Francis Scott
Chief Officer (Audit and Risk) 
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5. Impacts 
5.1 Public Sector Equality Duty and Fairer Scotland Duty 
Does the report contain information that has an impact as a result of the Public
Sector Equality Duty and/or Fairer Scotland Duty? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact? 
If Yes, has an assessment been carried out and published on the council’s
website? https://www.northlanarkshire.gov.uk/your-community/equalities/equality-
and-fairer-scotland-duty-impact-assessments 
Yes ☐ No ☒
5.2 Financial impact 
Does the report contain any financial impacts? 
Yes ☐ No ☒ 
If Yes, have all relevant financial impacts been discussed and agreed with
Finance? 
Yes ☐ No ☐ 
If Yes, please provide a brief summary of the impact? 
5.3 HR policy impact 
Does the report contain any HR policy or procedure impacts? 
Yes ☐ No ☒ 
If Yes, have all relevant HR impacts been discussed and agreed with People
Resources? 
Yes ☐ No ☐ 
If Yes, please provide a brief summary of the impact? 
5.4 Legal impact 
Does the report contain any legal impacts (such as general legal matters, statutory
considerations (including employment law considerations), or new legislation)? 
Yes ☐ No ☒ 
If Yes, have all relevant legal impacts been discussed and agreed with Legal and
Democratic? 
Yes ☐ No ☐ 
If Yes, please provide a brief summary of the impact? 
5.5 Data protection impact 
Does the report / project / practice contain or involve the processing of personal
data?   
Yes ☐ No ☒ 
If Yes, is the processing of this personal data likely to result in a high risk to the
data subject? 
Yes ☐ No ☐ 
If Yes, has a Data Protection Impact Assessment (DPIA) been carried out and e-
mailed to dataprotection@northlan.gov.uk 
Yes ☐ No ☐  
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5.6 Technology / Digital impact 
Does the report contain information that has an impact on either technology, digital
transformation, service redesign / business change processes, data management,
or connectivity / broadband / Wi-Fi? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact? 
Where the impact identifies a requirement for significant technology change, has
an assessment been carried out (or is scheduled to be carried out) by the
Enterprise Architecture Governance Group (EAGG)? 
Yes ☐ No ☐
5.7 Environmental / Carbon impact 
Does the report / project / practice contain information that has an impact on any
environmental or carbon matters? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact? 
5.8 Communications impact 
Does the report contain any information that has an impact on the council’s
communications activities? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact? 
5.9 Risk impact 
Is there a risk impact? 
Yes ☒ No ☒ 
If Yes, please provide a brief summary of the key risks and potential impacts,
highlighting where the risk(s) are assessed and recorded (e.g. Corporate or
Service or Project Risk Registers), and how they are managed? 
5.10 Armed Forces Covenant Duty 
Does the report require to take due regard of the Armed Forces Covenant Duty (i.e.
does it relate to healthcare, housing, or education services for in-Service or ex-
Service personnel, or their families, or widow(er)s)? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the provision which has been made to
ensure there has been appropriate consideration of the particular needs of the
Armed Forces community to make sure that they do not face disadvantage
compared to other citizens in the provision of public services. 
5.11 Children’s rights and wellbeing impact 
Does the report contain any information regarding any council activity, service
delivery, policy, or plan that has an impact on children and young people up to the
age of 18, or on a specific group of these? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact and the provision that has
been made to ensure there has been appropriate consideration of the relevant
Articles from the United Nations Convention on the Rights of the Child (UNCRC). 
If Yes, has a Children’s Rights and Wellbeing Impact Assessment (CRWIA) been
carried out? 
Yes ☐ No ☐ 
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INTERNAL AUDIT
STRATEGY  
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Internal Audit Strategy 2026-2029 2
Document control
Title Internal Audit Strategy
Owner Francis Scott, Chief Officer (Audit and Risk) Contact scottfr@northlan.gov.uk
Governance Group Audit and Scrutiny Panel
Author Francis Scott, Chief Officer (Audit and Risk) Contact scottfr@northlan.gov.uk 
Revision History
Number Originator Date Review Commenced Revision description/record of change
1.0 Ken Adamson April 2018 Update and refresh of document 
Ken Adamson May 2019 Updated to recognise the ongoing
transformation and change within the Council 
Paula Hendry August 2024 Update and refresh of document 
Francis Scott March 2026 Update and refresh of document 
Document Approvals
Number Governance
Group
Date approval granted Date approval to be requested 
(if document still draft)
1.0 Audit and
Governance
Panel
February 2015 
2.0 Audit and
Scrutiny Panel
April 2018 
3.0 Audit and
Scrutiny Panel
June 2019 
4.0 Audit and
Scrutiny Panel
October 2024 
5.0 Audit and
Scrutiny Panel 
14 May 2026 
Consultation Record (for most recent update)
Status of document consulted upon N/A
Stakeholders consulted/date N/A 
Strategic Alignment
The Internal Audit Strategy is a formal document that sets out Internal Audit’s strategic objectives and outlines how these
will be delivered. 
Next review date
Review Date April 2029, then every 3 years thereafter
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Internal Audit Strategy 2026-2029  3
1. OUR AUDIT ENVIRONMENT
1.1 This document sets out the Internal Audit Strategy for 2026-27 to 2028-29.  This
remains a very uncertain and challenging time for the Council and the local
government sector generally and this strategy reflects how we intend to support the
Council’s senior management and elected members in responding to the challenges
facing the Council.
1.2 The Council’s strategic plan, The Plan for North Lanarkshire, and its associated
Programme of Work sets out the Council’s strategic ambitions and those key
activities designed to deliver against them and to address the challenges facing the
people and communities of North Lanarkshire.
1.3 The Council continues to seek to achieve its ambitions against a backdrop of
significant financial pressures, increasing demands for many key services and
ever-changing expectations about how services will be delivered.  These challenges
mean that the Council will continue to face difficult decisions around financial
sustainability and significant ongoing pressure to ensure that services are delivered
in a cost-effective manner.  The Council also needs to respond to the impacts on it
and its communities of a range of Scottish and UK Government policies.  Finally,
external events (such as the ongoing cost of living crisis, the subdued performance of
the UK and Scottish economies and the increase in geopolitical conflict) pose
immediate challenges to which the Council and create considerable additional longer
term risks and uncertainties.
1.4 Our audit environment continues to evolve at a rapid pace.  The Programme of Work
commits senior management to a challenging agenda which requires to be
underpinned by sound leadership, effective financial management and robust
governance arrangements.  These arrangements will require to be supported by
effective performance and risk management arrangements and an increased
emphasis on project and programme management, service redesign, contract
management, commissioning and contracting and maximising the benefits of new
digital technology and transformation.
1.5 The Council, therefore, faces significant challenges balancing the day-to-day delivery
of services with achieving its wider strategic priorities, while delivering efficiencies,
driving service improvements and managing and delivering large scale
transformational change.
1.6 In this context, the role of Internal Audit has never been more important.  Our
independence and commitment to high quality work will provide senior management
and the Audit and Scrutiny Panel with appropriate assurance and insights into the use
of public funds and on the adequacy and effectiveness of the Council’s corporate
governance, risk management and internal control arrangements.
1.7 Our vision is to ensure our work adds real value to senior management and elected
members as we focus on the issues of greatest priority and have the capacity and
resources to support accountability and drive corporate and service improvement. 
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Internal Audit Strategy 2026-2029  4
2. OUR STRATEGIC OBJECTIVES
2.1 In this environment, Internal Audit will need to continually reflect and evolve what it
does and how it does it in order to ensure that it can continue to operate efficiently
and effectively, demonstrate relevance and provide value to the Council. 
2.2 Our strategic aim is to provide a high quality and customer focused internal audit
service which is responsive, flexible and consistent with best professional practice. 
We aim to concentrate on key areas of significance, utilise resources in an efficient
and effective manner, and for Internal Audit to be seen by stakeholders as a value-
adding function, offering meaningful insights and making a dynamic and significant
contribution to the Council. We will do this by:
• Supporting elected members and senior management in undertaking their
respective roles by providing an independent, objective assurance and consulting
activity designed to add value and improve the effectiveness of the Council’s
operations.
• Delivering an internal audit service which fulfils the role and responsibilities given
to it formally by the Council as laid out in the Internal Audit Charter approved by
the Audit and Scrutiny Panel, the Chief Executive and the Council’s s95 officer.
• Providing an internal audit service consistent with best professional practice in
accordance with the Global Internal Audit Standards (GIAS), the associated
Application Note: GIAS in the UK Public Sector and the CIPFA Code of Practice
on the Governance of Internal Audit in Local Government.
• Driving improvements in the Council’s risk management, internal control,
governance and service delivery arrangements in order to make a positive
contribution to the overall management and operation of the Council.
• Focusing our resources on providing assurance on the management of the
Council’s core governance processes, strategic priorities and key corporate risks.
2.3     Sections 3 to 12 of this document highlight how we aim to deliver these objectives. 
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Internal Audit Strategy 2026-2029  5 
3. INDEPENDENCE, INTEGRITY AND OBJECTIVITY
3.1 Although Internal Audit is a service within the Council, independence, integrity and
objectivity are essential attributes for us, not only in complying with best professional
practice, but in ensuring that we can contribute most effectively to the Council’s
governance arrangements.  We greatly value our independence, integrity and
objectivity and are fully committed to demonstrating these attributes in all that we do. 
4. PROVIDING ASSURANCE AND ADDING VALUE
4.1 We will deliver our strategy through a range of assurance outputs for senior
management and the Audit and Scrutiny Panel focused on coverage of core corporate
governance processes, key strategic priorities and programmes of work, corporate
risks and key financial systems.
4.2 Our work will include in-depth assessments of how well key risks, priorities, projects
and programmes of work are being managed by examining and reporting on the
adequacy, efficiency and effectiveness of management arrangements.  
4.3 We will add value by highlighting scope for improvements and providing those we
audit with better insight into how they manage and use public money.
4.4 We will seek to contribute to the Council’s achievement of best value and value for
money by providing independent assurance and highlighting where scope for
improved efficiency may exist. 
5. STAKEHOLDER ENGAGEMENT
5.1 Recognising the importance of pro-active stakeholder engagement, we will continue
our approach in this area through our annual planning arrangements and the issue
and discussion of terms of references for each audit assignment.  Formal audit closure
meetings will continue with Chief Officers, to discuss findings, issues and
recommendations arising from each audit.  By collaborating in this way, we will
enhance audit effectiveness and foster a culture of transparency and trust.
5.2 We currently have a well-established planning methodology which includes
consideration of a wide range of factors such as the relative scale, significance and
complexity of systems; previous audit activity; horizon scanning; review of key
corporate risks and the controls in place to mitigate these; and possible impact of any
failures on the achievement of the Council’s objectives, priorities and ambitions.  We
will continue to evolve our approach to audit planning through improved stakeholder
engagement and collaboration.
5.3 A formal process of consultation with all Chief Officers will be undertaken as
preparation of the annual plan to consider potential areas of risk and uncertainty,
service developments or areas of concern more fully. 
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Internal Audit Strategy 2026-2029  6
6. SECURING INFLUENCE THROUGH CONSULTING AND AGILE AUDITING
6.1 We want Services to view Internal Audit as a valuable resource that can help them to
achieve corporate and service objectives.  We will seek, where appropriate and
without compromising our primary function and independence, to become involved
in relevant emerging issues or new systems or process development at an early stage
and to provide advice and guidance to prevent problems or weaknesses from arising,
and to ensure effective and efficient use of Council resources. 
6.2 We will continue to explore auditing with agility as a mechanism to ensure that we are
able to respond to the changing environment the Council is operating in and to
enhance and protect organisational value. 
7. SUPPORT FOR THE AUDIT AND SCRUTINY PANEL
7.1 We will develop an effective working relationship with the Convener of the Audit and
Scrutiny Panel to provide support for their role and help them shape the work of the
Panel.  We will seek to work closely with the Audit and Scrutiny Panel members to help
them discharge their duties and responsibilities and to respond more quickly to
emerging issues.  
7.2 We will support and provide assistance to the Audit and Scrutiny Panel to undertake
self-assessment against the CIPFA Position Statement on Audit Committees in
Local Government (2022) (and any future updates of this statement) and evaluate its
effectiveness in discharging its duties.  Aligned to this we will also facilitate the
development and delivery of a training programme based on needs identified by the
Panel. 
8. CORPORATE FRAUD ARRANGEMENTS
8.1 We will work with management to continually improve the Council’s corporate fraud
arrangements and to ensure that key fraud risks are identified and appropriately
managed.  This will include raising awareness of the Corporate Fraud Strategy.  
8.2 We will respond appropriately, and in a timely manner, to reports or disclosures of
alleged fraud brought to our attention by elected members, management and
members of the public, in accordance with the Corporate Fraud Strategy. 
9. MODERNISING THE INTERNAL AUDIT FUNCTION
9.1 We will continue to review the processes and methods used by the team to ensure
that they meet best professional practice and embrace modern auditing techniques.  
9.2 We will also explore the introduction of an audit management system, to improve
workflow and provide a more efficient method of recording the work of the team and
tracking progress with audit recommendations.
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Internal Audit Strategy 2026-2029  7
9.3 A key focus over the period of this Strategy will be to embed the use of data analytics
and AI within our processes and outputs to enhance our performance, and inform
and improve the quality of our findings and support to clients. 
10. RESOURCE REQUIREMENTS
10.1 Internal Audit services are expected to be fully provided by an in-house team during
the period covered by this strategy.  The Chief Officer (Audit and Risk) (as head of the
function) will continue to annually assess the level and capacity of internal audit
resources and will report to the Audit and Scrutiny Panel on the adequacy, or
otherwise, of the resources available to them. 
10.2 The current structure for the audit team and will be reviewed and monitored on an
ongoing basis to ensure it remains effective and provides the best possible level of
service.   
11. DEVELOPING OUR STAFF
11.1 The environment within which we and the Council are operating continues to change
and this will need to be reflected in our staff.  As well as investing in our core internal
audit skills, we will continue to enhance the range of other skills and abilities within
Internal Audit to allow us to focus our work on the key governance processes and
strategic risks and priorities faced by the Council.
11.2 Investing in our staff is critical to our success.  We want to embed a culture of
continuous learning and development, whereby we help our staff to keep their skills
at the desired level and develop the skills they need for the future.  To achieve this,
we will support our staff seeking further develop across relevant areas, including
technological and methodological skills, digital skills, sector and cross-government
knowledge and personal effectiveness skills.
11.3 The need for Internal Audit to adapt to the changing landscape while providing
‘business as usual’ assurance has been identified as a key development objective for
all internal audit teams.  With the increased focus on developing use of data analytics
and AI, we will ensure our staff are equipped with the skills and knowledge to embrace
these developments and embed them into the everyday work of the team.   
12. DELIVERING HIGH PERFORMANCE
12.1 We will measure the success of this Strategy through our performance management
framework (shown in Appendix 1).  We will also continue to challenge ourselves to
work as efficiently as possible by ensuring that our own use of resources is cost-
effective and to seek continuous improvements in our audit methodologies and other
internal processes.
12.2 Our most recent independent External Quality Assessment (EQA) of our compliance
with the Public Sector Internal Audit Standards (PSIAS) was reported in April 2024 and
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Internal Audit Strategy 2026-2029  8
confirmed we were fully compliant with all aspects of the detailed requirements of
PSIAS.  Some recommendations for continuous improvement were made and we
continue to work to fully address these. 
12.3 The PSIAS were replaced by the Global Internal Audit Standards (GIAS) in 2025 and
placed additional requirements on the internal audit team.  The first EQA to check
compliance with the GIAS is scheduled for 2028, and during the period of this Strategy
we will work toward ensuring full compliance. 
13. REVIEW OF THE STRATEGY
13.1 This Strategy document covers a three-year period until 2028-29 and is due for review
in April 2029 by the Chief Officer (Audit and Risk).
13.2 The Chief Officer (Audit and Risk) may decide to undertake a more frequent review of
the Strategy where there changes in the Council’s strategic objectives or stakeholders’
expectations.  Factors that may lead to this include :
• Significant Changes in the Council’s Plan for North Lanarkshire or the Programme
of Work.
• Changes to the maturity of the Council’s governance, risk management and control
processes.
• Changes to the Council’s policies and procedures, or laws and regulations which
the Council is subject to.
• Changes to the membership, role or function of the Audit and Scrutiny Panel.
• Changes to the senior management of the Council, including the Chief Officer
(Audit and Risk).
• Results of the internal and external assessments of the internal audit function.
13.3 Future revisions of this Strategy will be presented to the Audit and Scrutiny Panel for
approval.
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Internal Audit Strategy 2026-2029  9
APPENDIX 1 – INTERNAL AUDIT PERFORMANCE FRAMEWORK 
Category Measure
Reported to
Chief Executive/CMT A&SP (Quarterly) A&SP (Annual)
1. Delivery of Annual Plan Percentage completion of agreed plan X  X
2. Targeting Percentage of key corporate risks and key financial systems
over which assurance provided X  X
3. Efficiency Cost of Internal Audit per £ million revenue budget   X
4. Efficiency Percentage of productive hours delivered v Plan   X
5. Delivery /
recommendations
Percentage implementation of agreed actions by
implementation date (cumulative year to date) X X X
6. Delivery / other Number of significant investigations (fraud and irregularity) X  X
7. Customer satisfaction
results
Scores from customer satisfaction questionnaires (cumulative
year to date) X X X
8. Customer satisfaction
results
Scores from key stakeholders (CMT and A&SP) questionnaires
(overall performance of the function) X  X
9. Quality / standards Quality review outcomes – EQA and internal self-evaluation X  X
10. Delivery of Annual Report Annual opinion and report prepared by 31 May annually X  X
11. Targeting Approval by CMT and A&SP of Annual Internal Audit plan by
31 May annually X  X  
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North Lanarkshire Council
Report
Audit and Scrutiny Panel 
Does this report require to be approved? ☒ Yes   ☐ No
Ref FS/ASP/May26 Date 14/05/26 
Internal Audit Annual Plan 2026-27 
From:  Francis Scott, Chief Officer (Audit and Risk)
E-mail: scottfr@northlan.gov.uk 
Executive Summary
The purpose of this report is to present the proposed Internal Audit Plan 2026-27 to members
of the Audit and Scrutiny Panel for their consideration and approval.
The report sets out the background and context within which the internal audit planning
process is undertaken and provides a high-level overview of how it is proposed Internal Audit
resources will be allocated in 2026-27.
The Plan follows a well-established planning methodology which is designed to ensure
internal audit coverage of key corporate risks, priorities and projects, governance
arrangements and financial systems. 
Recommendations
The Panel is invited to approve the proposed Internal Audit Plan for 2026-27 (at Appendix 1). 
1. Background
1.1 The Global Internal Audit Standards in the UK Public Sector (GIAS (UK Public Sector))
require the Chief Officer (Audit and Risk) to submit an annual Internal Audit Plan to the
Audit and Scrutiny Panel for consideration and approval.  This report outlines the
proposed Internal Audit Plan for North Lanarkshire Council for 2026-27.   
The Plan for North Lanarkshire
Priority  All priorities
Ambition statement All ambition statements
Programme of Work Statutory / corporate / service requirement
Item 9
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2. Report
2.1 Internal Audit is an assurance function whose work is designed to evaluate and improve
the effectiveness of the Council’s risk management, control, and governance processes,
with the aim of providing an independent and objective opinion on the control
environment within the Council.  The annual Internal Audit Plan is designed to assist the
Chief Officer (Audit and Risk) in formulating that opinion.  
2.2 From the 1 April 2025, Internal Audit work is undertaken in accordance with the GIAS
(UK Public Sector). Conformance against these standards is self-assessed on an annual
basis, with an independent external quality assessment being undertaken every five
years.  The first external assessment of the Internal Audit function under the GIAS (UK
Public Sector) is scheduled for 2029.
2.3 The purpose, mandate, authority and principal responsibilities of the Council’s Internal
Audit function are set out in the Internal Audit Charter, which is approved by the Panel,
the Chief Executive and the Chief Officer (Finance and Technology), as the Council’s
Section 95 Officer.
2.4 As detailed in the Internal Audit Strategy, Internal Audit aims to provide a high quality
and customer-focused service, which is responsive and flexible, consistent with best
professional practice, focuses on areas that matter, uses resources efficiently and
effectively and is seen by stakeholders as adding value, providing valuable insights and
making a positive contribution to the Council’s activities.
2.5 Although Internal Audit is a service within the Council, it is operationally independent
which provides a core basis for its work.  Internal Audit’s ongoing independence and
objectivity also forms an important element in ensuring that it can effectively meet
stakeholders’ needs and expectations.  The post of Chief Officer (Audit and Risk) has
sufficient status within the organisation (being a member of both the Business
Management and Corporate Management Teams and reporting directly to the Chief
Executive) to ensure the continuing independence of the Internal Audit service and its
ability to act in accordance with best professional practice, free from undue interference
by management and Elected Members
The Wider Audit Environment
2.6 The Council’s strategic plan, The Plan for North Lanarkshire, and its associated
Programme of Work to 2028, sets out the Council’s strategic ambitions and the key
activities designed to deliver them, for the Council to address the challenges facing the
people and communities of North Lanarkshire.
2.7 The Council continues to seek to achieve its ambitions against a backdrop of significant
financial pressures, increasing demands for many key services and ever-changing
expectations about how services will be delivered.  The Council also needs to respond
to the impacts on it and its communities of a range of Scottish and UK Government
policies.  There also continues to be significant change in governance structures and
processes across the Council.  Finally, external events, such as the ongoing cost-of-
living crisis, the performance of the UK and Scottish economies and ongoing geopolitical
destabilisation, pose immediate challenges to the Council and also create considerable
additional longer-term risks and uncertainties. 
Planning Considerations
2.8 In developing the Internal Audit Plan, a wide range of factors were considered including
the relative scale, significance and complexity of systems, previous experience of the
relevant control environments, the potential financial, operational and reputational
consequences of any significant failures in relevant internal controls and the possible
impact of any failures on the achievement of the Council’s objectives, priorities and
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ambitions.
2.9 The Chief Officer (Audit and Risk) also held discussions with the Chief Officers
responsible for each Council Service, to understand the challenges and risks faced in
delivering their services, recent or proposed changes to the operating environment and
any areas across the Council where they felt additional assurance would be required. 
Although senior management were consulted in the development of the plan, the Chief
Officer (Audit and Risk) is solely responsible for determining the content of the Internal
Audit Plan.
2.10 The Plan takes account of the key risks identified by senior management for inclusion on
the Corporate Risk Register, and consideration is also taken of assurance available from
other sources (such as external regulators and selected high-quality relevant internal
sources).
2.11 Internal Audit will continue to work closely with Audit Scotland, the Council’s appointed
external auditors, to ensure that all audit activities are properly coordinated to minimise
any duplication of work. 
Resources
2.12 In 2026-27, approximately 1,130 audit days will be available to undertake the work
included in the Internal Audit Plan.  This allocation is based on a funded budget of 6.5
FTE members of Internal Audit staff and assumes the successful recruitment of the
current vacant auditor position early in 2026/27.  This budget is broadly consistent with
the total audit days in the prior year.
2.13 I am satisfied that the resources available are adequate for the Internal Audit team to
carry out its role effectively.  Should there be a change to these resources during the
year which will impact the completion of the plan, this will be discussed initially with the
Convener and, if necessary, highlighted at the next Panel meeting.
Internal Audit Reporting
2.14 The Internal Audit Plan shows the outputs which members and Chief Officers can expect
from Internal Audit during 2026-27.  Each Internal Audit report will be issued to the
relevant Chief Officer and copied to the Chief Executive and Depute Chief Executive,
highlighting any control weaknesses together with recommendations for improvement. 
Reports on the work of Internal Audit will also be presented regularly during the year to
the Council’s Business and Corporate Management Teams.
2.15 Internal Audit will report progress against the plan during 2026-27 to the Audit and
Scrutiny Panel.  Progress reports will include high-level summary of all audit outputs in
the plan, with full copies of all reports being made available to the Panel.  Where the
Chief Officer (Audit and Risk) considers there are significant matters arising from an audit
report, these will be brought to the Panel’s attention in appropriate detail.  
2.16 The main output of Internal Audit in 2026-27 will be the Internal Audit Annual Report
prepared by the Chief Officer (Audit and Risk), which will include an opinion on the
adequacy and effectiveness of the Council’s control environment.  This report is used to
inform the Council’s Annual Governance Statement which is incorporated into the
Council’s financial statements.   The Internal Audit Annual Report and opinion in relation
to 2026-27 will be presented to the Panel in June 2027.
Categories of Work in the 2026-27 Internal Audit Plan
2.17 The proposed Internal Audit Plan for 2025-26 is detailed at Appendix 1, with reference
to entries on the Corporate Risk Register where appropriate.  There are three major
categories of work within the Annual Plan.  These include:
• Key Strategic/Corporate Risks – including work on procurement, resilience
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planning, climate change, cyber security, the housing repairs contract and project
management.
• Financial Management and Key Financial Systems – including work on treasury
management, Council Tax, creditors and debt recovery.
• Service/Operational/Programmes of Work – including developer contributions,
kinship care payments, IT applications, IR35 arrangements, succession to tenancy,
contract and supplier management, school excursions and education establishment
visits.
2.18 The Internal Audit team will continue to support services to ensure management
implement the recommendations arising from audit reports.  Quarterly updates on
management’s progress in implementing High and Medium priority recommendations
will be provided to the Panel.
2.19 The Internal Audit team will also continue to contribute to a wide range of corporate
working groups and Project Boards and be available to provide ad hoc advice and
guidance to Council services and officers.  The team will also provide an internal audit
service to the North Lanarkshire Health and Social Care Integrated Joint Board.
2.20 The GIAS (UK Public Sector) requires that the Internal Audit Plan be kept under review
to reflect any changing priorities and emerging risks relating to the Council’s business,
operations, programmes, systems, and controls.  We will therefore ensure the Plan
remains relevant and reflects any changes to the inherent risks in the Council.  The Audit
and Scrutiny Panel will be advised of any material changes to the Internal Audit Plan
during the year. 
3. Measures of success
3.1 Provision of independent assurance in accordance with the GIAS (UK Public Sector).
3.2 Completion of the planned audit work within 2026-27, in order to provide an annual
opinion on the Council’s control environment.
3.3 Positive assessment of the work of Internal Audit by key stakeholders including senior
management and members of the Audit and Scrutiny Panel. 
4. Supporting Documents
Appendix 1 Proposed Internal Audit Plan 2026-27 
Francis Scott
Chief Officer (Audit and Risk)   
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5. Impacts 
5.1 Public Sector Equality Duty and Fairer Scotland Duty
Does the report contain information that has an impact as a result of the Public Sector Equality Duty
and/or Fairer Scotland Duty?
Yes ☐ No ☒
5.2 Financial impact
Does the report contain any financial impacts?
Yes ☐ No ☒
5.3 HR policy impact 
Does the report contain any HR policy or procedure impacts?
Yes ☐ No ☒
5.4 Legal impact
Does the report contain any legal impacts (such as general legal matters, statutory considerations
(including employment law considerations), or new legislation)?
Yes ☐ No ☒
5.5 Data protection impact 
Does the report / project / practice contain or involve the processing of personal data?  
Yes ☐ No ☒
5.6 Technology / Digital impact
Does the report contain information that has an impact on either technology, digital transformation,
service redesign / business change processes, data management, or connectivity / broadband / Wi-
Fi?
Yes ☐ No ☒
5.7 Environmental / Carbon impact
Does the report / project / practice contain information that has an impact on any environmental or
carbon matters?
Yes ☐ No ☒
5.8 Communications impact
Does the report contain any information that has an impact on the council’s communications
activities?
Yes ☐ No ☒
5.9 Risk impact
Is there a risk impact?
Yes ☒ No ☐
Internal Audit forms part of the control framework for the management of several corporate risks
relating to corporate governance issues and these are documented in the relevant corporate risk
‘deep dive’ documents which are subject to periodic review by management.  Operational risks for
the Service itself are documented in the Service’s risk register and are regularly reviewed by the
Chief Officer (Audit and Risk) and the service management team.
5.10 Armed Forces Covenant Duty
Does the report require to take due regard of the Armed Forces Covenant Duty (i.e. does it relate
to healthcare, housing, or education services for in-Service or ex-Service personnel, or their
families, or widow(er)s)?
Yes              ☐                      No            ☒
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5.11      Children’s rights and wellbeing impact
Does the report contain any information regarding any council activity, service delivery, policy, or
plan that has an impact on children and young people up to the age of 18, or on a specific group
of these?
Yes ☐         No ☒ 
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APPENDIX 1 – Internal Audit Plan 2026-27
AUDIT CATEGORY AUDIT SERVICE AREA INDICATIVE
DAYS LINK TO CORPORATE RISK REGISTER
Key Strategic/
Corporate Risks
Cyber Security Legal, Democratic &
Strategy 25 Cyber Security
Housing Contract Housing & Communities 30 Enterprise Contract Management
Climate Change Assets & Procurement 25 Climate Change
Resilience Planning Corporate Review 25 Failure of the Council’s Resilience Planning
Procurement – Demolition Framework Housing & Communities 25 Procurement Risk
Procurement – Education Non-Contract
Spend Education 25 Procurement Risk
Procurement – Below Threshold Spend Corporate Review 25 Procurement Risk
Project Management (25/26) Corporate Review 25 Governance, Leadership & Decision Making
Financial Management
& Key Financial
Systems
Treasury Management Finance & Technology 20 Financial Sustainability
Creditors – Purchase 2 Pay Finance & Technology
Assets & Procurement 30 n/a
Council Tax – Discounts and Exemptions Finance & Technology 25 Financial Sustainability
Council Tax – Second Empty Homes
Premium
Finance & Technology 20 Financial Sustainability
Debt Recovery (25/26) Finance & Technology 20 n/a
Service/Operational/
Programmes of Work
IR35 Arrangements Corporate Review 30 n/a
Education Establishment Visits Education 25 Health & Safety
Education Leavers Process Education 25 Human Resources
Succession to Tenancy Housing & Communities 25 n/a
Subject Access Requests Legal, Democratic &
Strategy 20 Information Governance
Freedom of Information process Legal, Democratic &
Strategy 20 Information Governance
Developer Contributions Place 30 n/a
School Excursions Education 30 Improving Educational Outcomes
Contract & Supplier Management Corporate Review 30 Delivery of Approved Programme of Work
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APPENDIX 1 – Internal Audit Plan 2026-27 
AUDIT CATEGORY AUDIT SERVICE AREA INDICATIVE
DAYS LINK TO CORPORATE RISK REGISTER
Kinship Care Payments Education, Families, Justice
& Integrated Practice 30 n/a
Safeguarding Corporate Review 30 Public Protection
IT Application Audit Corporate Review 30 ICT Operational Capacity
Contribution to Good
Governance
Participation in Corporate Working
Groups Corporate Review 40 Governance, Leadership & Decision Making
Ad hoc advice to services Corporate Review 40 Governance, Leadership & Decision Making
Fraud & Irregularity
Corporate Fraud Awareness n/a 15 Serious Organised Crime, Fraud & Corruption
National Fraud Initiative n/a 30 Serious Organised Crime, Fraud & Corruption
Allowance for fraud and irregularity
investigations n/a 70 Serious Organised Crime, Fraud & Corruption
Audit Committee/
External Audit
Facilitating work of Audit & Scrutiny Panel n/a 30 Governance, Leadership & Decision Making
Follow-up of IA and EA recommendations n/a 50 n/a
Follow-up - Audit Scotland/Accounts
Commission National Reports n/a 10 n/a
Liaison with External Audit n/a 5 n/a
Provision of Internal
Audit to Third Parties
North Lanarkshire Integrated Joint Board
(IJB) n/a 30 n/a
Other
GIAS (UK Public Sector) –
implementation and self-assessment n/a 30 Governance, Leadership & Decision Making
Recruitment n/a 10 n/a
Flexible Capacity n/a 75 n/a
Contingency n/a 50 n/a
TOTAL INDICATIVE AUDIT DAYS 1,130 
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North Lanarkshire Council
Report
Audit and Scrutiny Panel 
Does this report require to be approved? ☐ Yes   ☒ No
Ref   FS/ASP/RMMay 26 Date 14/05/26 
Risk Management Update 
From  Francis Scott, Chief Officer (Audit and Risk)  
E-mail ScottFr@northlan.gov.uk   
Executive Summary
This report seeks to support the Audit and Scrutiny Panel in the discharge of the aspect of
its remit of monitoring the effective development and operation of risk management in the
Council. 
The report provides an overview the Corporate Risk Register (CRR) and developments on
Corporate Risks since the February update. The report also includes a high-level overview
of Horizon Scanning activity, the product of which will be used to inform deliberation on
entries on CRR and Service Risk Registers (SRR).  The report concludes with a summary
of other risk management developments and the key considerations of the Risk
Management Corporate Working Group (RMCWG) within the reporting period.  
Recommendations
The Panel is asked to consider the contents of the report and note: 
(1) the CRR for 2025-26 as detailed in Appendix 1.
(2) the changes to corporate risk assessments in sections 2.2 – 2.6.
(3) the Horizon Scanning information detailed in sections 2.7 – 2.8 and Appendix 2.
(4) the summary of other risk management developments as noted is sections 2.9 –
2.12. 
The Plan for North Lanarkshire
Priority  All priorities
Ambition statement All ambition statements
Programme of Work Statutory / corporate / service requirement
Item 10
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1. Background 
1.1 The Audit and Scrutiny Panel terms of reference include the remit to monitor the
effective development and operation of risk management in the Council. This report
supports the Panel in discharging that aspect of its remit by providing an overview of
how certain requirements of the Risk Management Strategy have been delivered during
the reporting period. 
2. Report 
Corporate Risk Register 2025-26 
2.1 The CRR for 2025-26 is included at Appendix 1. This version includes any changes
captured since the update to Panel in February.  Risks on the CRR are subject to
ongoing monitoring and review, with higher scoring risks being subject to more frequent
review.  Management considers factors such as changes in the operating environment,
the effectiveness of existing controls, the development of additional controls and
progress of agreed actions to determine whether it would be appropriate to adjust the
risk assessment in line with the Risk Management Strategy. 
Changes to Corporate Risk Assessments 
2.2 There have been no changes to corporate risk assessments or scoring since the
previous update to the Panel in February. During the reporting period, 19 risks were
reviewed, with controls and actions updated to reflect current management activity.
Additional controls were introduced where necessary to reflect enhanced risk
mitigation. 
2.3 The Power resilience (Black Start) risk has been retitled as National Power Outage
and Recovery to more accurately reflect the risk context of a national power outage
event and the Council’s response and recovery. 
2.4 Due to recent leadership changes, ownership of the Digital Adoption has been
updated, with the risk owner now being the chair of the Digital Culture, Leadership and
Knowledge sub-group (currently the Chief Officer (Housing and Communities)).
Ownership of other corporate risks is under review and communication of further
changes will be provided at the next update to the panel. 
2.5 In the February update, the newly developed Information Governance risk was
incorrectly reported with a risk score of 20 due to a typing error. The risk score is and
has always been 16, with a likelihood rating of 4 and impact rating of 4. This has been
amended in the CRR table included in Appendix 1. 
Horizon Scanning 
2.6 The Corporate Risk Team undertakes an annual Horizon Scanning exercise to inform
deliberations on matters for inclusion on the CRR and SRRs.  The main source of
information used in this year’s exercise in the World Economic Forum’s Global Risks
Report 2026.  The report is underpinned by the Global Risks Perception Survey
(GRPS) which captures views on the risk landscape from a range of stakeholders.  Our
analysis narrows in on the responses from government stakeholders with a focus on
the risks perceived as having at the most impact over the short term (2 years) and over
the long term (10 years).   
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2.7 Based on the information in the report, Appendix 2 presents the top 10 risks as
perceived by government respondents in the short and long term.  These are listed
alongside the results from all stakeholder groups for comparative purposes.  
This information will be shared with colleagues internally and will inform our next review
of the CRR.   
Other Risk Management Developments 
2.8 The RMCWG co-ordinates activities and resources to implement the Risk Management
Strategy and promote good risk management practice throughout the Council. There
were two sessions of the RMCWG since the last report to Panel, with the notable
discussion points noted below: 
2.9 The RMCWG has continued to support risk management training and awareness
across the risk network. 
• Mandatory internal training, acting on feedback to develop service specific
examples.  All service examples have now been drafted and are at approval stage
before being added to the online training system NL Learn. 
• Support has been provided to new Risk Facilitators by providing training on the
corporate risk management information system Figtree. 
• Introduction of Horizon Scanning guidance materials to Risk Champions and
Facilitators to assist with horizon scanning exercises at service level. 
2.10 Following recent leadership and structure changes in the Strategy and Engagement
function within the Chief Executive’s Service, some service level risks have been
reassigned across the service risk registers.   
• Community Partnership risks have been moved from the Chief Executive’s
service risk register to the Enterprise and Communities risk register, reported
under Housing and Communities. 
• Strategy and Customer Experience risks have remained on the Chief Executive’s
service risk register, but are now reported under Legal, Democratic and Strategy.   
2.11 The revised 2026-29 Risk Management Strategy was approved at the Policy and
Strategy Committee in March and has now been published. The new strategy includes
changes in response to recent internal audit recommendations, and several key
development initiatives which will further strengthen risk management arrangements. 
3. Measures of success 
3.1  The Corporate Risk Team will continue to report quarterly to BMT and the Audit and
Scrutiny Panel, providing an overview of key developments in risk management and
updating on progress in respect of planned improvements to the Council’s risk
management arrangements. 
3.2 The adequacy and effectiveness of the Council’s risk management arrangements will
be subject to independent review by Internal Audit, who will report directly on the results
of that work to the Audit and Scrutiny Panel. 
3.3 Effective risk management arrangements assist the Council in achieving planned
outcomes and/or help the Council mitigate the impacts of adverse events.   
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4. Supporting documentation 
Appendix 1: Corporate Risk Register 2025-26
Appendix 2: Horizon Scanning Summary 
Francis Scott
Chief Officer (Audit and Risk) 
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5. Impacts 
5.1 Public Sector Equality Duty and Fairer Scotland Duty
Does the report contain information that has an impact because of the Public Sector Equality
Duty and/or Fairer Scotland Duty?
Yes ☐ No ☒
5.2 Financial impact
Does the report contain any financial impacts?
Yes ☐ No ☒
5.3 HR policy impact 
Does the report contain any HR policy or procedure impacts?
Yes ☐ No ☒
5.4 Legal impact
Does the report contain any legal impacts (such as general legal matters, statutory
considerations (including employment law considerations), or new legislation)?
Yes ☐ No ☒
5.5 Data protection impact 
Does the report / project / practice contain or involve the processing of personal data?  
Yes ☐ No ☒
5.6 Technology / Digital impact
Does the report contain information that has an impact on either technology, digital
transformation, service redesign / business change processes, data management, or
connectivity / broadband / Wi-Fi?
Yes ☐ No ☒
5.7 Environmental / Carbon impact
Does the report / project / practice contain information that has an impact on any
environmental or carbon matters?
Yes ☐ No ☒
5.8 Communications impact
Does the report contain any information that has an impact on the council’s communications
activities?
Yes ☐ No ☒
5.9 Risk impact
Is there a risk impact?
Yes ☒ No ☐
If yes, please provide a summary of the key risks and potential impacts, highlighting where
the risk(s) are assessed and recorded (e.g. Corporate or Service or Project Risk Registers),
and how they are managed?
Effective risk management arrangements will enable the Council to manage its risks more
effectively, increasing the likelihood of the Council achieving its plans and ambitions by
minimising or mitigating potential threats to planned outcomes.  A robust risk management
strategy lays out the framework and underpins all risk management activity across the
organisation.
5.10 Armed Forces Covenant Duty
Does the report require to take due regard of the Armed Forces Covenant Duty (i.e. does it
relate to healthcare, housing, or education services for in-Service or ex-Service personnel, or
their families, or widow(er)s)?
Yes    ☐                No ☒
5.11      Children’s rights and wellbeing impact
Does the report contain any information regarding any council activity, service delivery, policy,
or plan that has an impact on children and young people up to the age of 18, or on a specific
group of these?
Yes ☐         No ☒ 
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Appendix 1 – Corporate Risk Register 2025-26 
CORPORATE RISKS (Operational) Likelihood Impact Rating Evaluation Change
1. Cyber Security 4 5 20 High No
2. Home support  4 5 20 High No
3. ICT operational capability   5 4 20 High No
4. Information governance 4 4 16 High No
5. Human resources (workforce planning) 4 4 16 High No
6. Public protection 4 4 16 High No
7. Health and Safety 5 3 15 Medium No
8. Business continuity planning 5 3 15 Medium No
9. Terrorism 3 5 15 Medium No
10. Information Security 4 3 12 Medium No
11. Governance, leadership and decision-making 3 4 12 Medium No
12. Procurement risk 3 4 12 Medium No
13. RAAC 3 4 12 Medium No
14. Failure of Council’s Resilience Planning
Arrangements 2 5 10 Medium No
15. Enterprise Contract Management  2 5 10 Medium No
16. Serious organised crime, fraud and corruption  3 3 9 Medium No
CORPORATE RISKS (Strategic) Likelihood Impact Rating Evaluation Change
17. Tackling poverty 5 4 20 High No
18. National Power Outage and Recovery 4 5 20 High Risk title
updated
19. Digital adoption 4 4 16 High No
20. Improving educational outcomes 4 4 16 High No
21. Financial sustainability 3 5 15 Medium No
22. Digital and IT strategy 4 3 12 Medium No
23. Climate change 3 4 12 High No
24. Engagement and consultation 3 3 9 Medium No
25. Delivery of approved programme of work  2 4 8 Low No
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Appendix 2 – Horizon Scanning Summary (Source: World Economic Forum. The Global Risks Report 2026) 
* Numbers represent stakeholder ranking of likely impact (severity) of risks in the relevant timeframe, 1 = most severe   
Government  All
Risk Short
term (2
Years)
Long
term (10
years) 
Short
term (2
Years)
Long
term (10
years)
Geoeconomic confrontation (sanctions, tariffs, investment screening)
Deployment of economic levers by global or regional powers to reshape economic interactions
between nations, restricting goods, knowledge, services or technology with the intent of
building self-sufficiency, constraining geopolitical rivals and/or consolidating spheres of
influence. Includes, but is not limited to: currency measures; investment controls; sanctions;
state aid and subsidies; and trade controls.
1   1 
Misinformation and disinformation
Persistent false information (deliberate or otherwise) widely spread through media networks,
shifting public opinion in a significant way towards distrust in facts and authority. Includes, but
is not limited to: false, imposter, manipulated and fabricated content.
2 5  2 4
Societal polarization
Present or perceived ideological and cultural divisions within and across communities leading
to declining social stability; gridlocks in decision-making; economic disruption; and increased
political polarization.
3 9  3 9
State-based armed conflict (hot wars, proxy, civil wars, coups, terrorism, etc.)
Bilateral or multilateral use of force between states and/or between a state and non-state
actor(s), often with ideological, political or religious goals, manifesting hot war and/or
organized, sustained violence. Includes, but is not limited to: hot wars; proxy wars; civil wars;
guerilla warfare; terrorism; genocide; and assassinations.
4   5 
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Government  All
Risk Short
term (2
Years)
Long
term (10
years) 
Short
term (2
Years)
Long
term (10
years)
Cyber Insecurity 
The state of vulnerability in digital systems, either accidental or deliberate in nature, that can
be exploited by cybercriminal or malicious actors. Includes, but is not limited to: cybercrime
(including ransomware, data theft and online fraud) and exploitation by cybercriminals or
malicious actors to interfere with government operations, conduct espionage and impact
national security.
5 8  6 8
Inequality (wealth, income)
Present or perceived substantive disparities in the distribution of assets, wealth or income
within or between countries, resulting in material differences in related economic outcomes.
Includes, but is not limited to: growing or persistent poverty; and economic polarization.
6 7  7 7
Extreme weather events (floods, heatwaves, etc.)
Loss of human life, damage to ecosystems, destruction of property and/or financial loss due to
extreme weather events. Includes, but is not limited to: land-based (e.g. wildfires), water-
based (e.g. floods) and atmospheric and temperature-related (e.g. heatwaves) events,
including those exacerbated by climate change
7 1  4 1
Pollution (air, soil, water, etc.)
Introduction of harmful materials into the air, water and soil stemming from human activity,
resulting in impacts to and loss of human life, financial loss and/or damage to ecosystems.
Includes, but is not limited to: household and industrial activities; environmental accidents
such as oil spills; and radioactive contamination. 
8   9 10
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Government  All
Risk Short
term (2
Years)
Long
term (10
years) 
Short
term (2
Years)
Long
term (10
years)
Economic Downturn (recession, stagnation) 
Near-zero or slow global growth lasting for several years or a global contraction (recession or
depression).
9    
Erosion of human rights and/or civic freedoms
Loss of protections for rights inherent to all human beings, regardless of individual status,
and/or the freedoms that underpin civic space. Includes, but is not limited to the right to: life
and liberty; work and education; freedom of expression; peaceful assembly; non-
discrimination based on gender, race ethnicity and other characteristics; and privacy. 
10   8 
Involuntary migration or displacement
Forced movement or displacement across or within borders. Stemming from, but not limited to:
persistent discrimination and persecution; lack of economic advancement opportunities;
human-made disasters; natural disasters and extreme weather events, including the impacts
of climate change; and internal or interstate conflict. 
10 
Biodiversity loss and ecosystem collapse
Severe consequences for the environment, humankind and economic activity due to
destruction of natural capital stemming from a result of species extinction or reduction,
spanning both terrestrial and marine ecosystems. 
2   2
Critical change to Earth systems 
Long-term, potentially irreversible and self-perpetuating changes to critical planetary systems,
as a result of breaching a critical climatic or ecological threshold or “tipping point”, at a 
3   3
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Government  All
Risk Short
term (2
Years)
Long
term (10
years) 
Short
term (2
Years)
Long
term (10
years)
regional or global level. Includes, but is not limited to: sea level rise from collapsing ice sheets;
carbon release from thawing permafrost; and disruption of ocean or atmospheric currents.
Adverse outcomes of AI technologies
Intended or unintended negative consequences of advances in AI and related technological
capabilities (including generative AI) on individuals, businesses, ecosystems and/or
economies. 
4   5
Natural resource shortages (food, water)
Supply shortages of food or water for human, industry or ecosystem use, manifesting as food
and water insecurity at a local, regional or global level. Stemming from, but not limited to:
human overexploitation and mismanagement of critical natural resources; climate change
(including drought and desertification); and/or a lack of suitable infrastructure. 
6   6
Concentration of strategic resources and technologies
Concentration of strategically important resources (minerals, materials, technologies) among a
small number of individuals, businesses or states that can control access and dictate
discretionary pricing. 
10   
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North Lanarkshire Council Report 
Audit and Scrutiny Panel 
Does this report require to be approved? ☐ Yes   ☒ No
Ref    FS/RMS/ASP/May26 Date 14/05/26 
Risk Management Strategy 
From  Francis Scott, Chief Officer (Audit and Risk)  
E-mail scottfr@northlan.gov.uk       
Executive Summary 
The purpose of this report is to present the revised Risk Management Strategy to the Panel
for noting, following approval of the document at the Policy and Strategy Committee in
March 2026. 
The Council’s Risk Management Strategy sets out a clear direction for how the Council will
develop its risk management arrangements to support achievement of the Council’s
objectives and The Plan for North Lanarkshire.     
Effective risk management arrangements form an important element of good corporate
governance and are designed to ensure that the Council operates systematic and logical
processes for managing uncertainty within a comprehensive framework, ensuring that
identified risks are managed consistently, effectively, efficiently and coherently across the
Council.   
The Audit and Scrutiny Panel has oversight of the Council’s risk management
arrangements and receives regular reports on risk management issues and changes to
corporate and service risk registers. 
Recommendation
It is recommended that the Audit and Scrutiny Panel note the revised Risk Management
Strategy (at Appendix 1), and the continuing role of the Panel in providing elected member
oversight of the Council’s risk management arrangements. 
The Plan for North Lanarkshire
Priority  All priorities
Ambition statement All ambition statements
Programme of Work All Programmes of Work
Item 11
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1. Background 
1.1 The Council is responsible for the delivery of a wide range of public services and has
set out a range of objectives, priorities and ambitions in The Plan for North Lanarkshire
and the Programme of Work.  The Council operates in an increasingly uncertain and
complex environment and faces multiple challenges in delivering against its priorities. 
Effective risk management arrangements will ensure that the Council is more likely to
achieve its goals and planned outcomes. 
1.2 A risk can be anything that may impact on what the Council is trying to achieve.  Risk
management is about having formal arrangements and processes in place to identify
what those uncertainties might be, to assess their potential consequences and to
decide how best engage with them. 
2. Report 
2.1 The Risk Management Strategy is intended to ensure that the Council is risk aware,
rather than risk averse, and that the management of risk is embedded in the Council’s
policies, procedures, culture and practices.  It is also designed to ensure that key
decisions are taken with an understanding of risks and their effective control.  The
revised Risk Management Strategy is attached at Appendix 1. 
2.2 The Strategy reflects the Council’s continuing risk management maturity by building on
the work carried out since the previous version was approved in 2023.  It outlines the
approach to the identification, assessment and management of risk, and includes
guidance for officers on their roles and responsibilities in relation to risk. The review of
the Strategy has also been informed by informal benchmarking and consultation with
other local authorities through the Association of Local Authority Risk Managers
(ALARM) Scotland group, to ensure consistency of approach and to benefit from
learning opportunities. 
2.3 The revised Strategy includes three key development initiatives which will further
strengthen the risk management arrangements.  These initiatives will be implemented
across the three-year term of the strategy and include: 
• Ever-Present Risks – it is recognised that there are some corporate risks that
tend to be static in terms of assessment and have already implemented controls
and actions. We will explore the development of a method of recording and
treating these risks which has a focus on developing enhanced assurance in
relation to the control environment and for ongoing management awareness and
continuous improvement.
• Opportunity Management – opportunities are areas of uncertainty that could
have a positive impact on the achievement of objectives, and promoting the
inclusion of opportunities within risk registers is recognised best practice.  When
opportunities are formally captured and managed within risk registers, it can
support informed decision making on whether, and how, to maximise potential
benefits.  We will develop our risk register infrastructure to record opportunities
alongside risks.
• Risk Appetite – during the term of this strategy, we will explore emerging
methodologies to further develop our application of risk appetite to enhance our
overall risk management arrangements. 
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2.4 Risk registers continue to represent a core element of the Council’s risk management
processes at both corporate and service levels, and the Strategy includes guidance on
how risk registers should be compiled, reviewed and challenged. 
2.5 Elected member oversight of the Council’s risk management arrangements is
undertaken by the Audit and Scrutiny Panel, who receive details on changes to the
Corporate Risk Register, summaries of Service Risk Registers and updates on all
relevant risk management developments, including progress with the key development
initiatives noted above. 
2.6 The Strategy document was approved by the Policy and Strategy Committee in March
2026. 
3. Measures of success 
3.1  Effective risk management arrangements increase the likelihood of the Council
achieving its planned outcomes, priorities and ambitions.  Internal Audit provides
independent assurance to senior management and the Audit and Scrutiny Panel on the
Council’s risk management arrangements.   
4. Supporting Documentation 
Appendix 1 – Risk Management Strategy   
Francis Scott
Chief Officer (Audit and Risk) 
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5. Impacts 
5.1 Public Sector Equality Duty and Fairer Scotland Duty 
Does the report contain information that has an impact as a result of the Public
Sector Equality Duty and/or Fairer Scotland Duty? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact? 
If Yes, has an assessment been carried out and published on the council’s
website? https://www.northlanarkshire.gov.uk/your-community/equalities/equality-
and-fairer-scotland-duty-impact-assessments 
Yes ☐ No ☐
5.2 Financial impact 
Does the report contain any financial impacts? 
Yes ☐ No ☒ 
If Yes, have all relevant financial impacts been discussed and agreed with
Finance? 
Yes ☐ No ☐ 
If Yes, please provide a brief summary of the impact?
5.3 HR policy impact 
Does the report contain any HR policy or procedure impacts? 
Yes ☐ No ☒ 
If Yes, have all relevant HR impacts been discussed and agreed with People
Resources? 
Yes ☐ No ☐ 
If Yes, please provide a brief summary of the impact?
5.4 Legal impact 
Does the report contain any legal impacts (such as general legal matters, statutory
considerations (including employment law considerations), or new legislation)? 
Yes ☐ No ☒ 
If Yes, have all relevant legal impacts been discussed and agreed with Legal and
Democratic? 
Yes ☐ No ☐ 
If Yes, please provide a brief summary of the impact?
5.5 Data protection impact 
Does the report / project / practice contain or involve the processing of personal
data?   
Yes ☐ No ☒ 
If Yes, is the processing of this personal data likely to result in a high risk to the
data subject? 
Yes ☐ No ☐ 
If Yes, has a Data Protection Impact Assessment (DPIA) been carried out and e-
mailed to dataprotection@northlan.gov.uk 
Yes ☐ No ☐
5.6 Technology / Digital impact 
Does the report contain information that has an impact on either technology, digital
transformation, service redesign / business change processes, data management,
or connectivity / broadband / Wi-Fi? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact? 
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Where the impact identifies a requirement for significant technology change, has
an assessment been carried out (or is scheduled to be carried out) by the
Enterprise Architecture Governance Group (EAGG)? 
Yes ☐ No ☐
5.7 Environmental / Carbon impact 
Does the report / project / practice contain information that has an impact on any
environmental or carbon matters? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact?
5.8 Communications impact 
Does the report contain any information that has an impact on the council’s
communications activities? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact?
5.9 Risk impact 
Is there a risk impact? 
Yes ☒ No ☐ 
If Yes, please provide a brief summary of the key risks and potential impacts,
highlighting where the risk(s) are assessed and recorded (e.g. Corporate or
Service or Project Risk Registers), and how they are managed?
Effective risk management arrangements will enable the Council to manage its
risks more effectively, increasing the likelihood of the Council achieving its plans
and ambitions by minimising or mitigating potential threats to planned outcomes.  A
robust Risk Management Strategy lays out the framework and underpins all risk
management activity across the organisation.
5.10 Armed Forces Covenant Duty 
Does the report require to take due regard of the Armed Forces Covenant Duty (i.e.
does it relate to healthcare, housing, or education services for in-Service or ex-
Service personnel, or their families, or widow(er)s)? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the provision which has been made to
ensure there has been appropriate consideration of the particular needs of the
Armed Forces community to make sure that they do not face disadvantage
compared to other citizens in the provision of public services.
5.11 Children’s rights and wellbeing impact 
Does the report contain any information regarding any council activity, service
delivery, policy, or plan that has an impact on children and young people up to the
age of 18, or on a specific group of these? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact and the provision that has
been made to ensure there has been appropriate consideration of the relevant
Articles from the United Nations Convention on the Rights of the Child (UNCRC). 
If Yes, has a Children’s Rights and Wellbeing Impact Assessment (CRWIA) been
carried out? 
Yes ☐ No ☐ 
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RISK MANAGEMENT STRATEGY 
AN ENTERPRISE WIDE APPROACH TO RISK MANAGEMENT
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Document Control
Title Risk Management Strategy 2026-2029
Owner Francis Scott, Chief Officer (Audit & Risk) Contact ScottFr@northlan.gov.uk
Governance Group Risk Management Corporate Working Group / Corporate Management Team
Author Donald Stone, Corporate Risk Manager Contact StoneD@northlan.gov.uk
Revision History
Number Originator Date Review Commenced Revision description / record of change
Original strategy Ken Adamson 2012 -
1.0 Ken Adamson 2017 Review
2.0 Lauren Anthony 2019 Planned refresh
3.0 Lauren Anthony December 2022 Planned refresh
4.0 Donald Stone November 2025 Planned refresh
Document approvals
Number Governance Group Date approval granted Date approval to be requested
(If document still draft)
Original strategy Policy & Resources Committee September 2012
1.0 Policy & Resources Committee June 2018
2.0 Policy & Strategy Committee March 2020
3.0 Policy & Strategy Committee March 2023
4.0 Policy & Strategy Committee March 2026
Consultation Record (for most recent update)
Status of document consulted upon Risk Management Strategy 2026-2029
Stakeholders consulted / date Risk Management Corporate Working Group, November 2025 - February 2026. BMT - February
2026.
Strategic Alignment
The risk management strategy outlines the council’s approach to the management of risk as part of robust corporate governance
arrangements designed to enable and support the delivery of all council ambitions and priorities.
Next review date
Review date December 2028 Page 171 of 238

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3
Risk Management Strategy 2026
Contents
Page
Foreword       04
1 Introduction       05
2 Embedding Risk Management       06
3 Risk Management Application       07
4 Risk Registers          08
5 Risk Management Governance, Leadership and Accountabilities    09
6 The Three Lines Model       14
7 Risk Management Structure        16
8 Risk Management Methodology         17
9 Risk Reporting, Review and Challenge         18
10 Training and Development          20
11 Key Initiatives for Development in 2026-2029    21
12 Risk Management Guidance        22 - 39
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4
Risk Management Strategy 2026
Foreword
The Council is ambitious in its vision for North Lanarkshire. We are equally ambitious in
developing our risk management arrangements in line with best practice to ensure they
support delivery of our ambition for North Lanarkshire to be the place to Live, Learn, Work,
Invest and Visit.
The Council operates in a complex environment
and faces multiple challenges in delivering against
its priorities. Effective and efficient risk management
arrangements will enable us to engage with
uncertainty in a manner that directly supports
delivery.
This strategy sets out a clear direction for how we
will develop our risk management arrangements to
support quality public services and delivery of The
Plan for North Lanarkshire.
It provides our high level ambitions for enhancing
risk management capability, building on our existing
framework with three key initiatives. These are,
exploring an alternative approach to engaging with
“ever-present risks”, expanding our risk registers to
record opportunities and developing our practices in
relation to risk appetite.
By implementing these initiatives and developing
the operational guidance that supplements this
strategy, we believe that effective risk management
will continue to play a significant part in helping the
Council deliver our ambitions and making North
Lanarkshire the place to Live, Learn, Work, Invest
and Visit.
Councillor Jim Logue
Leader North Lanarkshire Council
Des Murray
Chief Executive
North Lanarkshire Council
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Risk Management Strategy 2026
1 Introduction
1.1  The purpose of this Strategy is to set out the
Council’s vision for risk management and to
provide a framework to ensure that across
the organisation, we manage risk in a manner
consistent with good practice. The Strategy
provides a supporting framework to ensure the
key elements of risk management processes
are in place, enabling risks to be dealt with
and managed at the appropriate level of the
organisation.
1.2  This Strategy is designed to provide the
information and guidance necessary to assist
the organisation in identifying, evaluating,
managing, and monitoring risks that might
impact on achievement of the Council’s plans,
ambitions and objectives and the delivery of
quality public services.
1.3  The Strategy has been developed in
accordance with the CIPFA/SOLACE local
code of corporate governance, “Delivering
Good Governance in Local Government”
and the Audit Scotland, “Best Value tool kit:
Risk Management” which recognises risk
management as an integral part of good
corporate governance, and in accordance with
the International Risk Management Standard
ISO31000 (2018) “Risk Management –
Guidelines”.
1.4  Risk Management Standard: ISO 31000
describes risk management as ‘the
coordinated activities to direct and control an
organisation with regard to risk’. It covers the
processes involved in identifying, assessing,
and prioritising risks, assigning ownership,
taking proportionate management action, and
monitoring and reviewing progress.
1.5 We will continue to embed risk management
in the way we do business, the way we
make decisions, and in our relationships with
partners and suppliers.
1.6 For the purposes of this Strategy, it is useful to
refer to how “risk” is defined in the International
Risk Management Standard. ISO 31000
defines risk as “the effect of uncertainty on
objectives”.
Risk can therefore be characterised as an
event or set of events, which should it occur,
will have an impact on the achievement of
objectives. In other words, risk is “uncertainty
that matters”. Risk is measured by the
combination of the “likelihood” of the event
occurring, and the “impact” on objectives if it
does. The impact can be negative or positive.
• Risks can either be threats or opportunities.
Threats could have a potential negative effect
on objectives, while opportunities could
have a potential positive effect on objectives.
During this strategy period, we are committed
to evolving our approach to incorporate
the identification and management of
opportunities.
• An Issue can be described as a live event or
one that we know is certain to occur. An issue
may have arisen because a risk has not been
identified or has been identified but has not
been managed effectively, or circumstances
have changed to make a risk become an
issue.
Key Benefits of Effective Risk Management
Enables and evidences robust and defensible, best value
decision making, demonstrating openness, accountability and
good governance.
Decision making is risk aware rather than risk averse, enabling
acceptance of certain risks to achieve particular goals.
Enables better use and prioritisation of Council resources to
achieve corporate priorities and enhance service delivery.
Reduces adverse events, and enables effective and more
proactive management of those that occur, reducing time
spent “fire-fighting”.
Enables identification and maximisation of opportunities and
encourages innovation.
Positively contributes to the Council’s reputation as an
employer and service provider.
Provides protection to all stakeholders.
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Risk Management Strategy 2026
2 Embedding Risk Management
2.1  Enterprise Risk Management is a holistic
approach which recognises the link between
uncertainty at different levels and areas of
activity of the organisation, including those
arising from relationships and contracts
with other parties outwith the Council.  This
Strategy applies to the management of
uncertainty across all areas of activity of the
Council and incorporates both a “top down”
and “bottom up” approach.
2.2  Embedding risk management within the
Council will be achieved through application of
the risk management process, and using risk
registers as a management tool to record and
manage uncertainties that matter. This process
will be applied at all levels of the Council and in
our dealings with third parties and partners.
• Corporate Risks are those which could
impact the Council in achieving its Priorities
and objectives. These are strategic in nature
and require corporate oversight or are cross-
cutting across many services. The Corporate
Risk Register (CRR) may also include
significant Service level risks which have been
escalated for attention at a strategic level.
• Service/Team Risks are those risks which
could impact upon a Service or Team in
achieving its objectives.  Team risks may be
escalated to Service level as determined by
application of the Risk Management process,
with service risk registers reflecting an
amalgamated position of risks from different
teams within a service. Service risks which are
deemed to be significant may be escalated
to the CRR in accordance with the Risk
Management process.
• At a programme level the Programme
Uncertainty Level Status Evaluation
(PULSE) process seeks to identify elements
of uncertainty in programme delivery,
interdependencies between project activities
within programmes of work and help to inform
strategic decision making. More information on
the PULSE process is available in programme
governance board documentation and
guidance.
• The council’s Project Risk Management
approach and methodology is designed to
identify and manage those risks and issues
which could threaten delivery of the project,
or compromise cost, quality or timescales.
Key responsibilities with regard to risk
are specifically laid down in the Project
Management framework.
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Risk Management Strategy 2026
3 Risk Management Application
By applying the Risk Management process we develop a better understanding of
uncertainties that matter. This informs our decisions on how best to engage with those
uncertainties and enables a culture that is risk aware rather than risk averse.
3.1 Risk Management is a cyclical process and
will be applied across the organisation in
line with this framework. We operate in an
increasingly Volatile, Uncertain, Complex
and Ambiguous (VUCA) environment and so
exploring uncertainty that could impact on
the achievement of objectives is especially
important.
• When delivering transformational change;
• At the beginning of and during the lifecycle of
projects;
• When entering into partnership working;
• During budget setting exercises;
• During service review and/or structure
changes;
• As part of procurement exercises;
• Following political change;
• As part of strategic and service planning and
decision-making processes.
• Following a change in the regulatory
environment. For example, during the period
of this strategy we will need to assess our
control environment for Fraud Risk in line with
the requirements of the Economic Crime and
Corporate Transparency Act 2023 (ECCTA).
Risk Management and the
Strategic Planning Process
3.2 Our aspiration is for the Council’s risk
management processes and activities to
further develop the symbiotic relationship with
Strategic and Service Planning activities, taking
into account ‘The Plan for North Lanarkshire’
and associated Programmes of Work, as
well as individual Service Plans. The following
outlines how this will be achieved:
• The ongoing consideration of horizon
scanning activity and materials to identify
areas of uncertainty that may affect the
delivery of objectives at each level of the
organisation. This will be supplemented by
an annual exercise incorporating relevant risk
survey publications as a means of exploring
uncertainty in the external environment facing
the Council, as well as consideration of other
similar authorities’ corporate risk registers;
• At a strategic level, the Corporate Management
Team will regularly consider the CRR to ensure
coverage and appropriate treatment of key
areas of uncertainty;
• Regular consideration of any Service risks 
proposed for escalation to the corporate
register and any common themes arising from
across service registers;
• At service level, service risk register reports
should be considered by Service Management
Teams quarterly to ensure continued relevance
to service activities, and be updated following
service planning activity;
• Service Register Reviews should also be
informed by any changes to the CRR to ensure
that any key corporate risks that may impact
the service are adequately considered and
reflected;
• New risks can and should be added at any
point where they are identified outwith the
formal review process;
• This approach ensures that the risk
management process is both ‘top down’ 
and ‘bottom up’
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Risk Management Strategy 2026
4 Risk Registers
4.1  Risk Registers are a management tool used to
capture and maintain information on key areas
of uncertainty that relate to achievement of
objectives, in a consistent and comprehensive
format. The detail contained in a risk register,
including results of analysis and evaluation,
will enable Teams, Services and ultimately the
Corporate Management Team to compare
evaluations, and assess and understand the
organisation’s exposure to risk. Registers
will be used for the ongoing management of
uncertainty including capturing assessment
details, relevant controls and actions, and be
used to inform decision making.
4.2  Risk registers will be recorded and maintained
in the Council’s Risk Management Information
System. This system shall be configured
to reflect the organisational structure of the
Council, its Services and Teams. Visualisation
of this information will provide ease of analysis
and the production of Risk Management
information to aid decision making. The
detailed Risk Management guidance which
supports this Strategy contains documentation
to enable Teams to capture information on
uncertainties for this purpose.
4.3  Enterprise Risk Management means that
registers are maintained at each level of the
organisation, with the flexibility to escalate and
de-escalate risks between levels.
4.4  The levels are:
Risk Register Levels
Corporate Risk Register (CRR) Corporate risks are owned and overseen by the Corporate Management Team, and will be
monitored and reviewed by relevant Corporate Working Groups and/or Service Management
Teams on behalf of CMT. Progress on the management of these risks will be regularly reported
to the Corporate Management Team and the Audit & Scrutiny Panel as required. The Corporate
Register will be subject to ongoing review.
Service Risk Registers Service Risk registers will be maintained by each Service and will be considered at least once
every 3 months to ensure that they continue to reflect the risk profile of the service and that
matters are proposed for escalation where appropriate.
Service risk registers should be a reflection of Team registers, and include relevant partnership
and project risks. Detailed project risks and issues will be recorded within project management
documentation.
Project Risk Registers Project Risks should be captured and managed within project risk registers (within Project
Management documentation - not within the Risk Management Information System. We will
explore opportunities for centralising Project Risk Registers during the term of this Strategy) in
accordance with the Council’s Project Risk Management process which is embedded within
the Council’s approved Project Management Framework. The project risk management process
should be followed for all projects, as the risks that can hamper project success or cause
adverse impacts on the council, can happen in any project irrespective of the size or spend
of the project. Risks relating to the successful implementation of key projects of corporate
significance will be considered for inclusion within the CRR. Following project implementation
however, there may be residual operational risks which require to be included in the service risk
register of the relevant service
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Risk Management Strategy 2026
5 Risk Management Governance,
Leadership and Accountabilities
Everyone in the Council has a role to play in managing risk and should be aware of their
responsibilities. The following clearly sets out the roles and responsibilities for all, split by
formalised groups and individuals.
5.1 Roles and responsibilities - Groups
Policy and Strategy Committee •   Approve the Risk Management Strategy and governance framework and ensure that there is an appropriate review cycle for the strategy;
•   Support management in the use of risk management as an integral part of business practice;
•   Consider periodic reports from the Audit and Scrutiny Panel on overall performance of the Council’s Risk Management and Governance arrangements.
Audit and Scrutiny Panel •   Review and provide independent assurance on the adequacy and effectiveness of the Council’s risk management framework;
•   Monitor the effective development and operation of risk management arrangements in the Council, including monitoring progress in addressing risk related
issues reported to the Panel.
Corporate Management Team (CMT) Managing the Risk Management Framework:
•   Provide high level commitment to supporting, promoting and encouraging good risk management practice throughout the organisation, including
appropriate training, and developing a culture that seeks to be risk aware;
•   Ensure that responsibility for risk management is assigned to an appropriate Chief Officer to oversee corporate risk management arrangements on behalf of
the Chief Executive;
•   Ensure that there is adequate risk management resource to support the organisation in delivering effective risk management;
•   Ensures that key strategic decisions are undertaken with an understanding of the risks and associated controls either already in place or planned;
•   Receive reports that enable monitoring of delivery of the Risk Management Strategy.
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Risk Management Strategy 2026
5.1 Roles and responsibilities - Groups
Corporate Management Team (CMT) Managing Risk:
Own and oversee the CRR, which captures significant Key Corporate Risks;
• Ensure the identification, analysis, evaluation and ongoing management of Corporate Risks and that identification of these risks takes into consideration the
changing internal and external context in which the Council operates;
• Receive regular reports on how corporate risks are being managed;
• Ensure that an appropriate member of the CMT is identified as the owner of corporate risks;
• On an ongoing basis, monitor and review the CRR, including progress on planned control actions, and consider reports from the Risk Management
Corporate Working Group on risk management matters;
• Be proactive in identifying potential new and emerging uncertainty in relation to organisational objectives;
• Ensure that lessons are learnt from incidents, inspections, audits and self-assessments, and that these are considered and reflected where appropriate in
the Council’s risk registers.
Business Management Team (BMT) • To consider risk management outputs going to Committee and/or the Audit and Scrutiny Panel ensuring that adequate assurance exists on the effective
operation of the Council’s risk management arrangements.
Service Management Teams • To regularly review and monitor service risk registers, ensuring that registers are complete and up to date, that new and emerging risks are identified
assessed and managed effectively, and that service risk registers are used to support management discussions and inform decision-making.  
Specifically, this includes:
• Ensuring that risk management is integrated into service management arrangements including planning, performance management, project
management and change initiatives;
• Actively promoting risk awareness, ensuring that existing and emerging risks are understood and managed effectively within Services;
• Ensuring that appropriate Risk Management training is undertaken within each Service area;
• Ensuring that there is adequate resource to support risk management within each Service;
• Proactively identifying potential new and emerging uncertainty in relation to organisational objectives;
• Ensuring that lessons are learnt from incidents, inspections, audits and self-assessments, and that these are considered and reflected where
appropriate in risk registers; 
• Managing risks on a day-to-day basis, using Service and Project risk registers to monitor risks, plan services and support decision making, ensuring
appropriate actions are undertaken on a timely basis;
• Consider whether any high-level service risks may require escalation to the CRR.
Risk Management Corporate
Working Group (RMCWG)
• Support CMT in the co-ordination of activities and resources across the Council in order to implement the Risk Management Strategy and embed and
promote good risk management practice;
• Promote the integration of risk management into Service management arrangements including planning, performance management, project management
and change initiatives;
• On an ongoing basis, identify and review training requirements to ensure good risk management knowledge and awareness across the Council;
• Provide a forum for the sharing of good risk management practice, and share information in respect of existing, new and emerging risks; 
• Provide risk management support and advice across the organisation;
• Be the mechanism for movement of risks between Corporate and Service Risk Registers through Service Risk Champions and the Corporate Risk Team.
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Risk Management Strategy 2026
5.1 Roles and responsibilities - Groups
Service Risk Forums • Support Service Management Teams in the co-ordination of activities and resources across the Service in order to implement the Risk Management
Strategy and embed and promote good risk management practice;
• Provide regular reports to Service Management Teams on the management of Service risks and more generally on progress in embedding risk
management arrangements within Services;
• Promote the integration of risk management into Service management arrangements including planning, performance management, project management
and change initiatives;
• On an ongoing basis, identify and review training requirements to ensure good risk management knowledge and awareness across the Service;
• Provide a forum for the sharing of good risk management practice, and share information in respect of existing, new and emerging risks; 
• Provide risk management support and advice across the Service;
• Be the mechanism for movement of risks between Teams/Services and the Corporate Risk Register.
Corporate Working Groups • On behalf of CMT, and in conjunction with Risk Leads, key Corporate Working Groups/Management Teams may be tasked with the assessment,
monitoring and oversight of those risks on the CRR which link to the work of that group;
• Review lessons learnt from any relevant incidents and losses, inspections, audits and self-assessments related to those risks, and reflect and consider the
Council’s management arrangements in respect of them.
5.2 Roles and responsibilities - Individuals
Elected Members Risk management is an important and integral part of the Council’s governance arrangements and is crucial to the achievement of outcomes. A significant
aspect of an Elected Member’s role is in making decisions for the Council and the people of North Lanarkshire. The CIPFA/SOLACE Guidance “Delivering
Good Governance in Local Government” makes explicit the decision-making role of Elected Members, and the need to ensure that risk information contributes
to the decision making process.
Elected Members need to be satisfied, when considering recommendations from officers, that risk has been considered and addressed as part of relevant
decision-making activities. Members also need to ensure that the Council’s Risk Management Strategy and policies are suitably aligned with and support the
delivery of objectives.
In discharging these responsibilities Elected Members will:
• Require Officers to develop and implement an effective framework for risk management, and to receive reports on the management of significant risks on a
regular basis;
• Expect Officers to ensure that committee reports describe significant risks associated with proposals, and detail how these risks will be managed;
• Ensure that risk management arrangements are evaluated and monitored on a regular basis.
Chief Executive Supported by the Chief Officer (Audit & Risk), the Chief Executive will:
• Have overall responsibility for the Council’s Risk Management framework;
• Champion risk management at senior level, ensuring that effective arrangements and resources are in place to manage risk;
• Be accountable for the management of risk within the Chief Executive’s Service;
• Nominate and support a Service Risk Champion, who will co-ordinate risk management activities within the Service;
• Promote risk management awareness and practice within their area of responsibility;
• Ensure that risk management is integrated into Service planning, performance management and project management arrangements, and is a regular item
on the agenda of the Chief Executive’s SMT meetings;
• Ensure risks are appropriately managed, monitored, reported, reviewed and escalated where necessary, and that appropriate action to manage risks is
undertaken on a timely basis by control and/or action owners.
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Risk Management Strategy 2026
5.2 Roles and responsibilities - Individuals
Depute Chief Executive • Accountable for the management of risk within the Services which they oversee as part of their role as Depute Chief Executive;
• Nominate and support a Service Risk Champion(s), who will co-ordinate risk management activities within their Service(s);
• Promote risk management awareness and practice within their area of responsibility;
• Ensure that risk management is integrated into Service planning, performance management and project management arrangements, and is a regular item
on the agenda of management meetings;
• Ensure their risks are appropriately managed, monitored, reported, reviewed and escalated where necessary, and that appropriate action to manage risks
is undertaken on a timely basis by control and/or action owners.
Chief Officer (Audit & Risk) • Accountable to the Chief Executive, and has delegated responsibility for overseeing the Risk Management framework and the Council’s Risk Management
function;
• Provide regular reports to BMT/CMT and the Audit & Scrutiny Panel on the management of Corporate Risks and more generally on operational
performance and progress in embedding the Council’s risk management arrangements.
Corporate Risk Team (Corporate
Risk Manager and Corporate Risk
Officer)
• Co-ordination and continuous development of risk management arrangements across the organisation liaising with CMT and Services on their
implementation;
• Provide support and guidance to the organisation on the management of risk;
• Provide a range of risk management training opportunities to maintain role appropriate knowledge and awareness of risk management across the
organisation;
• Oversee the development, use and maintenance of the Risk Management Information System to support management of the Council’s risk registers;
• Support CMT in the ongoing management of the CRR;
• Monitor progress of Services in their implementation of the Risk Management Strategy;
• Support the Chief Officer (Audit & Risk) in meeting risk reporting requirements;
• Provide project risk management support where required for key projects including facilitation of risk workshops etc.
Chief Officers • Accountable for the management of risk within their area of responsibility;
• Responsible for identifying and analysing potential compliance risks for their service area including for example, Fraud risks, Health & Safety, Procurement
etc;
• Nominate and support a Risk Facilitator who will liaise with Service Risk Champions to co-ordinate risk management activity across their Teams;
• Ensure that employees are familiar, as appropriate, with the Risk Management Strategy, guidance and controls relevant to their specific duties;
• Ensure that training needs are assessed and met in respect of risk management skills.
Managers • Promote risk management awareness and practice within their area of responsibility;
• Ensure that risk management is integrated into Service planning, performance management and project management arrangements, and is a regular item
on the agenda of management meetings;
• Ensure their risks are appropriately managed, monitored, reported, reviewed and escalated where necessary, and that appropriate action to manage risks
is undertaken on a timely basis by control and/or action owners.
Risk Leads/Owners Those who through the risk management process are identified as having ownership of risks;
•   Responsible for leading on the ongoing management and monitoring of a particular risk assigned to them.
Control Owners Those who through the risk management process, are identified as having ownership of either current or planned controls;
•   Responsible for ensuring that controls are managed and maintained, and that any changes to controls are notified to risk owners so that risks may be
reviewed accordingly. 
Action Owners Those who through the risk management process, are identified as having ownership of those actions deemed necessary to either prevent or mitigate risks;
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Risk Management Strategy 2026
5.2 Roles and responsibilities - Individuals
Risk Champions Acting as the point of contact for risk management matters within their Service, the Risk Champion will be responsible for providing assurance to the Depute
Chief Executive / Chief Executive / Chief Officer on whether risk management arrangements are in place and operating effectively in accordance with the Risk
Management Strategy. This will be achieved by:
• Participating in the work of the Risk Management Corporate Working Group;
• Promoting risk awareness across their Service, including contributing to identification of relevant training needs and monitoring of the completion of the
same;
• Directing risk management discussions at Management Team meetings, ensuring that “Risk” remains a regular item on the agenda;
• Guiding, liaising with and supporting Risk Facilitators in Teams through the Service Risk Forum;
• Supporting their Service Management Team in the ongoing development and management of Service Risk Registers;
• Escalating risks to the Depute Chief Executive / Chief Executive / Chief Officer where immediate attention is required;
• Providing project risk management support where required for key projects including facilitation of risk workshops etc;
• Monitoring service compliance with the requirements of the Risk Management Strategy, process and procedures;
• Engaging in appropriate risk management training to maintain skills and knowledge.
Risk Facilitators Acting as the point of contact for risk matters within their Team, Risk Facilitators will be responsible for providing assurance to their Chief Officer on whether
risk management arrangements are in place and operating effectively in accordance with the Risk Management Strategy. This will be achieved by:
• Liaising with Risk Champions to maintain a co-ordinated approach including through the service risk forum;
• Promoting risk awareness across their service area, including contributing to identification of relevant training needs and monitoring completion of the
same; 
• Supporting their Management Teams in the ongoing development and management of Team Risk Registers;
• Directing risk management discussions at meetings, ensuring that “Risk” remains a regular item on the agenda;
• Escalating risk issues to the Chief Officer of the Service and Risk Champion where immediate attention is required;
• Engaging in appropriate risk management training to maintain skills and knowledge.
Project Managers/Project Boards
etc
Those involved in delivery of projects for the organisation have specific responsibilities for managing risks and issues within the Project Management
process, which could threaten delivery of the project, or compromise cost, quality or timescales. Key responsibilities are specifically laid down in the Project
Management framework.
Internal Audit Provide independent review, and report on adequacy of the Council’s risk management arrangements and the effectiveness of implementation of the Risk
Management Strategy at all levels.
Insurance & Risk Team • Put in place and maintain appropriate risk financing arrangements to mitigate against unacceptable financial loss from insured risks, in line with the
Council’s risk retention appetite;
• Handle in-house all liability and property damage claims within parameters agreed with the Council’s insurance/risk partners;
• Feedback to Services and the RMCWG statistics and loss information that will enable Services to target areas for improved risk control and loss prevention;
• Assist Services on control of insurable risks and the improvement of operational risk controls.
Employees • Maintain awareness of the Council’s Risk Management Strategy and processes through completing appropriate mandatory Risk Management training;
• Be aware of and contribute to the effective identification and management of risks relevant to their own role and that of their team. 
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6 The Three Lines Model
The Council operates on the principles of the ‘Three Lines’ model, an internationally
recognised framework for managing risk, which provides structure and helps demonstrate
key roles and responsibilities within that framework and how these link together to deliver
robust risk management.
6.1 Figure 1 below illustrates how responsibility
for managing risk gets proportionately less as
we move down the three lines, with the most
significant level of ownership and responsibility
for managing risks resting within the first line at
the top of the triangle, front line services.
• 1st Line lies with front line/operational
management who maintain ownership,
responsibility, and accountability for directly
identifying, assessing, controlling and
mitigating risks.
• 2nd Line includes those areas that provide the
tools and framework to allow the first line to
fulfil its role. Includes areas like the Corporate
Risk Team, Legal, Democratic & Strategy,
Finance & Technology, Health & Safety etc.
Second line functions facilitate and monitor the
implementation of effective risk management
by the first line, including providing key risk
controls, guidance, support, training and
advice.
• 3rd Line provides independent assurance
and includes areas that check activities and
arrangements at second and first lines to
ensure they are fit for purpose and are being
complied with. For example, the Internal
Audit function provides assurance to Audit
& Scrutiny Panel and senior management
about how well the first and second lines are
identifying and managing risks, and around
implementation and effectiveness of risk
controls.
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North Lanarkshire Council’s Three Lines Model
Services
Operational Procedures, Managing Risk,
Control Activity, Projects, Self-Evaluation
Oversight/Enabling/Control Functions
Corporate Risk Team, Legal, Democratic & Strategy,
Finance & Technology, Health & Safety etc (Framework,
Guide, Consult, Train, Advise, Support)
Assurance Providers
Internal Audit (Monitor Compliance, 
Provide Independent Challenge and Assurance)
3
2
1
3rd
Line
2nd Line
1st Line
Figure 1 - Three lines model
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7 Risk Management Structure
The following diagram shows the structure of risk
management activity in North Lanarkshire Council. 
Primary responsibility for co-ordination of risk
management activities lies with the Corporate Risk
Team through the Risk Management Corporate
Working Group. Service Risk Champions will be
responsible for facilitating and supporting the
implementation of risk management within their
service activities through their Service risk forums,
and reporting progress and risk management
information to their own Service Management
Teams.
Corporate
Management Team
Chief Officer
(Audit & Risk)
Corporate Risk Team
Service risk forums
(1/4ly following RMCWG)
Service
Management Teams
Policy and Strategy
Committee
RMCWG (8 weekly)
Service Committees
Audit and Scrutiny Panel
Risk Champions
Operational
Management
Employees
Figure 2 - Risk Management Structure
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8 Risk Management Methodology
Scope, Context,
Criteria
Com
m
unication
and
Consultation
Risk Evaluation
Risk Analysis
Risk Identification
Risk Assessment
Risk Treatment
M
onitoring
and
Review
Recording and Reporting
Figure 3 - Risk Management Process
8.1  Effective Risk Management is about developing
the right culture, processes and structures
in our organisation and directing them in a
co-ordinated way to manage risk, facilitate
continuous improvement and enhance service
delivery.
8.2  Risk Management is about being proactive in
understanding uncertainties that can impact
on achievement of our goals. It is a continually
evolving process which helps us to learn
and build upon good practice, ensuring that
we manage uncertainty in a proactive way,
contributing to successful delivery of services
and Corporate Priorities.
8.3  Embedding Risk Management throughout
the organisation will be achieved by the
consistent application of the risk management
process shown in Figure 3, across all Services
and business activities. This will enable the
organisation to manage and monitor risks at
the most appropriate level, ensuring that the
right oversight is in place, and that we respond
to risk in a consistent and proportionate
manner.
8.4  Risk management should not be done in
isolation, but requires to be considered by
Services, Teams, Programme and Project
Teams as a routine part of Corporate, Service,
Operational, Programme and Project planning.
This means that assessing risk becomes an
integral part of our working practices as well as
a feature of how we approach development of
new policies or business change initiatives.
8.5 A methodology for managing risk across
the organisation has been established and
will be consistently applied at all levels. The
approach has been developed in accordance
with the International Risk Management
Standard ISO31000:2018 “Risk Management –
Guidelines” as illustrated in Figure 3. 
Full details of the Risk Management
methodology to be followed are contained
in the Risk Management guidance that
accompanies this strategy.
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9 Risk Reporting, Review & Challenge
9.1  Different levels of the organisation require
different information from the Risk
Management process. For example, CMT
should know about the most significant
Corporate Risks facing the Council and how
these risks are being managed. Service
Management Teams require to be aware of the
risks which fall into their area of responsibility
which may impact on the services provided
by them, and on their ability to achieve their
objectives. Teams need to be aware of and
take appropriate action on the risks that face
the Team.
9.2  Risks identified and their control status should
be formally reported to the appropriate level
of management and stakeholders on a regular
and timely basis to ensure that they receive the
appropriate level of management attention.
9.3  To allow for the effective monitoring of risks, a
Risk Owner should be identified for each risk. 
This person is responsible for ensuring that
plans are in place for reviewing and reporting
progress on the management of that risk and
associated actions. The Risk Owner will be a
named individual.
9.4  The CRR will be presented to the Audit and
Scrutiny Panel on a quarterly basis. This will
reflect exceptional changes to the register that
occur in the reporting period. For example,
new additions, deletion or changes to the
assessment.
9.5 Risk Management reports will also be
presented to Service Management Teams on
a quarterly basis to enable them to monitor
and review key service risks, as well as
have oversight of service risk management
arrangements.
9.6  Oversight of risk registers is an essential part of
the risk management process, to ensure that
registers reflect the organisation’s risk profile.  
It will identify any anomalies for example where
risk or control review is due. Having the correct
oversight and challenge will mean that we
maximise the benefit of the risk register as
a management tool and have accurate risk
management information to inform decision
making.
9.7  As part of risk register monitoring,
management should consider the effectiveness
of risk controls and actions and how these
are reflected in risk ratings. Management
should also consider any new risks which have
emerged and reflect on any risks closed in the
reporting period.
9.8  Where a risk is reviewed by the Service and
felt to have either corporate relevance or its
significance has escalated to be of corporate
interest, this should be raised through the Risk
Management Corporate Working Group or with
the Business Management Team for inclusion
as a Corporate Risk.
9.9  The Council’s Internal Audit Team will
undertake regular audits of the Council’s
risk management arrangements as part of
the annual Internal Audit plan. The Council’s
external auditors may also periodically review
the risk management processes put in place
by the Council as part of their review of
the Council’s wider corporate governance
arrangements.
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Risk Management Strategy 2026
Risk Management Monitoring
9.10 Risk Management activity across services will
be monitored through the RMCWG in order to
provide targeted support to enable services
to maximise the benefit of risk management
as a management tool.  An agreed monitoring
approach will be used by the corporate
risk team and members of the risk network
on a 6 monthly basis to identify areas for
improvement.  A summary of the results will
be utilised to provide high level management
information and inform reporting to SMTs,
BMT, CMT and Audit & Scrutiny Panel.
Risk Tolerance
9.11 North Lanarkshire Council seeks to be risk
aware not risk averse, which means that we
will accept a tolerable level of risk that provides
a balanced organisational risk profile. The
expected responses to the varying levels of
risk are detailed in the accompanying risk
guidance.
It is recognised that in certain circumstances
there will be certain risks which the council
has little direct control or influence or where
incidents or errors may occur despite robust
controls being in place. In such circumstances
the risk management process should ensure
appropriate governance and oversight of these
risks through frequent monitoring and review of
the risk and control arrangements, to provide
assurance over the management of these high
risks.
More detail surrounding risk tolerance and
expected responses is contained within
the Risk Management Guidance which
accompanies this strategy.
9.12 Risk appetite is an expression of how much
uncertainty an organisation is willing to invite
into its processes in pursuit of objectives.
Having an established risk appetite framework
can encourage consistency when making risk
informed decisions. North Lanarkshire Council
will seek to develop its approach to risk
appetite throughout the period of this Strategy.
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Risk Management Strategy 2026
10 Training and Development
10.1  We need our workforce to have an awareness
of Enterprise Risk Management. We will ensure
that colleagues with a more detailed role in
facilitating the risk management process have
the skills and competence appropriate to their
role.
10.2  The Risk Management Corporate Working
Group will continuously identify and review
risk management training needs across the
organisation. The Corporate Risk Team will
provide training and learning opportunities
for Elected Members and Officers, which are
appropriate and proportionate to roles and
responsibilities.
10.3  Risk Management Training and Awareness
materials are referenced within the Risk
Management guidance which accompanies
this strategy. This may range from those
who require a general awareness, to Elected
Members and Senior Managers with more
strategic decision-making responsibilities, and
those employees who have a more specific
role in the Risk Management process.
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Risk Management Strategy 2026
11 Key Initiatives for Development in 2026-2029
Figure 4
Ever Present Risk
11.1  It is recognised that there are some Corporate
Risks that due to their ever present nature,
will always command the attention of Senior
Management. Where captured on risk registers
these ubiquitous risks tend to be static in
terms of assessment and have a series of
implemented controls; controls which are in
the main managed by second line functions
and must have cross organisational awareness
and adherence in order to remain effective.
The key aspects of the control environment
of these risks often feature in Internal Audit
assignments. Throughout the term of this
Strategy, we will explore the development of a
method of recording and treating these risks
which has a focus on developing enhanced
assurance in relation to the control environment
of these risks and for ongoing management
awareness and continuous improvement.
Opportunity Management
11.2  Recognised best practice and publications
promote the practice of capturing opportunities
within risk registers. Opportunities are areas
of uncertainty that could have a positive
impact on the achievement of objectives.
When opportunities are formally captured and
managed within risk registers, it can support
informed decision making on whether, and
how, to maximise their potential benefits. We
will develop our risk register infrastructure to
record opportunities alongside risks.
Risk Appetite
11.3  In preparing this iteration of our strategy
we have recorded explicit reference to the
definitions of risk tolerance and risk appetite
in line with industry standard. During the
term of this strategy we will explore emerging
methodologies and develop our application
of risk appetite to enhance our overall risk
management arrangements.
The timelines for delivering these initiatives are
illustrated in Figure 4.
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Risk Management Strategy 2026
12 Risk Management Guidance
Page
A. Risk Management Methodology and processes  23 - 24
•   Establishing the Context
•   Risk Assessment:
•   Risk Identification and description
•   Risk analysis
•   Risk evaluation
•   Risk response
B. Risk Assessment – Matrix & Descriptors     25 - 28
•   Likelihood descriptors
•   Impact descriptors
•   Risk Scoring Matrix
•   Risk Response and Escalation
•   Monitoring and Review
C. Risk Capture and Review Instructions      29 - 33
D. Risk Management Reporting        34
E. Dealing with Risk in Committee Reports     35 - 36
F. Training & Awareness Materials       37
G. Glossary of Risk Management Terms      38 - 39
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Risk Management Methodology
The process adopted by the Council for managing
risk is summarised below. 
Step 1. Establish the Context
The first step in the risk management process is
to understand and define the planned objectives,
outcomes and targets of the Service, Team or
Project. This will include scope, stakeholders, the
environment in which we operate, and any internal
and external factors. This is important since the
context from a corporate or strategic perspective
may be very different from an operational
perspective.
Step 2. Risk Assessment
This is the process where we identify key risks and
consider the likelihood and impact of these on
achievement of objectives, outcomes and targets. 
Risk assessment comprises the following three key
elements:
• Risk Identification
• Risk Analysis
• Risk Evaluation
Scope, Context,
Criteria
Communication and Consultation
Risk Evaluation
Risk Analysis
Risk Identification
Risk Assessment
Risk Treatment
M
onitoring and Review
Recording and Reporting
Figure 5 - Risk Management Process
Risk Identification
This is the systematic use of information from
the “Establishing the context” stage to identify
and describe risks. When identifying risks, there
are 6 risk categories that should be considered:
Strategic, Financial, Operational, Human Resources,
Legislative & Regulatory and Information Technology.
Detailed information on each risk category, including
their subcategories, can be found later in this
guidance document.
The risk identification process should, where
possible, involve relevant subject matter experts
who have knowledge or experience of the activity
or matter under consideration.  Risks should be
described in three parts, covering:
• The risk event i.e. “there is a risk
that…………..”
• The cause i.e. “due to……..”
• The consequence i.e., “which could result in
……”
Each risk should be considered in the context of,
and aligned to the Council’s corporate priorities, and
those activities that contribute to their achievement.
To ensure appropriate ownership of risk, each risk
should be assigned to a “Risk Owner”. This is the
person who, through the risk management process,
is identified as being the most appropriate Officer
to lead on the management and oversight of a
particular risk.
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Risk Management Strategy 2026
Risk Analysis
This stage determines the significance of a risk and
its priority relative to others through risk analysis.
We estimate the risk’s likelihood and multiply it by
its potential impact using the Council’s Likelihood
and Impact Descriptors and Risk Matrix. These tools
ensure a consistent approach to risk measurement
across the organisation. The combined score
produces a risk rating, calculated in two stages:
• Inherent risk rating is calculated first and is
done as if there were no controls in place to
manage the risk.   
• Existing controls – we then need to consider
what controls are already in place to manage
the risk. Controls can be policies, procedures,
training or other management arrangements
designed to manage risk by either reducing the
likelihood of the risk occurring, and/or reducing
the impact if it does occur.
• Residual risk rating is then calculated after
consideration of the effectiveness of existing
controls.
The residual risk rating will then dictate whether
further actions are required to reduce the risk further.
This analysis of risk produces a risk rating as
follows:
Risk Ratings
Insignificant Low Medium High Very High
Risk Evaluation
Compares the scores of all of the analysed risks
in order to make decisions about their significance
in relation to our priorities, objectives, and targets. 
This produces a “Risk Profile” which enables us to
prioritise the risks and decide whether further action
is required, with higher rated risks being given more
focus.
Risk Response/Treatment
Involves responding to identified and evaluated risks
in a way that is proportionate to the level of risk. This
means identifying what, if any, additional actions
and controls are required to manage the risk further.
Risks may be responded to by means of the 4 “T” s:
• Terminate – Avoid or eliminate the risk
exposure or activity giving rise to the risk, then
it no longer presents a risk to manage.
• Treat – implement cost effective actions to
modify the risk to a more tolerable level.
• Transfer – transfer all or part of the risk to
a third party i.e. through contract terms,
insurance etc.
• Tolerate – an informed decision to accept the
likelihood and the impact of a particular risk
rather than trying to mitigate it further.
This guidance applies to our current process for
identifying and managing threats. While threats
remain a key focus, it is equally important to
consider opportunities when assessing uncertainty
and its potential impact on our objectives.
During this strategy period, we are committed to
enhancing our approach to include the identification
and management of opportunities. Additional
guidance will be provided as this evolves.
If you identify an opportunity and require support,
please contact the Corporate Risk Team, who can
provide tools and assistance to help you develop
and manage opportunity related risks effectively.
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Risk Management Strategy 2026
Risk Assessment
Likelihood Descriptors
Please note that descriptors are intended to be
indicative only and may need to be tailored to
the individual objective, project or activity under
consideration, for example in line with specific
professional guidance, national targets or project
parameters. These should be agreed with all
stakeholders concerned with the risk.
Likelihood Descriptors
Score Description
5
Almost Certain
Event expected to occur
(If occurring treat as an issue)
Over 90% likelihood of occurrence
4
Likely
Event will probably occur
61-90% likelihood of occurrence
3
Possible
Event could occur
31-60% likelihood of occurrence
2
Unlikely
Event not expected to occur
11-30% likelihood of occurrence
1
Rare
Remote chance event could occur in certain
circumstances
10% or less likelihood of occurrence
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Impact Descriptors
Description of impact
Score On Service Delivery Financial On people (including
physical and mental
wellbeing)
On reputation Inspection / Legal / Compliance
5
Catastrophic
Catastrophic failure in service quality
and key service standards are not met;
long term catastrophic interruption to
operations; several major partnerships
are affected
Severe financial loss
>£1million
Multiple deaths
Major permanent incapacity
Prolonged National and
Local condemnation
National media(> 3 days)
Rapid intervention and/or prolonged
attention from legislative/regulatory body
Serious breach including potential
prosecution
Severely critical report
4
Major
Major impact to service delivery; multiple
service standards not met; long term
disruption to operations; multiple
partnerships affected
Major financial loss 
£500,000 - £1m
Death
Major injuries or long-
term incapacity/ disability
(loss of limb), requiring
medical treatment and/or
counselling.
Serious negative national or
local criticism
National media (<3 days)
Local media >3 days
Medium-term attention from legislative/
regulatory body
Breach which could lead to litigation or
prohibitions
Enforcement Action / Critical report
3
Moderate
Significant failure of service quality; major
partnership relationships strained; serious
disruption to service standards
Significant financial loss
£250,000 - £500,000
Significant injury requiring
medical treatment and/or
counselling.
Some adverse public / local
media attention
Local media only <3 days
Short term attention from legislative/
regulatory body
Breach which could lead to claims or
inquiry
Challenging recommendations but can
be addressed with appropriate action
plan.
2
Minor
Minor impact on service quality/minor
service standards are not met; short term
impact
Moderate financial loss
£50,000 - £250,000
Minor injury or illness, first-
aid treatment needed. No
staff absence required.
Minor adverse local/
public/media attention and
complaints
Very minor attention from legislative/
regulatory body
Legal action is unlikely or only minor
claims
Minor recommendations made which
can be addressed by low level of
management action
1
Insignificant
No impact on service quality/limited
disruption to operations
Minimal loss <£50,000 Adverse event leading to
minor injury not requiring
first aid.
No interest to the media,
internal only.
Public concern restricted to
local complaints
No external interest
None or little risk of legal action
Small number of recommendations
which focus on minor quality
improvement issues.
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Risk Scoring Matrix 
Risk Scoring Matrix
Risk
Likelihood
Almost Certain
5 5 10 15 20 25
Likely
4 4 8 12 16 20
Possible
3 3 6 9 12 15
Unlikely
2 2 4 6 8 10
Rare
1 1 2 3 4 5
1
Insignificant
2
Minor
3
Moderate
4
Major
5
Catastrophic
Risk Impact
Risk Rating Insignificant Low Medium High Very High
Risk Scoring Matrix
Risk Rating Expected Response Escalation Guidance
Insignificant
1 - 3
Insignificant risks score from 1-3 on the risk matrix.  We can normally accept these. No
further actions would normally be expected to prevent or mitigate the risk.
No escalation required to service management team or BMT.
Low
4 - 8
Low risks score from 4 – 8 on the risk matrix. We can normally accept these. We wouldn’t
normally need or expect to do anything further to prevent or mitigate the risk other than to
actively monitor existing controls to ensure they continue to be effective.
No escalation required to service management team or BMT.
Medium
9 - 15
Medium risks score from 9 – 15 on the risk matrix. These can be tolerated if we are
confident about the arrangements/controls we have in place to manage them. Any
additional control measures identified as necessary should be cost effective in relation to
the risk.
These risks should be reviewed on a frequent basis by line management and progress
should be reported regularly to the Service Management Team
16 - 20
High
High risks score from 16 – 20 on the risk matrix. We can tolerate high risks, but we
do need to monitor relevant controls carefully.  Consideration should be given to any
additional control measures which could help prevent or mitigate the risk and reduce the
risk score, where such actions would be cost effective.
These risks should be reviewed on an ongoing basis by the relevant Service Management
Team who may report or escalate to BMT for consideration/inclusion in the CRR.
Very High
25
Very High risks score 25 on the risk matrix. These risks should be actively managed to
reduce the risk score. Consideration should be given to any additional control measures
which could help prevent or mitigate the risk and reduce the risk score, where such
actions would be cost effective.
These risks should be reviewed on a more regular basis by the relevant Service
Management Team who may report or escalate to BMT for consideration/inclusion in the
CRR.
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Monitoring and Review
Residual Risk
Score
Risk Rating Review
Frequency
25 Very High Monthly
16 – 20 High 3 monthly
9 - 15 Medium 6 monthly
4 - 8 Low 9 monthly
1 - 3 Insignificant Annually
Monitoring & Review
Once risks have been assessed and rated, they
should be on a programme of regular review
according to residual risk score as follows, unless
circumstances change to suggest the risk should be
reviewed sooner:
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Risk Management Strategy 2026
Risk Capture Instructions
Mandatory fields are marked with an asterix
Risk Status*    Choose from Draft / Live / Closed
Primary Risk Category and Sub
Category* (see pages 40-41)
Chose most relevant Primary and Sub Category form drop down
Risk Title*        A short title/description of the risk.
Context* Some background information on the risk
Risk*                 Free text to describe what the risk or adverse event is. 
Wording should be “There is a risk that……“. A risk is something which “could” happen. If it happens or is definitely going to happen it becomes an “issue”.
Due to*               Free text to describe the potential causes of the risk occurring. Wording should be “due to….”
Impact**             Free text to describe the potential impact (s) if the risk occurs. Should be worded “which will result in……”
Proximity The earliest that this risk could occur: Immediate to one week; One week to one month; One month to six months; Six months to 1 year; One year to five
years; Greater than 5 years
Risk Owner*    The person who has responsibility for co-ordinating the management of the risk.
First Assessment Date The First Assessment Date needs to be in the past. The system will calculate when the next assessment date is due by frequency in Assessment Tab.
Risk Contact  This is a person nominated by the Risk Owner as first point of contact for any query regarding the risk. This person will also receive notifications on the risk,
new risk, assessment due or overdue in addition to Risk Owner
Corporate Priorities Tick any that are appropriate/most appropriate in relation to the risk. Should have at least one and may have all if considered relevant
Assessment
Inherent Likelihood*  Each risk should be scored in terms of Inherent Likelihood using the matrix below for guidance. Inherent Likelihood score is the evaluation of the likelihood of
the risk occurring if there were no controls in place. Enter the score from the drop-down menu.
Inherent Impact*  Each risk should be scored in term of Inherent Impact using the matrix below for guidance. Inherent Impact score is the evaluation of the potential impact if
the risk occurs, if there were no controls were in place. Enter the score from the drop-down menu.
Reason for Inherent Risk Likelihood*  Free text to describe the rationale for the Inherent Likelihood score. Where possible include any factual information to support this rationale.
Reason for Inherent Risk Impact*    Free text to describe the rationale for the Inherent Impact score. Where possible include any factual information to support this rationale.
Residual Likelihood*  Residual Likelihood score is the evaluation of the likelihood of the risk occurring, taking into account the control measures you have identified
Residual Impact*  Residual Impact score is the evaluation of the potential impact if the risk occurs, taking into account the control measures you have identified
Reason for Residual Likelihood*    Same rational as per Reason for Inherent Risk Likelihood
Reason for Residual Impact*  Same rational as per Reason for Inherent Risk Impact
Risk capture and assessment instructions
The following instructions define the process for recording risk details within the Risk Management
Information System. Supplementary tools and templates designed to facilitate risk identification,
documentation, and assessment are maintained by the Corporate Risk Management team and made
available to the risk network
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Risk Capture Instructions
Risk Response Type*  Terminate - Stop the activity giving rise to the risk or choose an alternative solution. This response may be chosen where the residual risk is too high, and the
preferred option is terminate.  
Treat - Implement cost effective measures to control a risk to a more acceptable level. Controls will focus on reducing either the likelihood of the risk
occurring, and/or the impact of the risk if it does occur. Chose Treat if there are any action plans.
Transfer - Transfer all or part of a risk to a third party, usually achieved through contract terms, insurance, or other means. 
Tolerate - Agree that any further action to treat a risk is not cost effective or proportionate in relation to the current risk and decide to tolerate it as it is.
Latest Review Remarks Free text to include a concise summary of any changes that have been made to a risk during a review.
Current Key Controls
Control Status*   Choose from Planned, In Progress, Implemented or Enhancing. Enhancing is where there is already a control and it will be further improved. 
Control Type*   Prevention where reduces likelihood of risk happening or Mitigation which reduces impact should the risk occur.
Key Control    If considered a most vital control
Control Description*  Something that reduces the likelihood of the risk occurring and/or mitigate the impacts if it does. 
Implementation Target Date Date that control was implemented. This is not mandatory
Control Owner*   In council terms while control owner can be a working group committee etc. for capture in Figtree it must be an individual. If it is a group etc. make reference
to that effect in the control description and enter as control owner person considered most suitable to co-ordinate the control. Where possible control owner
should be a NLC member of staff though there are certain time when control owner will be part of a key partnership e.g. NHS. Do not enter an elected
member as a control owner. 
Control Progress Remarks For controls that are not yet fully implemented, free text to document progress on a control during a risk review, including details of updates, improvements,
and changes made in developing the control.
Next Review Date (Implemented
Controls)
For implemented controls a field that fields allow users to set a date for the control to be next reviewed.
Latest Review Remarks
(Implemented Controls)
For implemented controls, free text to capture brief review notes at each review date. This ensures controls are still relevant and effective as prevention or
mitigation measures
Actions: Each Action must be linked to a parent control and the control status selected must NOT be’ Implemented’
Actions
Action Status*                                                    Choose from Raised, Underway or Complete
Action  Priority*                                                 Choose from Low Medium or High
Key Action If considered a most vital action
Action Description*                                          Details of the action which improve the control
Action Owner*                                                  Same rational as for control owner
Additional Contact This person will 
receive notifications on a new action, action due or overdue in addition to Action Owner
Action Progress Remarks Free text to document progress of an action during a risk review.
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Risk Management Strategy 2026
Risk Categories
Primary Risk Category Sub Risk Category Definition
Strategic Managing Strategic Change Inability of the Council to implement change and reform while still delivering its corporate objectives
Digital and IT Strategy Technology is inadequate to support future council initiatives
Governance Leadership and Decision Making Ineffective leadership in agreeing a shared ambition and strategy for North Lanarkshire. Lack of clarity in defining
responsibilities and appropriate governance across the complex roles for all Elected Members and senior staff.
Health and Social Care Integration IJB is ineffective with knock on impact on the Council SW or that NLC cannot provide adequate support for IJB priorities
Financial Policies and Controls Inadequate financial control over council activities including partnership arrangements
Financial Sustainability Lack of funding to manage council activities in current and future years.
Capital and revenue grant funded programmes   Inability of NLC to deliver on a major capital or revenue programme/project where there is potential for grant clawback.
Operational Procurement Risk Failures in the procurement process designed for the purchase and ongoing management of goods, services, and works.
Engagement and Consultation with
Communities, Partners and Stakeholders
That communities, partners and stakeholders are not engaged in the shaping and delivery of services and that NLC does
not optimise the benefits from implementation of the Community Empowerment (Scotland) Act 2015
ALEO Risk ALEOs fail to deliver Council services, expectations or requirements
Project Risk Risk arising from inadequate project management.
Risk Management Risks arising from inadequate Risk Management
Serious Organised Crime, Fraud and
Corruption
Fraud against the council, employees, members, key partners or stakeholders. Relationships with inappropriate bodies,
groups of people/individuals. Corrupt practices across range of NLC Stakeholders. 
Terrorism NLC fails to plan, prepare and protect its employees, elected members, the public and our communities. NLC fails to
provide a co-ordinated approach and contribution to the Counter Terrorism initiatives led by Police Scotland.
Communications Non-compliance with Communications Strategy and Policies across the council. Communications are ineffective, do not
reach or are not received from relevant parties
Human Resources Human Resources Lack of suitable numbers of appropriately skilled staff. Non-compliance with employment legislation and regulation.
Legislative and
Regulatory
Non-compliance existing and new Legislation
and Regulation
Non-compliance with Legislation, Regulation and government policies.
Health and Safety Failure to comply with the Health & Safety at Work etc Act 1974 and associated legislation protecting the health, safety
and welfare of our employees and anyone else who can be affected by our activities.
Resilience Planning Inadequate response and participation in a Civil Contingency event
Business Continuity Planning Service delivery or business operations are interrupted
Information Security and Information
Governance
Information is not managed securely or that information governance is ineffective.
External Inspections External Inspections adverse findings including Best Value.
Public Protection Non-compliance with legal obligations/failure to provide adequate Public Protection arrangements
Climate Change (mitigation, adaptation and
sustainability)
Failure to develop and implement measures to create and contribute to having a sustainable environment across North
Lanarkshire. This includes all activities in addition to those covered by specific climate change legislation.
Tackling Poverty Poverty issues impacting on the lives and outcomes for people who live in North Lanarkshire.
Information Technology ICT Operational Capability IT solutions do not support the Council
Catastrophic Event Natural / Manmade Disaster Risks arising from a significant prolonged catastrophic event that impacts citizens, staff and service delivery.Page 200 of 238

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Risk Management Strategy 2026
Risk Review Instructions
Why
To ensure that we have thoroughly assessed and understand the risks which have been identified as significant enough to merit inclusion on the Risk Register, and to gain assurance on how
well or otherwise each risk is being managed. Regular reviews of each risk will allow management to understand progress with key actions, any change in risk ratings and the reasons why. 
Reviews will also assist in understanding how the risk could impact the achievement of objectives and provide managers with relevant risk information to aid informed decision making.  It is also
an opportunity to challenge whether the risk remains valid or whether it may be a candidate for closing.
Who
Critical to the process is ensuring that there is appropriate variety and breadth of stakeholder/subject matter expert input to develop information for each risk. This ensures that a balanced,
robust and well-informed view of the risk and its assessment is obtained, and ensures a common understanding of the risk and associated controls and actions amongst staff.
Risk reviews should be undertaken as part of team meetings (either scheduled or specially called for this purpose) or as part of working group meetings. If this is not possible or appropriate, the
review may be conducted remotely gathering input from relevant stakeholders/subject matter experts who are best placed to inform the update to the risk information.
When
Residual Risk Score Risk Rating Review Frequency
25 Very High Monthly
16 – 20 High 3 monthly
9 - 15 Medium 6 monthly
4 - 8 Low 9 monthly
1 - 3 Insignificant Annually
Step
1
Review risk context and wording
Take the opportunity to consider whether the risk itself is still valid, or whether there has been any change in context of the risk or whether the risk requires to be reframed/reworded to be more
relevant.  For example has the risk changed as the result of a change in how the service is delivered, or as a result of a change in the external environment in which we operate.
Step
2
Review Current Key Management Controls
Current risk management controls are those which are designed to mitigate the risk by either reducing the likelihood of occurrence or mitigating the impact of the risk if it does occur. These
should be controls that you know are already in place and are working effectively. Whilst difficult to judge with precision, key controls are those which are significant enough to mitigate the risk
from its inherent level to its current residual level.
By reviewing what is already in place for the risk, you are seeking to confirm:
• Whether the detailed controls are still in place and have the same ownership, confirm with the control owner;
• If they are still in place, can we regard them as still being effective in reducing likelihood or impact;
• If any controls have been removed, this should be detailed and reflected within the risk score and rationale.
• Consider whether there are any controls which you know to be in place which are not currently detailed;
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Risk Management Strategy 2026
Risk Review Instructions
Step
3
Review Planned Management actions
If the residual risk score is too high and deemed unacceptable, it is necessary to agree the appropriate risk response. If it is agreed that the best response is to treat the risk further, then this
section is used to record planned management actions. These are the future actions deemed necessary to bring the risk down from its current “Residual” rating.  If an action is not likely to
contribute to having this effect, then it may not be necessary to include it so that attention can be focussed on the most important controls.
Avoid recording an action that is deemed to be “ongoing” since this is most likely just the same as maintenance of an existing control. Actions should have a target date for completion.
If the list of actions will not in themselves bring the risk down to an acceptable level, then this should be identified, with a clear statement of what future work will be done to identify actions
required.
Conversely, if there are no actions which will reduce the risk further, this should be noted with explanation.
If it has been decided to tolerate the risk at its current residual rating and take no further action, this must also be documented with accompanying rationale.
By reviewing planned management actions you are seeking to confirm:
• Which planned actions have been completed;
• If yes, whether any of these actions now constitutes a new management control which improves the control framework for the risk;
• If yes, the new control should be added to the controls information in Figtree and assigned a control owner;
• If no, record how completion of the action has enhanced or affected an existing control.
• If there are any new actions required, and whether any existing actions require to have new target dates.
• Ensure the action owner is the correct person and that they have a clear understanding of what their action is and timescales.
• Actions should always be linked to a parent control. 
• Consider whether there are any actions that are no longer relevant and should be removed.  (Notify corporate risk team for deletion on Figtree)
Step
4
Risk Assessment stage
In the context of changes made in previous steps, review the overall position to
• Evaluate whether the current inherent risk score remains valid or requires adjustment, considering that internal or external changes may influence the risk’s context and its inherent rating.
• Assess whether the current residual risk score remains accurate or requires adjustment, noting that the risk score could move either up or down depending on the impact of the risk review.
• Ensure “Rationale” is updated to reflect why particular risk scores have been chosen.
• Take time to make sure everything looks correct:
• Is there anything that is not as expected e.g. a residual Risk Rating greater than Inherent Risk Rating
• Is review frequency aligned to the risk rating in accordance with strategy as noted above.
Step
5
Review the remaining sections of the risk information for completeness, ensuring they are complete, relevant and current, noting any reasons for blank sections. Pay particular attention to any
changes in “Risk Context”, relevant to this risk. Bear in mind any potential impact on likelihood and impact scores.
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Risk Management Strategy 2026
Risk Management Reporting
Report title Purpose of report Report
prepared by
Frequency of
report
Reported to
Policy &
Strategy
Committee
Business /
Corporate
Management
Team
Audit &
Scrutiny
Panel
Service
Senior
Management
Teams
Service
Committees
Risk Management -
Corporate Progress
report
Review and monitoring report to provide updates
on key corporate risk management developments,
summary of CRR and any key changes to that during
the period arising from Horizon Scanning activity. 
* Every second report will include a summary of the risk
profile across Service Risk Registers
Corporate
Risk Team
Quarterly
(BMT prior to
ASP)
 
Risk Management
– Service Progress
report
Review and monitoring of service risk management
implementation and summary of service risk register
together with key changes in the period.
* (Including reflection of changes to CRR that occur in
the reporting period)
Service Risk
Champion
liaising with
Service risk
forum
Quarterly
 
Risk Management
year- end report
To report on key activities and achievements in relation
to delivery of the Risk Management Strategy.
* Included in the Chief Officer Audit & Risk Annual
Report.
Corporate
Risk Team
Annual
 
Review of the Risk
Management Strategy
To seek approval for updates made to the Strategy Corporate
Risk Team
Triennially
following each
review of the
Strategy  
Throughout this strategy period, we are committed to enhancing our reporting arrangements by
incorporating visualisations and graphics. These improvements aim to better meet the needs of report
users, support dynamic risk analysis and informed decision making.
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Risk Management Strategy 2026
Guidance for dealing with risk in Committee reports
How is Risk Management
incorporated into the Council’s
decision-making process?
The principles of risk management relating to
decision-making are the same as for any other risk
management process. The table below outlines the
process.
1. Identify any risks associated with the decision
and the implementation of the decision.
2. Assess the impact of the risk and the
likelihood of it occurring.
3. Prioritise and include commentary on any
significant risks/risks with significant potential
impacts in the report.
4. Manage – produce a SMART action plan
setting out how the Council intends to
minimise the impact or reduce the likelihood of
each of the significant risks identified.
5. Review risks with key subject matter experts
and relevant statutory officers and amend the
risk assessment accordingly.
6. Agree risk assessment with decision-maker
clarifying any risks in the risk assessment in
order to allow the decision to be made.
7. Update any Service or project risk registers
following the decision.
Committee report templates include a section ‘Risk
Impacts’. The section requires the author to record
significant risks identified after carrying out a risk
assessment. The risk assessment must record the
risks related to the proposed recommendations(s)
(including the risks of implementation) and the risks
of not taking the recommended action.
What is the purpose of the risk
assessment?
The risk assessment:
• Demonstrates that all significant risks related to
the decision have been considered;
• Provides evidence that the decision-maker has
been provided with sufficient information about
risks in terms of likelihood and impact; and
• Explains how risks will be managed.
What will the risk assessment
record?
The risk assessment should record:
• Risks that may arise if the decision is not
taken;
• Risks that may arise if the decision is taken;
and
• Action that will be taken to manage each risk
documented if the decision is taken.
Who needs to be involved in
compiling the risk assessment?
The report author will take the lead in compiling the
risk assessment using a standard template available
via the intranet. Involvement will vary significantly
depending on the subject matter and the nature of
the decision being sought but may include Subject
matter experts, the relevant Chief Officer, the
Chief Executive, the Council’s S95 officer and the
Monitoring Officer. The report author in consultation
with the appropriate Chief Officer should review the
report and the risk assessment prior to the report
being issued.
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Risk Management Strategy 2026
Do all risks in relation to a proposal
have to be recorded in a risk
assessment?
No. The risks assessment process should be
proportionate to the decision being made. The
report author and others involved should consider
the impact of any associated risk(s) when deciding
whether a risk assessment is required or not. It is
the responsibility of the report author to ensure that
the risk assessment is sufficient for its purpose.  If
the impacts of identified risks are low or negligible
then it is reasonable that the risks are not formally
recorded.
What should I put in the risk
management section of the
committee report template?
Key risks surrounding a decision and how these are
or will be managed should always be highlighted
in the narrative of the report. The audience should
receive assurance that the author has carried out
a proportionate risk assessment related to the
issue and recommendations, in compliance with
the council’s decision-making risk management
guidance.
In offering this assurance the report author is
confirming that:
1. Risk assessment documentation relating to the
decision has been completed and reviewed by
relevant senior management;
2. All significant risks relating to the decision and
how these will be managed are highlighted in
the report; and
3. Risks relating to the decision have, as
appropriate, been included in Service or
Project risk registers and will be managed
and subject to monitoring and review
in accordance with the council’s risk
management strategy
Will the risk assessment be
accessible to the public?
The risk assessment will not be published with the
Committee papers (although the Committee report
will confirm that a risk assessment exists to support
the decision sought in the report). However, risk
assessments will be subject to the normal rules of
disclosure under the Freedom of Information Act
2000 and other relevant legislation. 
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Risk Management Strategy 2026
Training and Awareness
Training and awareness materials will be developed
to support colleagues in their role within the
framework.
All employees and elected members are required
to complete the Introduction to Risk Management
E-learning mandatory training module.
Risk Champions and Risk Facilitators will have the
opportunity to complete accredited Enterprise Risk
Management training as part of their responsibilities.
Targeted training material will be developed to
support colleagues in their specific role within the
risk management framework.
Awareness materials will be made available to
colleagues through the most appropriate channels.
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Risk Management Strategy 2026
Glossary of Risk Management Terms
Glossary of Risk Management Terms
Context Context means the external and internal parameters that organisations must consider when they manage risk.
External context includes external stakeholders, local, national, and international environment, as well as any external factors that influence objectives. It includes social,
cultural, political, legal, regulatory, technological, economic, natural, and competitive environment.
Internal context includes internal stakeholders, approach to governance, contractual relationships, capabilities, culture, and standards.
Corporate Governance The framework of accountability to users, stakeholders, and the wider community, within which organisations take decisions and lead and control their functions to achieve
their objectives
Ever Present Risk Risks that are ubiquitous in nature, are ever present within an organisation and will always command the attention of senior management
Exposure The susceptibility to loss.
Impact Effect or consequences of a risk. Examples of a range of impacts can be found in the Impact Matrix.
Inherent Risk The exposure arising from a specific risk if no controls were in place to manage it.
Likelihood The chance that something might happen. Likelihood can be defined, determined, or measured objectively or subjectively and can be expressed either qualitatively or
quantitatively.
Mitigating Action Any action that seeks to reduce the likelihood or impact of a risk event to an acceptable level.
Monitoring To supervise, check and critically observe on an ongoing  basis. Monitoring will help determine the current status and assess whether or not required or expected
performance levels are being achieved.
Operational Risk Risks associated with the day-to-day issues facing the organisation in its service delivery, i.e., human error, system failures, inadequate procedures, and controls.
Opportunity Risk An uncertain event, which should it occur, could have a potential positive effect on objectives
Probability Extent to which a risk event is likely to occur. A measure (expressed as a percentage) of likelihood.
Residual Risk The level of risk remaining taking risk control measures into account.
Risk An adverse event or set of events, which should it occur, will have an impact on the achievement of objectives. Risk is measured by the combination of the “likelihood” of
the event occurring, and the “impact” on our objectives if it does.
Risk Analysis The use of information to work out how often risk events might occur and the magnitude of their consequences.
Risk Tolerance The Council’s attitude towards risk taking, which in turn dictates the amount of risk it considers tolerable or acceptable.
Risk Appetite An expression of how much uncertainty the Council is willing to invite into its processes in pursuit of objectives.
Risk Assessment The overall process of risk identification, risk analysis and risk evaluation. 
Risk Categories Risks are categorised into different types. The Council’s categories are Strategic, Financial, Operational, Legislative & Regulatory, Human Resources and Information
Natural/Manmade Disaster
Risk Control A control is any measure or action that modifies, Controls include any policy, procedure, practice, process, technology, technique, method, or device that modifies or
regulates risk. Risk treatments become controls or modify existing controls once they are implemented. 
Risk Evaluation The process of comparing the net effect of the scores of the analysed risks to make decisions about their significance in relation to our priorities, objectives and targets. 
Risk Financing The provision of funds to meet the cost of implementing risk treatments, including, but not limited to, insurance.
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Glossary of Risk Management Terms
Risk Identification The process by which risk events, which could affect the organisation’s objectives, are identified, described, and recorded.
Risk Management The co-ordinated activities to direct and control an organisation with regard to risk. It covers the processes involved in identifying, assessing, and prioritising risks, assigning
ownership, taking actions to prevent or mitigate them, and monitoring and reviewing progress.
Risk Management Policy
Statement
A high-level statement showing how Risk Management will be handled throughout the Council.
Risk Management
Strategy
Describes the goals of applying Risk Management to the activity, a description of the process that will be adopted, the roles and responsibilities, risk thresholds, the timing
of Risk Management interventions, the deliverables, the tools, and techniques that will be used and the reporting requirements. It also describes how the process will be
co-ordinated with other management activities.
Risk Matrix A model that visually displays the relationship between the likelihood and impact of specific risks. Visually it is a 5x5 box that plots likelihood and impact as Insignificant,
Low, Medium, or High.
Risk Owner A risk owner is a person or entity that has been given the authority to manage a particular risk and is accountable for doing so.
Risk Prioritisation The process of ranking risks into a logical order by establishing how significant they are in terms of likelihood and impact (NB Impact is given priority over probability when
prioritising risks).
Risk Profile The overall picture of the Council’s, Services, or Team’s risks including the number of risks and their scores.
Risk Register A formal listing of identified risks, together with the results of the risk analysis and risk evaluation procedures, as well as details of any risk responses. Helps decision makers
prioritise resources to minimise risk to best effect and provide assurances that progress is being made.
Risk Response Selection and implementation of appropriate options to further minimise the likelihood or impact of an identified risk.
Strategic Risk Risk concerned with where the Council wants to go, how it plans to get there and how it can ensure survival.
Terminate Avoid or eliminate the risk exposure or activity giving rise to the risk so that it no longer presents a risk to manage.
Threat Risk An uncertain event, which should it occur, could have a potential negative effect on objectives
Tolerate An informed decision to accept the likelihood and the impact of a particular risk rather than trying to mitigate it further. This is usually because there are certain benefits to
be gained, or the cost and effort of implementing further control measures is disproportionate to the risk.
Transfer An informed decision to transfer all or part of the risk to another party i.e., through contract terms, insurance etc.
Treat Implement cost effective actions to modify the risk to a more tolerable level.
Uncertainty A condition where the outcome can only be estimated.
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CC_2025_00305
Produced by
NORTH LANARKSHIRE COUNCIL
Donald Stone
Corporate Risk Manager
Chief Executives Office
Civic Centre, Windmillhill Street
Motherwell ML1 1AB
e. StoneD@northlan.gov.uk
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North Lanarkshire Council Report 
Audit and Scrutiny Panel 
Does this report require to be approved? ☐ Yes   ☒ No
Ref    FS/CFP/ASP/May26 Date 14/05/26 
Corporate Fraud Policy 
From  Francis Scott, Chief Officer (Audit and Risk)  
E-mail scottfr@northlan.gov.uk       
Executive Summary 
The Council’s Counter Fraud Policy details the Council’s approach to the prevention,
detection and investigation of fraud across all Council service areas.  This version of the
Policy was approved by the Policy and Strategy Committee in March 2026.   
The Policy has been recently reviewed to ensure the document remains consistent with
good practice and continues to reflect the Council’s attitude, approach and response to
fraud.  The content of the revised Policy remains broadly similar to the previous version. 
One key addition to the Policy is a section to highlight the requirements of the Economic
Crime and Corporate Transparency Act 2023, which introduced a corporate offence of the
failure to prevent fraud.  The title of the document has also been changed, from the Counter
Fraud Policy to the Corporate Fraud Policy. 
Recommendation
It is recommended that the Audit and Scrutiny Panel: 
1. Note the key changes to the Policy and the implications of the new legislation; and 
2. Note the approved Corporate Fraud Policy (at Appendix 1).  
The Plan for North Lanarkshire
Priority  All priorities
Ambition statement All ambition statements
Programme of Work All Programmes of Work
Item 12
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1. Background 
1.1 North Lanarkshire Council has a zero-tolerance approach to fraud.  The Corporate
Fraud Policy details the Council’s approach to the prevention, detection and
investigation of fraud across all Council service areas and outlines the responsibilities
of all officers and members in relation to fraud. 
2. Report 
2.1 The Council’s previous Counter Fraud Policy was approved by the Policy and Strategy
Committee in September 2023.  A scheduled review of this policy was recently
undertaken to ensure that it remained relevant and up to date, consistent with good
practice and continues to reflect the Council’s attitude and response to fraud. 
2.2 While some amendments have been made to the format and structure of the Policy,
the content remains broadly similar to the version approved in 2023. 
2.3 The main change to the Policy is the inclusion of a section detailing the key elements
of the Economic Crime and Corporate Transparency Act 2023 (ECCTA), including: 
• The introduction of the offence of the failure to prevent fraud.  This offence
allows large organisations to be held accountable for fraudulent acts committed
by employees, agents, subsidiaries or other associated persons.  Organisations
found guilty of this offence may be subject to unlimited financial penalties on
conviction.
• A corporate defence for organisations that they will not be held liable for this
offence if they can demonstrate that they had reasonable procedures in place to
prevent fraud.  To rely on this defence, an organisation must ensure its specific
risk profile, determined through fraud risk assessments, is reflected in its control
framework.
• UK Government guidance outlining the key principles organisations should follow
when establishing a fraud prevention framework as part of the corporate defence. 
2.4 As part of the review, and to better align with the changes made, the title of the
document has also been changed from the Counter Fraud Policy to the Corporate
Fraud Policy. 
2.5 The revised Corporate Fraud Policy was approved by Policy and Strategy Committee
in March 2026.  Following this approval, the Chief Officer (Audit and Risk) and the Chief
Officer (Legal and Democratic) will undertake an exercise to ensure that the key
components of the Policy and the requirements of the new legislation are
communicated to all relevant officers for awareness and understanding. 
3. Measures of success 
3.1  Up to date policies and associated processes will contribute towards having effective
corporate fraud arrangements which are an important part of the framework designed
to help prevent and detect fraud and to deal with it effectively when it occurs.   
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4. Supporting Documentation 
Appendix 1 – Corporate Fraud Policy 
Francis Scott
Chief Officer (Audit and Risk) 
5. Impacts 
5.1 Public Sector Equality Duty and Fairer Scotland Duty 
Does the report contain information that has an impact as a result of the Public
Sector Equality Duty and/or Fairer Scotland Duty? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact? 
If Yes, has an assessment been carried out and published on the council’s
website? https://www.northlanarkshire.gov.uk/your-community/equalities/equality-
and-fairer-scotland-duty-impact-assessments 
Yes ☐ No ☐
5.2 Financial impact 
Does the report contain any financial impacts? 
Yes ☐ No ☒ 
If Yes, have all relevant financial impacts been discussed and agreed with
Finance? 
Yes ☐ No ☐ 
If Yes, please provide a brief summary of the impact?
5.3 HR policy impact 
Does the report contain any HR policy or procedure impacts? 
Yes ☒ No ☐ 
If Yes, have all relevant HR impacts been discussed and agreed with People
Resources? 
Yes ☒ No ☐ 
If Yes, please provide a brief summary of the impact?
Sections relating to investigations and the relationship between this policy and other
relevant HR policies has been discussed with HR.
5.4 Legal impact 
Does the report contain any legal impacts (such as general legal matters, statutory
considerations (including employment law considerations), or new legislation)? 
Yes ☒ No ☐ 
If Yes, have all relevant legal impacts been discussed and agreed with Legal and
Democratic? 
Yes ☒ No ☐ 
If Yes, please provide a brief summary of the impact?
Sections relating to investigations and the relationship between this policy and other
relevant policies and statutes have been discussed with Legal Services.
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Does the report / project / practice contain or involve the processing of personal
data?   
Yes ☐ No ☒ 
If Yes, is the processing of this personal data likely to result in a high risk to the
data subject? 
Yes ☐ No ☐ 
If Yes, has a Data Protection Impact Assessment (DPIA) been carried out and e-
mailed to dataprotection@northlan.gov.uk 
Yes ☐ No ☐
5.6 Technology / Digital impact 
Does the report contain information that has an impact on either technology, digital
transformation, service redesign / business change processes, data management,
or connectivity / broadband / Wi-Fi? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact? 
Where the impact identifies a requirement for significant technology change, has
an assessment been carried out (or is scheduled to be carried out) by the
Enterprise Architecture Governance Group (EAGG)? 
Yes ☐ No ☐
5.7 Environmental / Carbon impact 
Does the report / project / practice contain information that has an impact on any
environmental or carbon matters? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact?
5.8 Communications impact 
Does the report contain any information that has an impact on the council’s
communications activities? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact?
5.9 Risk impact 
Is there a risk impact? 
Yes ☒ No ☐ 
If Yes, please provide a brief summary of the key risks and potential impacts,
highlighting where the risk(s) are assessed and recorded (e.g. Corporate or
Service or Project Risk Registers), and how they are managed?
New legislation introduces corporate offence of failure to prevent fraud, for which
large organisations such as the Council can be liable for unlimited financial
penalties.  The defence against this is having reasonable procedures in place to
prevent fraud, including an assessment of fraud risk in the organisation.
5.10 Armed Forces Covenant Duty 
Does the report require to take due regard of the Armed Forces Covenant Duty (i.e.
does it relate to healthcare, housing, or education services for in-Service or ex-
Service personnel, or their families, or widow(er)s)? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the provision which has been made to
ensure there has been appropriate consideration of the particular needs of the
Armed Forces community to make sure that they do not face disadvantage
compared to other citizens in the provision of public services.
5.11 Children’s rights and wellbeing impact 
Does the report contain any information regarding any council activity, service
delivery, policy, or plan that has an impact on children and young people up to the
age of 18, or on a specific group of these? 
Yes ☐ No ☒
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If Yes, please provide a brief summary of the impact and the provision that has
been made to ensure there has been appropriate consideration of the relevant
Articles from the United Nations Convention on the Rights of the Child (UNCRC). 
If Yes, has a Children’s Rights and Wellbeing Impact Assessment (CRWIA) been
carried out? 
Yes ☐ No ☐ 
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CORPORATE
FRAUD POLICY  
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2 
Document control
Title Corporate Fraud Policy
Owner Francis Scott, Chief Officer (Audit and Risk) Contact scottfr@northlan.gov.uk
Governance Group Policy and Strategy Committee
Author Francis Scott, Chief Officer (Audit and Risk) Contact scottfr@northlan.gov.uk 
Revision History
Number Originator Date Review Commenced Revision description/record of change
1.0 Ken Adamson June 2023 Update and refresh of full policy 
2.0 Francis Scott December 2025 Update and refresh of full policy     
Document Approvals
Number Governance
Group
Date approval granted Date approval to be requested 
(if document still draft)
1.0 Policy and
Strategy
28/09/23 
2.0 Policy and
Strategy 
19/03/26     
Consultation Record (for most recent update)
Status of document consulted upon N/A
Stakeholders consulted/date N/A 
Strategic Alignment
The Corporate Fraud Policy highlights the Council’s zero tolerance approach to fraud and outlines how fraud risks will be
managed across the organisation and how suspected or identified fraud will be managed as part of robust corporate
governance arrangements designed to enable and support the delivery of all Council ambitions and priorities. 
Next review date
Review Date December 2027 (for approval at Policy and Strategy Committee in March 2028).
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3 
CONTENTS
1 Introduction 4
2 Zero-Tolerance Approach 4
3 Offence of Failure to Prevent Fraud 5
4 Responsibility for Managing Fraud Risk 5
5 Fraud Reporting 7
6 Investigation Process 9
7 Investigation Outcomes 10
8 Media Contact 10
9 Joint Working 11
10 Fraud Training and Awareness 11
11 Conclusion 11 
Appendix A – Definitions of Fraud 12 
Appendix B – Examples of Fraud Risks for Council Services 13 
Appendix C – List of Related Documents 14 
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1. INTRODUCTION
1.1 The Corporate Fraud Policy outlines the Council’s commitment to preventing,
detecting and investigating fraudulent activities across all the Council’s service areas,
ensuring ethical conduct and compliance with legislation.
1.2 Fraud is defined as the deliberate use of deception or dishonesty to disadvantage or
cause loss to another person or party.  Fraud includes a wide variety of dishonest
behaviour such as theft, false accounting, embezzlement, forgery, bribery, corruption,
deception, false representation, concealment of material facts and other intentional
acts designed to deceive others for personal gain.  Fraud can occur within the Council
or can be perpetrated against the Council by outside parties.
1.3 The scope of this policy extends to all employees, elected members, service users,
contractors, agencies and suppliers and other partner organisations, including the
voluntary sector. 
2. ZERO-TOLERANCE APPROACH
2.1 North Lanarkshire Council has a zero-tolerance approach to fraud.
2.2 The Council expects its staff to act honestly, with integrity and to safeguard public
resources for which they are responsible.  The Council aims to conduct its business in
an honest and ethical manner and is committed to acting professionally, fairly and
with integrity in all its dealings and relationships wherever it operates.
2.3 Any instances of fraud will be investigated thoroughly, and employees found to have
been involved in fraudulent activity will be subject to disciplinary action, including
termination of employment and other relevant legal consequences.  The Council will
seek to recover any loss suffered because of fraud.
2.4 The Council is committed to ensuring that opportunities for fraud are minimised and
will actively co-operate and share information with other local authorities and public
sector bodies to assist in the prevention, detection and investigation of fraud. 
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3. OFFENCE OF FAILURE TO PREVENT FRAUD
3.1 The Economic Crime and Corporate Transparency Act 2023 (ECCTA) introduced the
new offence of the failure to prevent fraud.  This objective of this provision is to make
it easier to hold large organisations (such as the Council) accountable for fraudulent
acts committed by employees, agents, subsidiaries or other associated persons. 
Organisations found guilty of this offence may be subject to unlimited financial
penalties on conviction.  
3.2 ECCTA provides a defence for organisations that they will not be held liable for the
“failure to prevent fraud” offence if it can demonstrate that, at the time the fraud was
committed, it had reasonable procedures in place to prevent fraud.  To rely on this
defence, organisations must implement procedures that reflect their specific risk
profile, determined through risk assessment – the Council should assess the
likelihood of frauds being committed and based on those findings, review and revise
their existing controls.
3.3 The UK Government has issued guidance outlining six key principles that
organisations should follow when establishing a fraud prevention framework:
• Top Level Commitment – senior management must actively demonstrate a
clear commitment to the prevention of fraud.
• Risk Assessment – organisations should evaluate the nature and extent of their
exposure to fraud risk, ensuring these assessments are documented and
reviewed.
• Fraud Prevention Procedures – based on identified risks, organisations should
implement proportionate, risk-based procedures as part of a comprehensive
fraud prevention strategy.
• Due Diligence – organisations must carry out appropriate, risk-based due
diligence to identify and mitigate potential fraud risks.
• Effective Communication – fraud prevention procedures must be clearly
communicated and embedded across the organisation, with strong emphasis
on training and ongoing education.
• Monitoring and Review – organisations should continuously monitor the
effectiveness of their procedures and make improvements where necessary to
ensure they remain fit for purpose. 
4. RESPONSIBILITY FOR MANAGING FRAUD RISK
4.1 Managers, staff and elected members must always be alert to the risk of fraud.  The
prevention, detection and reporting of fraud are the responsibility of all members,
officers and employees of the Council.
4.2 The Chief Executive has overall responsibility for the operations and activities of the
Council.  This includes overall responsibility to ensure that the Council’s management
arrangements in respect of fraud are adequate and effective and that any lessons to
be learned corporately from any fraud occurrences arising are appropriately
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addressed.
4.3 The Deputy Chief Executive and all Chief Officers are expected to display high
personal standards of conduct in accordance with the Chief Officers’ Code of Conduct
and are responsible for establishing and maintaining a sound system of internal
control within their areas of responsibility which supports the achievement of
Council policies, aims and objectives.  The system of internal control is designed to
respond to and manage the wide range of risks which the Council faces, including
minimising the scope for fraud.  Chief Officers should ensure that their employees
are made aware that they should report any matter arising which involves, or is
thought to involve, a fraud or irregularity.
4.4 The Chief Officer (Finance and Technology) has a duty, in accordance with Section
95 of The Local Government (Scotland) Act 1973, to make proper provision for the
administration of the Council’s financial affairs.  Proper administration includes
ensuring that an adequate system of financial control exists and operates effectively
throughout the Council.
4.5 The Chief Officer (Audit and Risk) is responsible for:
• Reviewing and reporting on the Council’s control environment for the
prevention of fraud.
• Establishing and maintaining an effective corporate fraud policy,
commensurate to the level of fraud risk identified, including establishing
appropriate mechanisms for staff to report suspected fraud risk issues.
• Disseminating the Council’s Corporate Fraud Policy to all staff to ensure that
they are aware of their responsibilities in relation to preventing and combating
fraud.
• Ensuring that vigorous, prompt and proportionate investigations are carried out
where fraud occurs or is suspected, and reporting to the Service, Chief Executive
and Audit and Scrutiny Panel on the outcome of these investigations.
• Co-ordinating assurances about the effectiveness of anti-fraud arrangements
to support the Statement of Internal Financial Control and the Council’s Annual
Governance Statement.
• Notifying the Council’s External Auditors regarding all frauds over £5,000.
• Liaising on fraud matters with other relevant stakeholders, including the Audit
and Scrutiny Panel and the Risk Management Corporate Working Group.
4.6 All Chief Officers and managers are responsible for:
• In line with the Council’s Risk Management Strategy, identifying and analysing
potential fraud risks for their service area.
• Designing and implementing an adequate system of internal control to mitigate
these risks and ensuring that that these controls are operating effectively and
are being complied with.
• Ensuring that any fraud or suspected fraud or irregularity is reported promptly.
4.7 All employees and elected members are responsible for:
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• Complying with relevant codes of conduct, council policies and procedures,
including declaring and registering relevant conflicts of interest and offers of
gifts or hospitality.
• Ensuring that the Council's procedures and management arrangements
designed to mitigate fraud and corruption risks facing the Council operate
effectively.
• Reporting any suspicion of fraud or irregularity promptly. 
4.8 The Audit and Risk team is responsible for:
• Assisting in the prevention and detection of fraud by examining and evaluating
the adequacy and effectiveness of controls in line with the annual Internal Audit
Plan and in accordance with the Global Internal Audit Standards (GIAS).
• Ensuring management has considered and identified the possibility of fraud as
a business risk and has included any such fraud risks in their risk register. 
5. FRAUD REPORTING
EMPLOYEES
5.1 The Council accepts that, to enable the process for reporting concerns of serious
wrongdoing within the Council to have credibility, employees must have the
confidence that any matter highlighted will be treated confidentially and handled with
discretion and tact.  
5.2 In the first instance, employees should report any issue or suspicion of fraud or
irregularity at the earliest possible stage, to their Line Manager or Chief Officer.  If they
do not feel that this is appropriate, they may contact the Chief Officer (Audit and Risk)
or email the Internal Audit mailbox internalaudit@northlan.gov.uk.  Anonymous
reports will be accepted and followed up by Internal Audit where possible, however,
this should be avoided as it could hinder the investigation if further information is
required.  
5.3 An employee wishing to raise any matter on a confidential basis may do so using the
Council’s whistleblowing arrangements, which are part of the Public Interest
Disclosures Policy.  This Policy is consistent with the Public Interest Disclosure Act
1998, with respect to the disclosure of information by employees, and all matters
highlighted under these arrangements will be dealt with in confidence and in strict
accordance with the terms of the policy.  This statute protects the legitimate personal
interests of staff irrespective of how an allegation is highlighted.   The Policy is located
at Whistleblowing Procedure.
5.4 Individuals who refuse to accept an offer or bribe and wish to raise concerns or report
another’s wrongdoing are sometimes worried out possible repercussions.  The
Council aims to encourage openness and will aim to support anyone who raises
genuine concerns in good faith under the Public Interest Disclosures policy.  Whilst
reports of suspected or actual fraud will be dealt with sensitively, it may not always be
possible to deal with fraud allegations on a confidential basis, however, the Council
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will, wherever possible, observe the wishes of an employee raising concerns who does
not wish their identity to be disclosed.
5.5 The Council is committed to ensuring that no-one suffers any detrimental treatment
by refusing to take part in bribery or corruption or reporting suspicion of fraud. 
Detrimental treatment includes dismissal, disciplinary action, threats or other
unfavourable treatment connected with raising a concern.  If someone believes that
they have suffered such treatment, they should inform the officer who received the
original report immediately.  If the matter is not remedied, this should be raised
formally using the Dignity at Work Policy. 
ELECTED MEMBERS, THIRD PARTIES AND MEMBERS OF THE PUBLIC
5.6 The Council is committed to dealing with any allegation of fraud brought to its
attention by Elected Members, third parties (e.g. contractors, suppliers, organisations)
and members of the public.  Elected Members should report any concerns of fraud
directly to the Chief Officer (Audit and Risk).  Third parties and members of the public
can contact the Chief Officer (Audit and Risk) or email internalaudit@northlan.gov.uk. 
BENEFIT FRAUD
5.7 The Department for Work and Pensions (DWP) Single Fraud Investigation Service (SFIS)
are responsible for investigating Housing Benefit Fraud. All matters relating to the
allegation of fraud in respect of Housing Benefit should be reported directly to the
DWP via the online referral form, which can be found here.    Further information on
reporting fraud relating to benefits administered by Social Security Scotland can be
found here.
5.8 Fraud referrals from Council staff should initially be made to the Council’s Appeals
and Adjudication team where the report will be added to the SFIS referral form and
passed for investigation. 
PROCEDURES FOR CHIEF OFFICERS AND MANAGERS NOTIFIED OF FRAUD
5.9 Managers and Chief Officers notified of instances of fraud or irregularity must
immediately notify the Chief Officer (Audit and Risk).
5.10 On being informed by an employee of a fraud, it is important that the manager
receiving the information deals with it appropriately.  In particular, the manager
should:
• Deal with the employee giving the information in a way that shows that their
concerns are being taken seriously.
• Not belittle or dismiss the information.
• Respect, as far as possible, the confidentiality of the employee.
• Attempt to identify where any evidence may be but should not attempt to
obtain it, or question anybody.
• Pass the information to the Chief Officer (Audit and Risk).
5.11 Line managers should not conduct their own investigations before informing the Chief
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Officer (Audit and Risk) as this may compromise any later investigation, invalidate
evidence and consequently enable someone who has committed fraud to avoid
punishment.
5.12 Circumstances may require the temporary relocation or suspension of an employee. 
Such decisions rest with the appropriate Chief Officer and must be in accordance with
relevant Council policies including the Discipline Policy.  It is recommended that HR
advice is sought before a member of staff is suspended.  In circumstances where an
employee is suspended, they should be escorted from the premises immediately, only
being allowed to remove personal belongings under supervision.  All IT devices held
by the employee should be retrieved and the employee’s access to the Council’s
network should be suspended.  The Chief Officer (Audit and Risk) must be advised of
any such action taken by the Chief Officer as soon as possible. 
6. INVESTIGATION PROCESS
6.1 The Chief Officer (Audit and Risk) is responsible for determining what course of action
should be taken when notified of allegations or concerns of possible fraud.  The audit
approach to the investigation of a potential fraud is likely to vary depending on the
nature and complexity of the fraud, the number and seniority of employees involved
and the nature of the Service in which the suspected fraud has occurred.  All
investigations will be undertaken in a manner that ensures confidentiality and
fairness, and where possible the anonymity of those reporting the fraud will be
respected.
6.2 Internal Audit’s role in relation to fraud is to act as an independent investigator to
establish whether there is any substance to allegations made.  This role includes
establishing the facts as far as possible, quantifying any loss, identifying any control
weaknesses or failures, recommending improvements to address control
weaknesses, providing a written factual report on the fraud to the relevant Chief
Officer and attending any subsequent disciplinary proceedings, where appropriate, in
the role of witness.
6.3 The Council’s Financial Regulations and Internal Audit Charter give Internal Audit staff
unrestricted access to all Council records and authority to enter all Council premises
or land at all reasonable times.  Internal Audit staff can also require and expect to
receive any explanations from Council staff as considered necessary to fulfil their role
and responsibilities.
6.4 As part of any fraud investigation, Internal Audit will be required to interview Council
employees.  This may take the form of a general fact-finding interview, or the
employee may be called to an investigative interview to answer questions specifically
in relation to the alleged or suspected fraudulent activity.  In the latter case, the
employee will be notified in advance of their right to Trade Union or other
representation at the interview.  In either type of interview, the employee will be
advised of the reasons for the interview and, where appropriate, cautioned by Internal
Audit staff, thus ensuring any statement taken and subsequently used as evidence in
disciplinary proceedings or in court, will not be rejected as inadmissible.
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6.5 Two officers will always be present when conducting any such interviews, one asking
questions and one taking notes.
6.6 On completion of an investigation, a written report will be prepared by the Chief
Officer (Audit and Risk) and sent to the relevant Chief Officer detailing the findings of
the investigation.  The report may include recommendations to improve controls, to
mitigate the threat of similar frauds re-occurring in the future.  Details of this report
will also be presented to the Audit and Scrutiny Panel.
6.7 If the value of the fraud is greater than £5,000, the Chief Officer (Audit and Risk) is
required to report the details to the Council’s External Auditor. 
7. INVESTIGATION OUTCOMES
7.1 Fraud is a serious offence against the Council, and several outcomes are possible from
the investigation processes.
7.2 Employees found to have been involved in fraudulent activity will be subject to
disciplinary action in line with the Council’s Discipline Policy.  Internal Audit staff
involved in the investigation, will attend any subsequent disciplinary hearing as a
witness, if requested.  Where the disciplinary process concludes that the employee’s
actions are deemed to be gross misconduct, the employee can be summarily
dismissed with no entitlement to notice.
7.3 If there is evidence to support involvement in an alleged criminal offence, the Chief
Officer (Audit and Risk) will make the decision to refer the case to Police Scotland.  Any
such decision requires to be approved by the Chief Executive.  Where the incident
involves a break-in, Services are authorised to contact the Police immediately.
7.4 The Council will seek to recover any financial loss it has suffered through fraudulent
or corrupt activity, through means such as salary recovery, court compensation or by
pursuing civil action.  Any party or person committing fraudulent activity or behaviour
against the Council may be subject to relevant measures as available to the Council
and other relevant agencies under the law.  These may include warnings, recovery of
losses through legal action, fines, interest charges and custodial sentences. 
8. MEDIA CONTACT
8.1 The Senior Strategic Communications Manager has been designated by the Chief
Executive as the appropriate officer to manage all contact with the media to ensure
that the release of information is properly co-ordinated. 
8.2 No statements relating to actual or alleged fraud, or any ongoing or complete
investigations should made to the press or on social media by any member of staff
unless through the Senior Strategic Communications Manager, who will liaise with the
Chief Executive, Deputy Chief Executive and the Chief Officer (Audit and Risk). 
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9. JOINT WORKING
9.1 The Council participates in the National Fraud Initiative, a comprehensive data
matching exercise between public bodies to highlight potential frauds and errors. 
Internal Audit plan and co-ordinate the submission of data and investigation of
matches identified. 
9.2 The Council is an active member of the National Anti-Fraud Network (NAFN) and the
Scottish Local Authority Investigator’s Group (SLAIG) and liaises closely with other
public sector bodies and fraud professionals to raise awareness of the risk of fraud
and share information, knowledge and good practice regarding common fraud risks.  
9.3 The Council, where appropriate, provides information to other public bodies which
has been requested under Schedule 2 part 1(2) of the Data Protection Act 2018 to
assist in the prevention and detection of crime. The Chief Officer (Legal, Democratic
and Strategy) co-ordinates this process and maintains a log of all requests received,
together with appropriate documentation. 
10. FRAUD TRAINING AND AWARENESS
10.1 Training on Fraud Awareness in Local Government is available to all staff as an e-
Learning module.  The content of this training has been updated to reflect the
requirements of ECCTA.
10.2 Internal Audit will undertake exercises to raise fraud awareness amongst Council
employees on a periodic basis, including the communication of the Corporate Fraud
Policy. 
11. CONCLUSION
11.1 The Council recognises the importance of making best use of public resources and of
demonstrating high standards of corporate governance.  The Council takes a zero-
tolerance approach to fraud, and all cases of actual and suspected fraud will be
vigorously and promptly investigated, with appropriate action taken.
11.2 The policy will be scheduled for review every two years and may be updated within
this timescale to reflect any required amendments or changes to legislation. 
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APPENDIX A – DEFINITIONS OF FRAUD
Bribery A bribe is an offer, promise, gift or receipt of a financial or other
advantage, designed to induce another person to act improperly in
the performance of their functions, to reward them for acting
improperly or where the recipient would act improperly by accepting. 
A person acts improperly where they act illegally, unethically,
contrary to an expectation of good faith or impartiality, or where they
abuse a position of trust.  The improper acts may be in relation to any
business or professional activities, public functions, acts in the course
of employment, or other activities by, or on behalf of, any
organisation of any kind.
Corruption Corruption is the abuse of entrusted power or position for personal
gain.
Money Laundering Money laundering is the process by which criminally obtained money
or other criminal property is exchanged for ‘clean’ money or other
assets with no obvious link to their criminal origins.  The aim of this
activity is to legitimise the possession of such monies through
circulation, and this effectively leads to ‘clean’ funds being received in
exchange.
Insider Threat Insider threat is a perceived threat to an organisation that comes
from people within the organisation who have inside information
concerning the organisation’s security practices, data and computer
systems.  The threat may involve fraud, theft of confidential or
commercially valuable information, theft of intellectual property or
sabotage of computer systems.
Serious Organised
Crime
Serious organised crime (SOC) refers to criminal activity that is
planned, co-ordinated and committed by individuals or groups.  The
motivation for these crimes is often financial gain.  Examples of SOC
include money laundering, fraud, bribery and corruption, cyber-
crime, illegal firearms, illegal drugs, child sexual exploitation, modern
slavery and human trafficking.
Tax Evasion The Criminal Finances Act 2017 created two new corporate criminal
offences in relation to the failure to prevent facilitation of UK and of
foreign tax evasion.  Tax evasion is defined as the deliberate and
dishonest evasion of tax or knowingly taking steps to facilitate
another person to evade tax.  The Council would be guilty of an
offence if a person commits a UK tax evasion facilitation offence
when acting in the capacity of a person associated with the Council. 
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APPENDIX B – EXAMPLES OF FRAUD RISKS FOR COUNCIL SERVICES
Payroll False employees; fraudulent overtime claims or expenses
Employees Misappropriation of money, equipment, expenses; time recording irregularities;
undeclared conflicts of interest
Tenancy Fraudulent applications for housing/successions of tenancy; subletting of
properties
Benefits  Fraudulent applications; failure to declare sources of income or capital; failure to
declare changes of circumstances (DWP responsible for benefit fraud)
Council tax Fraudulent applications for discounts and exemptions or council tax support
Business rates Fraudulent applications for exemptions and reliefs; unlisted properties
Procurement  Tendering issues including conflicts of interest, collusion, disclosure of sensitive
information; attempting to influence Council processes and/or decision-making
Payment of
creditors
False invoices, inappropriate changes of bank details; double invoicing
Social care
fraud
Overstatement of needs through false declaration; multiple claims across
authorities; third party financial abuse by carer, family or organisations;
posthumous continuation of claims; including personal budgets
Schools Theft of monies
Identity fraud False identity/fictitious persons applying for services/ payments
Blue badges Use of counterfeit/altered badges; use when disabled person is not in the vehicle;
use of deceased person’s badge; corporate badges being misused by employees
Grants Fraudulent claims; work not carried out; funds diverted; ineligibility not declared
Cyber crime A range of fraud types resulting in diversion of funds, creation of false applications
for services and payments
Insurance
Fraud
False claims, including slips and trips
Concessionary
travel
Use of concession by ineligible person
Immigration False entitlement to services and payments, sham marriages
Tax evasion Failing to identify workers/contractors that should be paid via payroll (IR35), failure
to deduct income tax at the correct rate, Construction Industry Scheme – suppliers
submitting artificially low labour breakdown on their invoices to avoid tax being
deducted on labour element
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APPENDIX C – LIST OF RELATED DOCUMENTS
The following list of documents includes other existing policies, procedures and guidance
notes which touch upon issues which are of relevance, or are closely related, to fraud
matters.  The list is not exhaustive and will be subject to periodic update without requiring
a formal review of this policy. 
• Scheme of Delegation
• Contract Standing Orders
• Financial Regulations
• Public Interest Disclosures Policy (Whistleblowing)
• Discipline Policy
• Chief Officers’ Code of Conduct
• Employees’ Code of Conduct
• Acceptable Use of ICT Policy
• Information Security Policy
• Policy and Procedure on Directed Surveillance, Use of Covert Human Intelligence
Sources and Obtaining Communications Data
• Procurement Journey Route maps and tender toolkit 
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North Lanarkshire Council
Report
Audit and Scrutiny Panel 
Does this report require to be approved? ☐ Yes   ☒ No
Ref     FS/ASP/NFI Date 14/05/26 
National Fraud Initiative - Update 
From  Francis Scott, Chief Officer (Audit and Risk)  
E-mail scottfr@northlan.gov.uk 
Executive Summary
The purpose of this report is to inform the Panel of the progress made to date by the Council
in response to the 2024 National Fraud Initiative (NFI) data matching exercise.  This
exercise is now complete, and preparations are underway for NFI 2026, therefore this
report confirms the final outcome of the NFI 2024 exercise. 
The NFI in Scotland is a counter-fraud data matching exercise led by Audit Scotland and
overseen by the Public Sector Fraud Authority for the UK as a whole. The exercise is
undertaken every two years and is recognised as an important tool in preventing and
detecting fraud. It involves comparing data sets from a range of public bodies to identify
inconsistencies and anomalies which may be indicative of possible fraud or error. This
information enables public bodies to follow-up matches on a targeted and prioritised basis
to establish if fraud has occurred and to take appropriate action. 
Recommendations
It is recommended that the Panel note the contents of the report and the progress made to
date.  
The Plan for North Lanarkshire
Priority  All priorities
Ambition statement All ambition statements
Programme of Work All Programmes of Work
Item 13
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1. Background 
1.1 The NFI is a UK-wide exercise which assists public bodies in detecting possible fraud
and error. It is led by Audit Scotland under statutory powers added to the Finance and
Accountability (Scotland) Act 2000 by section 97 of the Criminal Justice and Licensing
(Scotland) Act 2010. 
1.2 The NFI uses data matching to compare a range of information held by public bodies
to identify potential inconsistencies or circumstances that could indicate fraud or error.
This information enables public bodies to follow-up these matches on a targeted and
prioritised basis to establish if fraud has occurred and to take appropriate action. A
match does not automatically mean that there is fraud or error, and therefore the
Council is not expected to review or follow up every match. The outcomes from any
investigations are recorded on the secure NFI web application. 
1.3 Data in relation to payroll, housing (current tenants and waiting lists), Council Tax
Reduction scheme, blue badge parking permits, taxi licenses, business rates, creditor
payments and other relevant creditor standing data was uploaded to the secure NFI
database in October 2024. Further data in relation to residents in private residential
care homes and clients in receipt of personal budgets was uploaded to the NFI
database in November 2025.  Data matching for these datasets identified a total of
17,452 matches. 
1.4 Additionally, Council Tax single person discount (SPD) and electoral register data was
uploaded separately to the NFI database in December 2024, resulting in 21,351
matches.  An external third party has been commissioned to review these matches. 
2. Report 
2.1 Audit Scotland has indicated that they do not expect every match or report to be
reviewed and advise bodies to prioritise matches.  As such, they have categorised the
individual reports based on the assessed quality of match (high, medium, address or
information only) with ‘high’ reports often being matched on National Insurance
Number.  Additionally, all matches contained in reports have been allocated a ‘risk
scoring’ based on a combination of the likelihood or fraud occurring and the number of
times an individual appears across the NFI data. 
2.2 Given the high volume of matches received, there are limitations to the number of
matches that can be reviewed within the resources available.  Services are responsible
for determining a method of prioritising their matches for investigation, ensuring timely
action and update of the NFI database.  This is generally done by considering the risk
scoring allocated on the NFI database. 
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2.3 As of 22 April 2026, 11,380 (65%) of matches have been reviewed, resulting in 639
errors and 1 fraud, with £72,992 savings identified.  A summary of the results by report
type is detailed in the table below. 
Report Type Matches Processed In
progress Fraud Error Value (£)
Housing Benefit 184 143 4 0 0 0
Council Tax
Reduction
1,271 371 8 0 23 15,927
Payroll 119 111 7 0 0 0
Blue Badges 1,125 796 0 0 598 0
Creditors 6,948 6,948 0 0 14 44,507
Procurement 54 53 1 0 0 0
Housing Tenants 1,280 1,196 46 0 0 0
Housing Waiting
List
1,913 1,530 42 0 0 0
Business Rates 62 62 0 1 4 12,558
Personal Budgets 13 13 0 0 0 0
Private Residential
Care Homes
117 117 0 0 0 0
HMRC 4,366 40 0 0 0 0
Total 17,452 11,380 108 1 639 72,992 
2.4 Matches relating to housing benefit and Council Tax Reduction were reviewed and
investigated by the Appeals and Adjudications team within Finance and Technology. 
Review of these matches is complete. 
2.5 Internal Audit assessed payroll matches where North Lanarkshire Council employees
are also employed by other public sector organisations.  These matches are generally
innocent, although public bodies have previously identified some matches to be
indicative of ‘ghost’ employees with individuals holding multiple employments whilst on
sick leave with one of the bodies.  Internal Audit is awaiting confirmation of work
patterns and sickness from other bodies in relation to five matches, but no issues have
been identified to date.   
2.6 Internal Audit also assessed matches where Council employees received creditor
payments for goods or services provided.  Review of these matches is complete, but
we are currently investigating a small number of matches. 
2.7 The review of matches relating to active blue badges to deceased persons is complete
and has resulted in 598 badges being cancelled. 
2.8 Creditors matches (relating to potential duplicate payments and creditors references)
account for 40% of the total matches received. An initial review by Internal Audit
identified that many of these matches contain false positives, as some suppliers can
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have regular monthly charges using the same account reference as the invoice
number.  The review of these matches was therefore prioritised to focus on those where
the potential for duplicate payments is greatest, and the invoice value is most
significant, and this is now complete.  A small number of duplicate payments were
identified, and these have been passed to Finance and Technology to instigate
repayment. 
2.9 Matches relating to procurement involve a comparison of North Lanarkshire Council
employees to Companies House information and creditor payments to identify any
potential undeclared conflicts of interest.  Internal Audit has reviewed these matches
and identified two matches which are being investigated further. 
2.10 Review of housing tenant and waiting list matches has significantly progressed with
88% of the matches having been reviewed, and 88 matches identified for further
checking by localities. These matches are being progressed by the Service. 
2.11 Business rates matches were received in April 2025.  Review of these matches is
complete, with 1 fraud and 4 errors identified.  For these matches, the small business
bonus relief has been removed, with the ratepayer being issued with a revised bill
reflecting the updated liability. 
2.12 Data relating to residents of private residential care homes and clients in receipt of
personal budgets was matched to deceased persons records to determine whether
Council payments had promptly ceased, and Social Work records had been properly
updated to reflect the client’s death.  Review of these matches is complete and no
issues were identified. 
2.13  HMRC data matched to housing tenants, Council Tax Reduction and Council Tax SPD
data to identify potential fraud in relation to undeclared ownership, earnings and capital,
and household composition, generated 11,195 matches.  A review of these matches
during NFI 2022 identified that the HMRC data provided had not been matched on a
unique identifier (such as National Insurance number) but was generally matched on
name and address.  As a result, many matches related to different individuals, previous
residents or individuals who had never resided in the property. These issues were also
identified by other local authorities. Internal Audit reviewed a small sample of the
matches received as part of this NFI exercise and identified the same issues as those
encountered in the previous exercise.  Given the poor quality and reliability of the
matches, no further work was undertaken. 
2.14  The NFI has a mandatory requirement to submit Council Tax SPD records for matching
against electoral data. In line with the previous NFI exercise, the Council has
commissioned an external third party to undertake the review work and this is expected
to conclude shortly.  Once the data has been fully analysed and validated, the outcome
will be reported to the Finance and Resources Committee, with a further update
provided to the Panel. 
2.15 The SPD matches also included 1,152 matches to deceased persons.  Review of these
matches is now complete and no issues were identified. 
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3. Measures of success 
3.1  Successful participation in NFI 2024 will result in error, fraud and potential savings
identified and positive assessment by the Council’s external auditor of the Council’s
approach.   
Francis Scott
Chief Officer (Audit and Risk) 
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5. Impacts 
5.1 Public Sector Equality Duty and Fairer Scotland Duty 
Does the report contain information that has an impact as a result of the Public
Sector Equality Duty and/or Fairer Scotland Duty? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact? 
If Yes, has an assessment been carried out and published on the council’s
website? https://www.northlanarkshire.gov.uk/your-community/equalities/equality-
and-fairer-scotland-duty-impact-assessments 
Yes ☐ No ☒
5.2 Financial impact 
Does the report contain any financial impacts? 
Yes ☐ No ☒ 
If Yes, have all relevant financial impacts been discussed and agreed with
Finance? 
Yes ☐ No ☐ 
If Yes, please provide a brief summary of the impact? 
5.3 HR policy impact 
Does the report contain any HR policy or procedure impacts? 
Yes ☐ No ☒ 
If Yes, have all relevant HR impacts been discussed and agreed with People
Resources? 
Yes ☐ No ☐ 
If Yes, please provide a brief summary of the impact? 
5.4 Legal impact 
Does the report contain any legal impacts (such as general legal matters, statutory
considerations (including employment law considerations), or new legislation)? 
Yes ☒ No ☐ 
If Yes, have all relevant legal impacts been discussed and agreed with Legal and
Democratic? 
Yes ☒ No ☐ 
If Yes, please provide a brief summary of the impact?
Future data matching arrangements will be reviewed to ensure the Council remains
legally compliant with recent legislative changes.
5.5 Data protection impact 
Does the report / project / practice contain or involve the processing of personal
data?   
Yes ☒ No ☐ 
If Yes, is the processing of this personal data likely to result in a high risk to the
data subject? 
Yes ☐ No ☒ 
If Yes, has a Data Protection Impact Assessment (DPIA) been carried out and e-
mailed to dataprotection@northlan.gov.uk 
Yes ☐ No ☐
5.6 Technology / Digital impact 
Does the report contain information that has an impact on either technology, digital
transformation, service redesign / business change processes, data management,
or connectivity / broadband / Wi-Fi? 
Yes ☐ No ☒
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If Yes, please provide a brief summary of the impact? 
Where the impact identifies a requirement for significant technology change, has
an assessment been carried out (or is scheduled to be carried out) by the
Enterprise Architecture Governance Group (EAGG)? 
Yes ☐ No ☐
5.7 Environmental / Carbon impact 
Does the report / project / practice contain information that has an impact on any
environmental or carbon matters? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact? 
5.8 Communications impact 
Does the report contain any information that has an impact on the council’s
communications activities? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact? 
5.9 Risk impact 
Is there a risk impact? 
Yes ☒ No ☐ 
If Yes, please provide a brief summary of the key risks and potential impacts,
highlighting where the risk(s) are assessed and recorded (e.g. Corporate or
Service or Project Risk Registers), and how they are managed?
Failure to participate in the NFI could result in non-compliance with legislation,
criticism from external audit and create additional potential for fraudulent activity
not being identified at an early stage.
5.10 Armed Forces Covenant Duty 
Does the report require to take due regard of the Armed Forces Covenant Duty (i.e.
does it relate to healthcare, housing, or education services for in-Service or ex-
Service personnel, or their families, or widow(er)s)? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the provision which has been made to
ensure there has been appropriate consideration of the particular needs of the
Armed Forces community to make sure that they do not face disadvantage
compared to other citizens in the provision of public services. 
5.11 Children’s rights and wellbeing impact 
Does the report contain any information regarding any council activity, service
delivery, policy, or plan that has an impact on children and young people up to the
age of 18, or on a specific group of these? 
Yes ☐ No ☒ 
If Yes, please provide a brief summary of the impact and the provision that has
been made to ensure there has been appropriate consideration of the relevant
Articles from the United Nations Convention on the Rights of the Child (UNCRC). 
If Yes, has a Children’s Rights and Wellbeing Impact Assessment (CRWIA) been
carried out? 
Yes ☐ No ☐ 
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