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Internal Audit- Follow-Up of Actions previously agreed by Management in response to Audit Recommendations

North Lanarkshire Council · 24 November 2022
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North Lanarkshire Council
Report
Audit and Scrutiny Panel
Does this report require to be approved? ☐ Yes   ☒ No 
Ref  KA/LM/ASP/Nov 2022 Date 24/11/22 
Internal Audit: Follow up of actions previously agreed by
management in response to audit recommendations 
From Ken Adamson, Head of Audit and Risk
Email adamsonk@northlan.gov.uk Telephone 07939 280602 
Executive Summary
The purpose of this report is to update the Panel on the results of Internal Audit’s follow-up
work reviewing the extent to which management have implemented actions previously
committed to in response to previous Internal and External Audit recommendations.
Information is contained in respect of the last two years External Audit outputs and those
actions agreed in response to ‘High’ and ‘Medium’ Internal Audit recommendations which
were due to be completed in the period up to the end of September 2022.
The Panel should note that where actions are not yet ‘complete’ this does not mean that no
relevant activity has been undertaken by management and that often the actions
taken/progress made to date will have reduced the risk exposure in respect of the
weaknesses previously identified even if the action is not yet complete.
It should be noted that, as reported to the Panel in December 2021, there has been a change
to our reporting on follow-up and those recommendations which were previously reported to
the Panel as partially implemented but not yet complete will now be monitored against
revised target implementation dates agreed with management.
9 of the 14 actions agreed in respect of External Audit outputs have been completed, one
has been partially implemented and four are no longer relevant.  19 of the 24 actions agreed
in response to relevant Internal Audit recommendations due in the period have been fully
completed and five have been assessed as partially implemented.
Recommendations
The Panel is invited to:
(a) note the contents of this report;
(b) note the recommendations made by Internal Audit at Appendix 1; and 
(c) to 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

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1. Background
1.1 All Internal and External Audit reports contain management responses to audit
recommendations which generally include a commitment to specific actions by a stated
date.  This report presents an overview of progress by management in addressing all
External Audit recommendations made in the last two years and all ‘High’ and ‘Medium’
Internal Audit recommendations which were previously reported as outstanding or
where the proposed actions were due to be completed by the end of September 2022.
1.2 The format of this report is designed to allow the Panel to focus on those issues where
non-implementation of agreed actions presents the most significant ongoing risk to the
Council and to enable the Panel to hold relevant senior management to account.
1.3 As reported to the Audit and Scrutiny Panel in December 2021, Internal Audit recently
reviewed our arrangements for following-up audit recommendations.  As a result, we
have amended our processes to include, in certain circumstances, agreeing a revised
implementation date and monitoring and reporting against these revised dates where
we are provided with a strong rationale for the non-implementation of the audit
recommendation by the originally agreed date.  This avoids repeatedly reporting and
focusing on actions which are ‘late’ where there are sound reasons for non-
implementation by the originally agreed date.
1.4 This report presents the assessment of the potential risks arising from those planned
actions agreed in response to Internal Audit recommendations due in the period (July
to September 2022) which are not yet fully completed.
1.5 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
Actions previously agreed by management – Internal Audit recommendations
2.1 Table 1 below shows whether management have implemented those actions
previously agreed to in response to ‘High’ and ‘Medium’ Internal Audit
recommendations which were due to be completed by the end of September 2022. 
Overall, 19 of the agreed actions have been completed and five have been assessed
as partially implemented.
Table 1
Head of Service Area Complete Partially
implemented
No longer
relevant Total
Asset and Procurement 3 1 0 4
Audit and Risk 0 1 0 1
Business and Digital 4 3 0 7
Education (North/South) 2 0 0 2
Education and Families 3 0 0 3
Financial Solutions 3 0 0 3
People & Organisational
Development 2 0 0 2
Performance, Planning and Quality
Assurance 1 0 0 1
Planning and Regeneration 1 0 0 1
TOTAL 19 5 0 24

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2.2 Internal Audit has reviewed the management updates and agreed revised
implementation dates for all five recommendations listed as partially implemented at
Table 1 with relevant management.  These recommendations will now be monitored in
line with the agreed revised date and will be reported back to the Panel in accordance
with this revised timescale at which time consideration will be given as to whether
previously identified weaknesses have now been addressed. 
2.3 Detail in respect of each of these recommendations and the current residual risk
assessed by Internal Audit as a result of partial implementation is provided in Appendix
1, in which we have also made suggestions as to how the Panel may wish to consider
these issues.  Definitions of the residual risk ratings are provided at Appendix 3.
2.4 In response to queries raised at the last meeting of the Panel in September 2022, we
have provided detail in respect of each of the recommendations which were reported
at that meeting as ‘not yet complete’ and with a September 2022 revised date. This is
as detailed in Appendix 2.
Actions previously agreed by management – 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 2019-20 and 2020-21 audits.  Internal Audit has
concluded that nine of the 14 agreed actions have been completed, one has been
partially implemented and the remaining four actions are no longer relevant.
Table 2 Completed Partially
implemented
Not yet
due
No longer
relevant Total Report Title/Year
2019-20
Interim Audit Report 1 1 0 2 4
Annual Report 2 0 0 1 3
2020-21
Interim Audit Report 3 0 0 1 4
Annual Report 3 0 0 0 3
TOTAL 9 1 0 4 14
2.6 The four External Audit actions assessed as ‘no longer relevant’ relate to issues on
which External Audit have made a subsequent recommendation in subsequent audit
reports. 
3. Measures of success
3.1 Internal Audit report each cycle to the Audit and Scrutiny Panel on the progress made
by management in implementing actions previously committed to in response to
Internal and External Audit reports. 
4. Supporting documents
Appendix 1 Internal Audit recommendations - Management actions assessed as
‘not yet complete’ in this cycle
Appendix 2  Internal Audit recommendations – Management actions with revised
timescale of September 2022 per ASP meeting on 8/9/22
Appendix 3  Residual risk rating definition 
Ken Adamson, Head of 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 ☐
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 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).

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Appendix 1 Internal Audit recommendations - Management actions assessed as ‘not yet complete’ in this cycle
Head of Service
Report Details Details from original recommendation Current position per management
update
Original and
revised
timescales
Internal Audit comment
Head of Asset and Procurement
Enterprise Project
(May 2022) 
Risk: Without a robust and realistic contingency
plan in place the Council may not be able to ensure
continuity of service delivery and achievement of
ambitions.
Recommendation: The Enterprise Project Board
should ensure that the key tasks required to fully
document a contingency plan, including key
milestones and lead times/critical path, is included
in the project plan and thereafter monitor
development of the contingency plan to ensure that
an alternative ‘Plan B’ is available, and lead
times/critical path are clearly understood should the
project not be able to be progressed as currently
envisaged.
Category: Medium
The risk of a lack of market appetite for the
procurement opportunities remains key within
the Enterprise Project with the Project Board
receiving updates on this and other risks at
each meeting.  This risk, along with a high-level
contingency plan, has also been discussed
separately with the SRO, Project Sponsor and
Chief Executive.
The Project Lead has taken advice from the
project’s legal advisers and is developing
contingency plans and timescales.
The outcome of the SPD evaluation will help
inform the Council’s decision to proceed with
the procurement and/or appraise alternate
delivery options (‘Plan B’).  This decision will in
turn help inform the detailed development of the
‘Plan B’ and if required, allow the ‘Plan B’ to be
enacted after appropriate engagement with the
CMT and Elected Members. 
Original timescale:
July 2022 
Revised timescale:
December 2022 
We acknowledge that work in this area to
develop the ‘Plan B’ has been ongoing and
that the delay in implementing this is largely
due to ensuring the timely launch of the
Phase 1 procurement.
Given that further action is required to fully
develop the contingency plan/’Plan B’, we
assess the residual risk as ‘Medium’ and
consider it important that the agreed
extension date of December 2022 is
achieved.  We note that an update on the
status and future development of the
Enterprise Project is due to be presented to
the Policy and Strategy Committee in
December 2022.
We would suggest that the Panel may wish
to consider agreeing to note the progress
made and the revised completion date and
to monitor progress being made as part of
the next follow-up report.
Head of Audit and Risk
Risk Management
(July 2022) 
Risk: The absence of a fully documented corporate
risk register, subject to regular monitoring and
challenge may mean that key stakeholders may fail
to fully understand the key risks the Council faces
and in turn may consequently fail to take
appropriate action to mitigate them.
Recommendation: The Head of Audit and Risk
should ensure that the replacement and/or new
corporate risks detailed in the finding are
documented, assessed and moved to ‘live’ status
with a reasonable timescale.
Category: Medium
The corporate risks on Supply Chain and the
Scottish Child Abuse Inquiry have been
developed, agreed and are now ‘live’.
The corporate risk in relation to the National
Care Service proposals has been documented
as much as can be based on current information
available.  This will continue to be developed as
the national policy direction progresses and the
current level of uncertainty reduces.
The two remaining corporate risks (Educational
Outcomes and Target Operating Model) are
both in draft format and require further
discussion and development with the relevant
Risk Leads before being agreed and finalised.
Original timescale:
September 2022 
Revised timescale:
December 2022
Whilst we acknowledge that there has been
significant action taken to address the
recommendations made, it is important the
two remaining risks are finalised and moved
to ‘live’ status at an early opportunity.
We consider the revised timescale to be
reasonable and have assessed the residual
risk for this recommendation as ‘Low’. 
Accordingly, we would suggest that the
Panel may simply wish to consider agreeing
to note the progress made and the revised
completion date.

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Appendix 1 (continued) Internal Audit recommendations - Management actions assessed as ‘not yet complete’ 
Head of Service
Report Details Details from original recommendation Current position per
management update
Original and
revised
timescales
Internal Audit comment
Head of Business and Digital 
Digital NL 
(November 2021)
Risk: Benefits and savings may not be being adequately
tracked and monitored resulting in the Council being
unable to demonstrate the achievement of the objectives
of the programme.  
Recommendation: Management should ensure that:  
(1) the non-financial benefits tracker is finalised and
approved with non-financial benefits thereafter identified,
calculated, tracked and monitored for all workstreams;
and  
(2) the review of the suite of documentation cited in the
Benefits Management Realisation approach is completed
and the process thereafter updated and circulated to all
relevant parties. 
Category: Medium
The updated Benefits
Management approach has
been revised, updated and
circulated to all relevant
parties. 
The non-financial benefits
tracker templates for each of
the sprints (both completed and
those in progress) have been
created but have not yet been
populated with the expected
non-financial benefits and how
these will be measured and
quantified.  The focus to date
has been on the financial
benefits.
1:1 meetings require to be held
with the Business Change
Analysts to determine what, if
any, non-financial benefits
are/were expected and how
these will thereafter be
measured.  The non-financial
benefits tracker templates will
thereafter be populated with
this information.
For those sprints which have
already been completed, the
templates will be updated
retrospectively.  Going forward,
the expectation is that the
templates will be updated in
line with progression of the
sprint.
Original timescale: 
April 2022 
Revised timescale:
September 2022 
Further revised
timescale: 
March 2023
Whilst we acknowledge that the updated Benefits
Management Approach would enable both financial
and non-financial benefits to be identified, monitored
and tracked, it is important that the non-financial
benefits are identified, measured and quantified
retrospectively for completed sprints and going forward
identified and captured in a timely and consistent
manner for those sprints not yet underway/at an early
stage.
Given the limited progress of identifying and
quantifying non-financial benefits to date we have
assessed the residual risk as ‘High’ and consider it
important that the revised timescale is adhered to and
would suggest that the Panel may wish to consider
requesting an update on this issue from relevant senior
management at the next meeting of the Panel.

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Appendix 1 (continued) Internal Audit recommendations - Management actions assessed as ‘not yet complete’ 
Head of Service
Report Details Details from original recommendation Current position per
management update
Original and
revised
timescales
Internal Audit comment
Head of Business and Digital 
Managing
Strategic Change 
(June 2021)
Risk: Key stakeholders may not be adequately
informed of progress in the Council’s key corporate
projects and may not be able to undertake effective
oversight and/or ensure that timely remedial action,
necessary to ensure that projects are delivered
successfully, has been progressed by relevant
management.
Recommendation: Management should progress
the previously identified action of establishing a
reporting mechanism which better facilitates regular
and ongoing oversight by key stakeholders of the
progress of key projects against plan, including
management of key risks, progress against timelines,
cost against budget, achievement or otherwise of key
milestones and expected outcomes or benefits
realisation.  We suggest that this could include
introducing a standard reporting template and
adopting a traffic light system to report progress
against key criteria, project milestones and overall
deliverability against expected time, cost and any
other intended outcomes.
Category: Medium
Following review and refresh of the
project management framework, the
updated framework includes a
section on reporting to the
programme/project boards on the
progress of specific programmes
and projects.  This references that
good practice recommends that
these reports assign a RAG status
based on assessment criteria for
three of the key dimensions within
which the project requires to be
delivered (i.e. cost, time and quality).     
Original timescale:
September 2021 
Revised timescale: 
September 2022 
Further revised
timescale: 
Still to be
determined by
management
The Service consider this action to be complete as the
updated project management framework includes
detail around reporting to project/programme boards. 
However, we note that this does not reference the
arrangements in place for reporting to key stakeholders
(for example: CMT and/or Committee) to facilitate
regular and ongoing oversight of identified key projects
across the Council. 
We have assessed the residual risk as ‘High’ as the
recommendation has not yet been fully addressed by
management who have provided no clear indication as
to how or when oversight of progress of key projects
across the Council against plan, including
management of key risks, progress against timelines,
cost against budget, achievement or otherwise of key
milestones and expected outcomes or benefits
realisation will be reported to key stakeholders.
We consider it important in allowing effective oversight
and scrutiny that management identify and commit to a
clear timescale for implementing this recommendation
and would suggest that the Panel may wish to consider
requesting an update on this issue from relevant senior
management at the next meeting of the Panel.

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Appendix 1 (continued) Internal Audit recommendations - Management actions assessed as ‘not yet complete’ 
Head of Service
Report Details Details from original recommendation Current position per
management update
Original and
revised timescales Internal Audit comment
Head of Business and Digital 
Governance of
Capital Projects
(December 2019) 
Risk: 
If Services are aware of the projects which will be reviewed, they are
more likely to follow the guidance for those projects and the results of any
such reviews may not provide a true representation of the extent of
compliance with expected arrangements, including use of the relevant
guidance and control template documents.
Recommendation: 
Management should review the ‘project management model review
programme’, particularly in relation to:
• expanding the sample of projects being reviewed to incorporate
some capital and non-capital projects that Services have not
received advance notification; and
• reviewing and updating the checklist to include consideration of the
adequacy and effectiveness of the completed control document
templates, determination of whether established processes have
been documented and confirmation that key stakeholders have been
adequately updated on the progress of the project, in line with the
suggested improvements at Appendix 3.
Category: Medium
A review programme cannot be
established until the Project
Registers have been received from
Heads of Service. This review
programme will cover both capital
and non-capital projects.  An e-mail
was sent to all Heads of Service on
11th October 2022 asking that they
submit their Project Registers by the
1st November 2022.
Project Register maintenance and
monitoring will be revisited in line
with the future development and
implementation of a centralised
project management IT system.
As reported to CMT on 27/09/22, the
review and refresh of the project
management framework identified
the need for a more consistent
approach across the Council with
regards to the extent and
effectiveness of the programme and
project board.  It is considered that
this approach will also support
further improvements in the
development of the project
management framework review
programme and ensure that it
provides a meaningful accurate and
representative assessment of the
extent of compliance with the
fundamentals and mandatory tasks
within the framework.
Original timescale:
June 2020 
Revised timescale: 
September 2022 
Further revised
timescale:
Still to be determined
by management
Although the Service have
provided some detail around
the planned approach and
review programme for the
project management
framework which will assess
compliance with this, they have
provided limited detail to
confirm how and when this will
be implemented.
Given that further action is
required to progress
arrangements for monitoring
compliance with the refreshed
project management
framework, we have assessed
the residual risk as ‘Medium’
and consider it appropriate that
more detailed plans and
timescales are identified by
management at an early stage.
We would suggest that the
Panel may wish to consider
agreeing to note the progress
made and request that
management provide an
update including revised
implementation dates at the
next meeting of the Panel.

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Appendix 2 (continued) Internal Audit recommendations - Management actions with revised timescale of September 2022 per ASP meeting on 8/9/22
Head of Service
Report Details Details from original recommendation Position per previous
management update
Internal Audit comment
per previous update
Position as at October
2022
Head of Business and Digital 
Governance of
Capital Projects
(December 2019) 
Housing
Investment
Programme
(October 2020) 
Managing
Strategic Change 
(June 2021)
The three audit reports listed each raised issues regarding the Council’s
project management model.  In summary the risks and recommendations
arising comprised the following:
Risk: 
The Council’s project management arrangements may not reflect good
practice which may lead to projects being managed and documented on an
inconsistent basis.
Key stakeholders may not be adequately informed of progress in the Council’s
key corporate projects and may not be able to undertake effective oversight
and/or ensure that timely remedial action, necessary to ensure that projects
are delivered successfully, has been progressed by relevant management.
Recommendation: 
Management should:
• review and update, as appropriate, the project management model to
ensure that it is sufficiently prescriptive to enable officers to identify the
circumstances of when, and to what extent, it should be followed. 
• review and amend the project management documentation to ensure that
it requires the title of the project to be recorded and includes version control
to clearly detail when it was prepared and last updated. 
• review the ‘project management model review programme’ particularly in
relation to: expanding the sample of projects being reviewed to incorporate
some capital and non-capital projects that Services have not received
advance notification of; and reviewing and updating the checklist giving
due consideration to the suggested improvements made by Internal Audit. 
• progress the previously identified action of establishing a reporting
mechanism which better facilitates regular and ongoing oversight by key
stakeholders of the progress of key projects against plan, including
management of key risks, progress against timelines, cost against budget,
achievement or otherwise of key milestones and expected outcomes or
benefits realisation.  We suggest that this could include introducing a
standard reporting template and adopting a traffic light system to report
progress against key criteria, project milestones and overall deliverability
against expected time, cost and any other intended outcomes.
Category: Medium
The planned review process
and subsequent refresh of the
council’s Project Management
Model took place from
February to June 2022.  A
Review Team comprising
representatives from all
Services, including audit and
risk, took part in the evaluation
and review process.  The
refreshed Project Management
Framework was circulated to
the Review Team for their final
input in June 2022.  
Insufficient feedback was
received from the majority of
service representatives on the
Review Team which led to a
delay in the finalisation of the
refreshed Project Management
Framework.  Further work is
being undertaken on a 1:1
basis to ensure Services are
fully engaged with, and
involved in, the final
development stages of the
refreshed Project Management
Framework.  Following this, the
Project Management
Framework will be finalised and
submitted to CMT for approval.
Revised timescale: April
2022
Further revised timescale:
September 2022
The Service has indicated
that these actions are largely
complete and that the delay
in implementation is largely
due to insufficient feedback
from service representatives
which the Service are
currently taking steps to
address.
Given the extensive delay in
implementation of these
recommendations, we
assess the residual risk as
‘High’ and would suggest
that the Panel may wish to
consider noting the progress
made to date and the revised
timescale but also to request
an update on this issue from
relevant senior management
at the next meeting of the
Panel if the action is not fully
implemented at that time.
The actions in respect of the
review and update of the
project management model
and the project management
documentation have now
been fully implemented.
The refreshed project
management model was
presented to CMT, OMT and
ODA in September/October
2022. 
An update in terms of the next
steps is documented in the
Strategic Frameworks Annual
Position Statement which is
included the pack for this
meeting of the Panel.
The actions in respect of
amendments to the ‘project
management model review
programme’ and establishing
a reporting mechanism which
better facilitates regular and
ongoing oversight by key
stakeholders of the progress
of key projects against the
plan are partially
implemented.
See Appendix 1 for further
detail on the current position.

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Appendix 2 (continued) Internal Audit recommendations - Management actions with revised timescale of September 2022 per ASP meeting on 8/9/22
Head of Service
Report Details Details from original recommendation Position per previous management
update
Internal Audit
comment per previous
update
Position as at October
2022
Head of Business and Digital 
Digital NL
(November 2021)
Risk: Benefits and savings may not be being adequately
tracked and monitored resulting in the Council being unable to
demonstrate the achievement of the objectives of the
programme.  
Recommendation: Management should ensure that:  
(1) the non-financial benefits tracker is finalised and approved
with non-financial benefits thereafter identified, calculated,
tracked and monitored for all workstreams; and  
(2) the review of the suite of documentation cited in the
Benefits Management Realisation approach is completed and
the process thereafter updated and circulated to all relevant
parties. 
Category: Medium
The non-financial benefits tracker has been
finalised and the updated Benefits Management
Approach revised and updated.  However, the
non-financial benefits tracker has not yet been
populated for all workstreams and work is
ongoing in this area.  
The agenda for SRO/Delivery Board has
recently been amended to focus on Benefits
Realisation as the first agenda item. 
Revised timescale: September 2022
The Service has indicated
that they consider these
actions to be largely
complete. However, while
we acknowledge that there
has been some progress
made in this area, we
consider there is still further
action which requires to be
taken to fully address the
identified risks.
This action thus remains
partially implemented. 
See Appendix 1 for further
detail on current position.

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Appendix 2 Internal Audit recommendations - Management actions with revised timescale of September 2022 per ASP meeting on 8/9/22
Head of Service
Report Details Details from original recommendation Position per previous management
update
Internal Audit comment
per previous update
Position as at October
2022
Head of Asset and Procurement
Procurement 
(November 2021)
Risk: If performance measures are not correctly calculated in
line with the definition, management and elected members
may misinterpret the information presented to them and may
not raise appropriate questions. 
Recommendation: Asset and Procurement Solutions should
review the processes in place to ensure that all future
performance measures contained within the Annual
Procurement Report are accurately and consistently
calculated in line with the corresponding definition.
Category: Medium
Performance indicators have been reviewed
and amended.  Work is ongoing with the
Scottish Government to ensure that relevant
content is incorporated into the future
Annual Procurement Report.
The Annual Procurement Report is currently
being finalised prior to it being reported to
the Finance and Resource Committee in
September 2022.
Revised Timescale: September 2022
The Service has indicated
that they consider this
recommendation to be largely
complete and have
committed to finalising the
Annual Procurement Report
for the next meeting of the
Finance and Resource
Committee scheduled for
September 2022.  
This action has now been
fully implemented.
The Annual Procurement
Report 2021-22 has been
finalised and was presented
to the Finance and
Resources Committee in
September 2022.
Head of Business and Digital
Digital NL
(November 2021)
Risk: Inadequate arrangements for identifying, agreeing and
realising expected outcomes (including expected financial
savings) within timescales may result in consequential
impacts on the management of the Council’s finances.  
Recommendation: Management should continue to review
the future deliverability of the revised Digital NL programme to
ensure timescales for delivery and expected outcomes are
realistic and achievable.  This should include consideration of:
• further developing/enhancing the RAG status for
assessing individual projects/workstreams.  In particular
consideration should be given to splitting the RAG status
to provide separate assessments of achievement of
timescales and achievement of projected benefits
(including expected savings) to enable the impact of the
RAG status on savings to be more clearly documented.  
• the use of optimism bias to make explicit risk-based
adjustments to the projected estimates of projects costs,
benefits (including expected savings), and duration; and  
• the identification and implementation of actions necessary
to address the continual movement of projected savings.  
Category: High
A full review of deliverability of the DigitalNL
programme, SmartNL and infrastructure
business has taken place.  The outstanding
year 3 development work and the potential
Year 4 Roadmap were reviewed in line with
shape and size, resource availability,
benefits realisation, funding availability and
risk.  A prioritisation matrix has been
developed and an Assessment Board
created to ensure all activities are reviewed
in line with the newly developed Integrated
Programme Plan. 
The full end to end process was presented
to the SRO meeting on 26 May 2022 with
approval given at this meeting to further
develop the proposals.  In recognising the
Delivery Board is responsible for governing
the DigitalNL programme and its associated
outcomes, the final proposals will be
presented to the Delivery Board in August
2022 for consideration and approval as
appropriate.
Revised timescale: August 2022
The Service has indicated
that they consider these
actions to be largely
complete. However, while we
acknowledge that there has
been some progress made in
this area, we consider there is
still further action which
requires to be taken to fully
address the identified risks.
This action has now been
fully implemented.
A report was presented to
the Policy and Strategy
Committee in September
2022 outlining the progress
to date and the Roadmap
for Year 4 and beyond.

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Appendix 2 (continued) Internal Audit recommendations - Management actions with revised timescale of September 2022 per ASP meeting on 8/9/22
Head of Service
Report Details Details from original recommendation Position per previous management
update
Internal Audit comment
per previous update
Position as at
October 2022
Head of Business and Digital 
Digital NL
(November 2021)
Risk: Without full, clear and timely information, key
stakeholders may not be able to effectively monitor
performance in respect of the DigitalNL programme and/or
progress against expected benefits and planned outcomes or
determine whether the programme is achieving its targets,
and/or identify and agree timely action to address areas of
underperformance and/or make informed decisions about the
future direction of the DigitalNL programme.  
Without clear recording of actions prescribed and identified
responsible officers for actions planned in response to
highlighted risks, key stakeholders would be unable to monitor
the risk to ascertain if it had been addressed/mitigated.
Recommendation: Management should ensure that:  
(1) reports on DigitalNL to the Delivery Board, CMT and
Committee are amended to provide a clear and
comprehensive assessment of progress/status of both the
programme as a whole and of individual workstreams.  This
should include an assessment of each project/workstreams
RAG status; 
(2) reports submitted to the Board make clear reference to all
those significant risks with the potential to impact on the
successful delivery of the programme including the relevant
mitigating controls; actions planned to further address the
relevant risk and identified officers tasked with doing so and
that key risks are tracked and monitored at each meeting of
the Board; and  
(3) discussions at the Board in relation to any high/significant
programme risks included on the Programme Highlight Report
submitted to the Board, including the corresponding
prescribed action(s) and identified officers, are clearly
documented in the Action Note or Action Summary of that
meeting.  
Category: Medium
The Programme Highlight report submitted to
the Delivery Board has been reviewed and
amended to clearly show the RAG status and
the financial and non-financial benefits
anticipated for each business change sprint.
The reports submitted to the Board make clear
reference to significant risks and a link to the
Risk Register has been added to the
Programme Highlight Report. 
The Action Summary, introduced in early 2022,
allows members of the Delivery Board to focus
on agreed actions.
Revised timescale: September 2022
The Service has indicated
that they consider this action
to be substantially complete. 
However, due to the limited
number of Delivery Board
meetings since the process
was amended, we have not
yet been able to determine
whether adequate detail is
provided and/or appropriate
discussions held with regards
to those risks assessed as
‘high’/red. 
This action has now been
fully implemented.
A report was presented to
the Delivery Board at the
end of August referencing
proposed changes to the
Programme Highlight
Report which will further
enhance the reporting
process.  A revised report
incorporating these
changes was presented
to the Board on 27
October 2022.

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Appendix 2 (continued) Internal Audit recommendations - Management actions with revised timescale of September 2022 per ASP meeting on 8/9/22
Head of Service
Report Details Details from original recommendation Position per previous management
update
Internal Audit
comment per
previous update
Position as at October
2022
Head of Education  (North/South)
Follow Up: Scottish
Attainment Challenge &
Pupil Equity Fund
(August 2021)
Risk: Without short, medium and long-term targets against
which performance can be monitored, there is a risk that
effective oversight of the SAC and PEF programmes may be
impaired. 
Without an effective performance management framework,
management would not be able to measure whether the SAC
and PEF programmes were being delivered and/or may not be
able to take appropriate action to address areas of ‘under-
performance’.  
Recommendation: Management should: 
(1) identify and set realistic short, medium and long-term
targets for the SAC and PEF programmes and consider the
current and future planned actions which will be taken to
deliver against the identified objectives and measures of
success 
(2) ensure that appropriate and realistic SMART performance
measures are used wherever possible in the annual SAC
Plan, subsequent progress reports to committee and within
the individual establishments’ SIPs and SIRS to ensure that
progress of key all actions and interventions can be
appropriately tracked; and 
(3) set out clearly defined baselines against which the
activities or interventions will be assessed for their contribution
to closing the poverty-related attainment gap and ensure that
the reports at both authority and individual establishment level
clearly set out to key stakeholders the progress made against
the identified targets/milestones together with any significant
challenges in achieving these targets.
Category: Medium
Previous targets have been set by the
Scottish Government but from 2022, targets
in relation to progress in attainment are being
set in collaboration and discussion with local
authorities and both the SAC and PEF Team
are engaging in discussions to agree on
aspirational yet achievable targets and align
the plans for the year ahead.
Further development sessions for
Headteachers and senior managers have
taken place to assist with the development of
clear rationales; help with the identification of
outcomes and measures and provide both a
local and national context to their approach.  
Whilst improvements in planning at school
level have been noted the SAC and PEF
Team consider there is still work to be done
in encouraging greater detail in school
improvement plans.  The Improvement and
Equity Lead continues to support and
challenge establishments in both their SAC
and PEF submissions through scrutiny of
plans and encouraging all schools to ensure
that, wherever possible, data should form the
basis of all submissions of progress in the bi-
annual checkpoints.  
Revised timescale: June 2022
Further revised timescale: September
2022
Whilst we acknowledge
that there has been some
action taken to address
the recommendations
made, we consider that
there is still further action
required to fully mitigate
the identified risks.
This action has now been
fully implemented.
A review of the
documentation provided
demonstrated that the Head
Teachers are now
identifying, planning and
setting out outcomes for their
SAC and PEF programmes.
There are two bi-annual
reporting ‘checkpoints’ as
part of the annual
improvement cycle for all
establishments.
Schools/establishments are
now using a variety of data
when setting targets and
both the reports to
Committee and individual
schools’ School
Improvement Plans now
include detail on
performance measures and
progress being made. An
update on progress of SAC
and PEF was presented to
CMT in October 2022 and
will be presented to the
November meeting of the
Education, Children and
Families Committee.

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Appendix 2 (continued) Internal Audit recommendations - Management actions with revised timescale of September 2022 per ASP meeting on 8/9/22
Head of Service
Report Details Details from original recommendation Position per previous
management update
Internal Audit comment per
previous update Position as at October 2022
Head of Education (North/South) 
Follow Up: Scottish
Attainment
Challenge & Pupil
Equity Fund
(August 2021)
Risk: Services may not be procured in accordance with the
Framework. 
Without formal documentation, schools may not be able to
evidence why a particular procurement method and/or
supplier was selected and/or be able to demonstrate best
value when procuring services
Recommendation: Management should:  
(1) remind/encourage all schools to use the Procurement
framework as far as possible and of the requirements of
the Framework (including the use of approved suppliers
wherever possible) and the importance of completing
the RFP documentation for each procurement exercise; 
(2)  periodically report to senior management on the use of,
and expenditure incurred via, the Framework against the
total spend allocation; and  
(3) ensure that they periodically review non-Framework
expenditure items to obtain sufficient assurance that
procurement activity funded via SAC/PEF is being
undertaken in accordance with corporate expectations
and can demonstrate best value.
Category: Medium
Headteachers are reminded
on an ongoing basis of the
requirements of the
Procurement Framework.
A review of Framework and
non-Framework expenditure
for session 2021-22 has been
undertaken with subsequent
findings to be reported to the
Programme Board and
Services Senior Leadership
Team in August 2022.
Revised timescale: June
2022
Further revised timescale:
September 2022
Whilst we acknowledge that there has
been some action taken to address the
recommendations made, we consider
that there is still further action required
to fully mitigate the identified risks. 
This action has now been fully
implemented.
A review of Framework and non-
framework expenditure has been
reported to both the Programme
Board and the Senior Leadership
Team. This was presented to the
Senior Leadership Team at the end
of August 2022 and thereafter
shared with the Programme Board
at the October meeting.

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Appendix 2 (continued) Internal Audit recommendations - Management actions with revised timescale of September 2022 per ASP meeting on 8/9/22
Head of Service
Report Details Details from original recommendation Position per previous
management update
Internal Audit comment per
previous update Position as at October 2022
Head of Education and Families
Tackling Poverty
(November 2021)
Risk: If the process to create a consolidated
action plan is not properly documented, the
LCPAR action plan may not be appropriately
aligned with the strategy action plan which may
result in key actions potentially being missed in
error.   
Feedback from external reviews may not be
incorporated into the LCPAR resulting in a
failure to address or progress relevant actions
or activities.
Recommendation: Management should
ensure that: 
(1) all relevant key actions from the strategy are,
where appropriate, incorporated within the
LCPAR action plan and/or that where actions
are removed/not included there is appropriate
documentary evidence maintained to support
the rationale for their removal; and 
(2) all outstanding recommendations and
actions arising from the NL Fairness
Commission and Scottish Government reviews
are, where appropriate, incorporated into the
LCPAR.
Category: Medium
Following the production of the Best
Start, Bright Futures Child Poverty
Delivery Plan 2022-2026, the LCPAR
will be incorporated within the
production of a new Tackling Poverty
Strategy 2023-2026 which will allow for
forward planning whilst meeting the
requirements of the Scottish
Government.  This document will include
all of the outstanding recommendations
and actions from the North Lanarkshire
Fairness Commission and Scottish
Government reviews.
The Local Child Poverty Action Report
will be prepared and submitted to the
Policy and Strategy Committee in
September 2022.
Revised timescale: September 2022
The delay in implementing this
action is due to a number of
factors, including the Council
elections, however a firm
commitment has been given by the
Service to submit the LCPAR to
Committee in September 2022. 
This action has now been fully
implemented.
The Local Child Poverty Action
Report was prepared and submitted
to the Policy and Strategy
Committee in September 2022.

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Appendix 2 (continued) Internal Audit recommendations - Management actions with revised timescale of September 2022 per ASP meeting on 8/9/22
Head of Service
Report Details Details from original recommendation Position per previous
management update
Internal Audit comment
per previous update Internal Audit comment
Head of Financial Solutions
Use of Corporate Credit
Cards and Purchase
Cards
(November 2021)
Risk: Without a clear statement of expected procedures and
oversight arrangements, there is an increased risk of
inadequate control over the administration of purchase cards
and expenditure incurred which may be inappropriate and/or
not appropriately monitored.
Recommendation: The Head of Financial Solutions should,
in conjunction with Facility Support Services, undertake a
formal review of the purchase card scheme, to ensure that
an appropriate and effective control environment is
established and thereafter implemented.  The review should
include, but not be limited to, considering the issues
identified in the finding.
Category: High
The review of the purchase
card scheme is currently
underway.  Delays in
implementation are due to staff
changes, shortages and a
prioritisation of financial year
end activities.
Revised timescale:
September 2022
Although the review of the
purchase card scheme is not
yet complete, we acknowledge
that the delay in implementing
this is due to a number of
factors, including changes in
staff. A firm commitment has
been given by the Service to
complete the review by the
proposed revised timescale. 
This recommendation has been fully
implemented.
The review has now been completed
and the Policy reviewed and re-
issued to the relevant managers
along with detailed instruction on the
responsibility of card holders.
A briefing note providing details of
the Financial Solutions review and
resultant recommendations and was
issued to the Head of Financial
Solutions in September 2022.  Steps
have been taken to implement the
recommendations made in this
briefing note.

Page 17

Appendix 3  Residual Risk Rating definition
Internal Audit Assessment of Residual Risk from non-implementation 
High Non-implementation of actions has the potential to significantly undermine the
relevant control environment.
Medium Non-implementation of actions has the potential to impact upon the achievement
of the control environment.
Low Other issues which require management attention but which pose less significant
or less immediate impacts to the control environment.