Democracy Spraffa

Internal Audit Report - 25-04 - Health and Safety

Perth and Kinross Council · 29 June 2026
Back to Audit and Risk Committee — 29 June 2026 and its agenda

Text extracted from the council's PDF. Layout and reading order may differ from the original.

Original council PDF · Download plain text

Page 1

1 
Internal Audit Report
Strategic Planning, People and Performance
25-04 Health & Safety  
June 2026 
Final Report
(Report No. 26/194) 
Legal and Governance
Perth & Kinross Council
Council Offices
2 High Street 
Perth
PH1 5PH

Page 2

2 
25-04 Health & Safety 
Contents by Section 
1. Introduction          
2. Audit Background Information        
3. Scope and Limitations         
4. Assessment of the Control Environment      
5. Summary of Findings         
6. Conclusions          
7. Acknowledgement         
8. Action Implementation & Follow Up     
9. Management Action Plan 
10. Authorisation
11. Distribution
12. Assessment Definitions

Page 3

3 
1.  Introduction 
1.1 This assignment forms part of the Internal Audit plan for 2025/26, approved by
the Audit Committee on 25 June 2025. The period under review for the
purposes of the audit exercise was financial years 2024/25 and 2025/26. 
1.2 The indicative scope for the audit was to review arrangements in place for the
corporate oversight of health and safety within the Council. 
1.3 This audit is linked to the Strategic Risk Register SR011 – The health and safety
of staff and the public is not adequately protected which was reported to be
Priority 1, High in May 2025. 
2.  Executive Summary 
2.1  The audit has found that reasonable assurance can be placed on the Council’s
internal controls in relation to the review arrangements in place for the corporate
oversight of Health and Safety within the Council. 
2.2  There are twenty-three actions arising from the findings in Section 6. An action
plan is included in Section 10. Once these actions are completed, Internal Audit
should be able to place substantial assurance on the arrangements in place. 
3.      Audit Background Information 
3.1 Local authorities have a fundamental responsibility to ensure the health, safety
and welfare of their employees, service users, contractors, and members of the
public who may be affected by council activities. This duty is underpinned by a
comprehensive framework of UK Health & Safety legislation, primarily the
Health and Safety at Work etc. Act 1974 (HASWA) and associated legislation,
which places a statutory obligation on employers to provide a safe working
environment and manage risks effectively. 
3.2 The section 2(2) of the Act, states that without prejudice to the generality of an
employer’s duty under the subsection 1, the matters to which that duty extends
include in particular
(a) the provision and maintenance of plant and systems of work that are, so far
as is reasonably practicable, safe and without risks to health;
(b) arrangements for ensuring, so far as is reasonably practicable, safety and
absence of risks to health in connection with the use, handling, storage and
transport of articles and substances;
(c) the provision of such information, instruction, training and supervision as is
necessary to ensure, so far as is reasonably practicable, the health and safety
at work of his employees;
(d) so far as is reasonably practicable as regards any place of work under the
employer’s control, the maintenance of it in a condition that is safe and without

Page 4

4 
risks to health and the provision and maintenance of means of access to and
egress from it that are safe and without such risks;
(e) the provision and maintenance of a working environment for his employees
that is, so far as is reasonably practicable, safe, without risks to health, and
adequate as regards facilities and arrangements for their welfare at work. 
3.3 In the local council context, compliance is especially important due to the
diverse nature of services delivered such as housing, social care, waste
management, roads, education, parks, and public spaces. Each service area
carries unique operational risks, requiring tailored controls, risk assessments,
training, and monitoring arrangements. Councils must also comply with
supporting regulations such as the Management of Health and Safety at Work
Regulations 1999, Control of Substances Hazardous to Health (COSHH),
Manual Handling Operations Regulations, and Reporting of Injuries, Diseases
and Dangerous Occurrences Regulations (RIDDOR). 
3.4 According to the Health and Safety Executive (HSE), any organisation as a
minimum has a duty to have the processes and procedures required to meet
the legal requirements, including: 
• a written health and safety policy; if they employ 5 or more people
• assessments of the risks to employees, contractors, customers, partners,
and any other people who could be affected by your activities and record
the significant findings in writing. Any risk assessment must be ‘suitable
and sufficient’,
• arrangements for the effective planning, organisation, control, monitoring
and review of the preventive and protective measures that come from risk
assessment;
• access to competent health and safety advice;
• providing employees with information about the risks in their workplace
and how they are protected; 
• instruction and training for employees in how to deal with the risks; 
• ensuring there is adequate and appropriate supervision in place; 
• consulting with employees about their risks at work and current preventive
and protective measures. 
4.  Scope and Limitations 
4.1  The audit has reviewed the relevant legislation and governance requirements
in fulfilling corporate health and safety (H&S) of the Council. 
4.2 To arrive at an opinion on the achievement of the control objective, the review
included,
• Document reviews concerning H&S policies and procedures,
• Interviews with key staff who are responsible for the H&S of the different
services,
• Reviews of any third-party documents, audit reports and arrangements with
independent audits.

Page 5

5 
• Ensuring lessons learned from previous non-compliance and reported
incidents/accidents are incorporated into future planning. 
4.3  There were no limitations identified that would impact the Audit. 
4.4 The details of the control objectives reviewed and the Internal Audit’s
assessment of their strength of control in each area are contained within
Section 5 of this report. 
5.  Assessment of the Control Environment 
5.1  The table below contains a summary of the number of findings and their ratings,
as detailed in Section 12, against each control objective, along with Internal
Audit’s assessment of the adequacy and effectiveness of the controls in place
to meet each of the objectives agreed for this audit. Further details, including
any improvement actions, are set out in the Management Action Plan. 
No. Control Objective Action Rating  Control
Objective
Assessment 5 4 3 2 1
1 To ensure that the Council
complies with all H&S legislation
and statutory requirements. 
2 4   Reasonable
Assurance
2 To ensure that adequate steps
are taken to protect employees,
service users, contractors, and
the public from harm. 
2 4 1 1 Reasonable
Assurance
3 To ensure H&S training, incident
reporting, and risk assessments
are robust and effective. 
4 3 2  Reasonable
Assurance 
5.2 The auditor has assessed that reasonable assurance can be placed on controls
overall in relation to the arrangements in place for the corporate oversight of
Health and Safety within the Council. Meaning:
“There is a generally sound system of governance, risk management and
control in place. Some issues, non-compliance or scope for improvement were
identified which may put at risk the achievement of objectives in the area
audited.” 
5.2 A summary of the key findings and actions is provided in section 6. Please note,
however, the following areas of good practice which have been highlighted
during the audit: 
5.2.1 The Chief Executive and the Executive Leadership Team providing leadership
on Health and Safety matters at Council, and this is discharged by setting a
policy, ensuring that business plans are in place, that regular consultation with
employees and trade unions take place, and that the Council’s overall approach
is thoroughly monitored and reviewed. We have noticed a clear organisation
structure for reporting and managing H&S in place. Council website has details

Page 6

6 
of the recognised Trade Unions with names and contact details of their
representatives and those who cooperatively work with the Council. 
5.2.2 The Strategic Health and Safety Consultative Committee has approved the
Occupational Health and Safety Policy on 21 January 2026, signed by the Chief
Executive and the Strategic Lead of Strategic Planning, People and
Performance. This has replaced the old policy prepared and approved in 2018
and is readily available on ERIC, uploaded on 9 February 2026. 
5.2.3 The strategic objective of the new policy is in line with the legal requirements
and HSE guidance (HSG65) provided. The guidance explains the Plan, Do,
Check, Act approach and shows how it can help to achieve a balance between
the systems and behavioural aspects of management. The Policy provides
clarity on Health and Safety responsibilities of both the employer and the
employees.   
5.2.4 As per Section 7 of the Management of Health & Safety at Work Regulations
1999, Council has appointed a dedicated H&S Team within the Council, and
the Team comprises highly competent and qualified professionals to meet the
legal requirement for competent advice.  In addition, they provide consistent
training, advice and support to managers and staff, to ensure they meet their
legal obligations in relation to Health and Safety at work. Also, there are various
groups of stakeholders and committees, such as Trade unions, Employee Joint
Consultative Committee and Strategic H&S Consultative Committee that input
their feedback for the planning, doing and monitoring of H&S within the Council. 
5.2.5 In accordance with the Occupational Health & Safety Policy, where specialist
technical advice cannot be provided internally within the Council, competent
external specialist advice must be obtained. We noted that technical specialists
have been engaged in certain areas to support preventive maintenance
activities. These services remain subject to third-party audit requirements and
the instructions of external agencies and regulators such as the Health and
Safety Executive (HSE), Scottish Fire and Rescue Service (SFRS), Scottish
Environmental Protection Agency (SEPA), and the Care Inspectorate etc. In
most of the cases their advice and instructions have been followed to ensure
full statutory compliance. 
5.2.6 The auditor attended the Strategic Health and Safety Consultative Committee
meetings held on 12 March 2026 and 01 June 2026 and was satisfied that there
was evidence of employee representative participation and active involvement
of service managers and team leaders on the H&S matters considered and
discussed. 
5.2.7 Audit has reviewed last year’s Employee Joint Consultative Committee (EJCC)
minutes and is satisfied with the content of the recorded minutes, participation
and decision making. During these meetings, H&S and Fire safety performance
has been discussed.  This includes details of incident reporting and training
figures.

Page 7

7 
5.2.8 Audit has observed the certificate of employers’ liability insurance which is a
compulsory insurance required under the Employers’ Liability (Compulsory
Insurance) Act 1969 and associated regulations, which mandates employers to
obtain insurance to cover liability for employee injury or illness arising from
work. This has been obtained and renewed for the current year (until 30
September 2026) from Zurich Insurance Company Ltd. All fleet vehicles have
been insured under Motor insurance and other relevant insurances have been
obtained by Council including public liability insurance. 
5.2.9 We appreciate the efforts taken by the H&S Team to move from an expensive
external system for the incident reporting to an in-house system. Currently, all
the incidents are reported through the MyPKC platform and those are monitored
by H&S Team. Most of the services have confirmed that they use the current
system. The auditor participated in a pilot training session on incident
investigation conducted by the H&S Team on 29April 2026 and satisfied with
the content and delivery. 
5.2.10 The auditor has checked the arrangement of H&S of the fleet employees and
is satisfied with overall risk assessment procedures, vehicle maintenance,
drivers’ assessments (based on the point system), incident reporting, follow up
with insurance team and performance monitoring. Specially, recent
implementation of random eye test of the drivers is welcomed. 
5.2.11 The auditor has checked the arrangements for H&S of the HART team and
observed that clearly defined H&S responsibilities, including the completion and
adherence to risk assessments, infection control measures, safe systems of
work, and established reporting procedures are in place. All the risk
assessments have been reviewed on 18 March 2026, are maintained, up to
date, and are subject to annual review. 
5.2.12 Justice services operate across multiple sites in Perth within a higher risk
environment and demonstrate good practice, through clear identification and
management of key risks to the employees. As per the team leader, all risk
assessments are up to date and mandatory H&S training is in place for all staff.
Incidents are formally reported and reviewed, lone working is supported by
policy and personal alert systems, and staff wellbeing is promoted through
regular supervision, absence management, and access to counselling, with
overall compliance overseen by the Justice Services Health & Safety Meetings. 
5.2.13 In Communities Repair & Improvement Services, a strong and proactive
approach to H&S through comprehensive risk assessments, regular mandatory
training, and consistent communication is in place. Safety is embedded into
daily operations through toolbox talks, monthly meetings, standing H&S agenda
items, and unannounced site checks carried out by both compliance officers
and trade coordinators. The use of corporate systems for incident reporting,
lone-working monitoring, and job management ensures risks are tracked
effectively, while quarterly meetings with the Health & Safety Team help the
service stay aligned with legislative updates and best practice. Staff wellbeing
is also prioritised through one-to-one meetings, an open-door policy, and
proactive support via Occupational Health.

Page 8

8 
5.2.14 H&S of Direct Services is clearly positioned as providing a foundation to all
operational activities, with responsibilities embedded through training,
supervision, and monitoring.  This takes place across refuse collection, waste
management, grounds maintenance, and Burials. There is statutory training for
all staff (in Key2 system), and specialist training needs (e.g. machinery use,
manual handling, driver competence) are clearly identified and delivered as per
Lifting Operations and Lifting Equipment Regulations 1998 (LOLER) and Provision
and Use of Work Equipment Regulations 1998 (PUWER). Incidents and near
misses are effectively managed through a learning-focused investigation
framework, while controls for lone working, wellbeing support, and clear
communication channels further strengthen safety culture. Ongoing monitoring,
engagement with the Health & Safety Team, and external reviews provide
assurance of compliance and continuous improvement. 
5.2.15 Based on the Local Government Benchmarking Framework (LGBF) data and
internal information, sickness absence has shown a slight year on year
reduction from 2023/24 to 2024/25, with the overall time lost for all employees
decreasing from 5.38% to 5.31% at the Council. However, some areas continue
to experience high levels of sickness absence, particularly Integrated
Healthcare for Older People and Environment & Infrastructure, both of which
remain high risk service areas. People & Culture have introduced several
supportive measures to help reduce H&S related sickness absence. For
example, new managers can access direct case handling support from the
Employee Relations & Wellbeing team, and the Erica chatbot enables
managers to book appointments for advice. In addition, targeted work in
Education & Learning, including a dedicated resource reviewing absence
trends and a working group focused on reducing challenging behaviour in
schools, aims to reduce Violence and Aggression(V&A) incidents related
sickness levels. All managers also have access to a Power BI dashboard,
allowing them to monitor sickness absence trends within their teams. 
6.  Summary of Findings 
6.1 Below is a summary of key findings and actions, which are reflected in the
Management Action Plan, detailed in section 10.  
6.2 To ensure that the Council complies with all Health & Safety legislation
and statutory requirements 
6.2.1 As per HSG65, all large public and private sector organisations are required to
maintain formal procedures for auditing and reporting health and safety
performance. As per the Corporate Occupational Health & Safety Policy section
4.1.4 on Auditing “Strategic Lead areas will be required to audit their own
practices and record these details (inspection etc) in line with their own Action
Plan. In conjunction, the H&S Team will also audit following a H&S audit plan
which will identify compliance and good practice. Audit reports will be reported
into the Employee Joint Consultative Committee and Executive Leadership
Team for discussion and comment.”

Page 9

9 
6.2.2 Our review identified that the H&S Team does not currently have an established
audit plan in place, despite this being a policy requirement. Although this issue
has been acknowledged within the Corporate Risk Register (with an initial
completion target of 31 December 2025), the deadline has since been deferred.
During our discussions, the Team Leader confirmed that the audit process is
expected to be implemented in the Team Plan 2026/27.
[Action point 01] 
6.2.3 Our review noted that, in relation to Risk Register entry SR011, “the
implementation of a robust corporate Health and Safety policy and the
associated topic-specific arrangements” has not yet been fully completed. 
However, we found that no formal approval had been granted for the following
guidance documents:
• Alcohol and Drug Use Guidance (HR Guides)
• First Aid Guidance
• Infection Control Guidance
• General Risk Assessment Guidelines
In addition, no guidance has yet been developed for the Provision and Use of
Work Equipment (PUWER).
[Action point 02] 
6.2.4 Our review of H&S practices within Fleet Management identified that there is
currently no comprehensive policy in place to prevent drivers from operating
vehicles while under the influence of Alcohol or Drugs. Although a memo
referencing an Alcohol and Drug Policy was issued to all staff by the Direct
Service Manager on 14 March 2025, this communication alone is insufficient to
ensure consistent understanding and enforcement. Internal audit opinion’s is
that there should be a robust, council wide Drug and Alcohol policy. 
[Action point 03] 
6.2.5 Section 2.3 in the Occupational Health and Safety Policy, clearly states that
H&S Team (under People & Culture) must work in synergy with a range of other
services including, IT, Insurance, Facilities Management, Estates, Property
Services, Housing Repairs, Education & Learning, and Direct Services to
ensure an integrated and cohesive approach to risk management. 
6.2.6 During our review we have noticed many insurance claims due to various
reasons including fire at properties, trip/ fall and driver errors. However, there
is a lack of effective coordination between the H&S Team and the Insurance
Team, despite the clear importance of this collaboration and explicit
requirement within organisational policies. 
[Action point 04] 
6.2.7 Audit acknowledges that employees working directly with the public may face
increasing risks of Violence and Aggression (V&A), stemming from the nature
of certain frontline services and interactions. As part of its commitment to
safeguarding staff, the Council identifies these behaviours ranging from verbal
abuse to physical assault as significant organisational risks requiring proactive
management and continuous improvement. We observed that established

Page 10

10 
systems including MOSAIC, Northgate (Housing management information
system’ person alerts) facilitate the sharing specific information among Housing
and Social Work Teams. These systems support staff and contractors’
awareness of potential risks and enable informed decision-making when
engaging with service users. 
6.2.8 Despite recognising the seriousness of the V&A, there are gaps in adequacy of
planning, monitoring, and control measures in place by management to protect
a minority of staff. These gaps are especially evident for teams such as
Licensing, Environmental Health, and Food Health and Safety, where staff may
attend locations or interact with individuals without full visibility of potential risks.
The absence of consistent and accessible risk information limits the ability of
manager and staff to undertake appropriate precautionary measures, such as
conducting visits in pairs rather than individually.
[Action point 05]
6.2.9 The Employment Right Act 2025, effective from April 2026, increases
employer’s responsibility and liability for preventing harassment, including
sexual harassment. Employers now need to take “all reasonable steps” to
prevent sexual harassment in the workplace. In our inquiry from the service
manager, it was highlighted challenges in managing this duty due to third party
involvement such as parents, contractors, agency workers etc. In our
observation, it indicates that appropriate preventive arrangements to address
these risks have not yet been fully established.
[Action point 06] 
6.3 To ensure that adequate steps are taken to protect employees, service
users, contractors, and the public from harm 
6.3.1 Several external contractors have been engaged by the Council to deliver a
range of property related services, including janitorial support, cleaning
services, school catering, school crossing patrols, and facilities management to
various Heads of Establishment (HoE). With respect to H&S, each contractor is
fully responsible for ensuring the safety of their own employees as well as any
other individuals present within the premises while carrying out the contracted
activities. The extracts from the relevant parts from the sample contracts have
been reviewed during the audit. 
6.3.2 Although the services are provided directly to HoE, overall oversight and
performance monitoring of all contracted services should be carried out by the
Property Services Team. The responsible person for the management of HoE
Property Services has been appointed recently, and monitoring activities are
still under development stage. It is recognised this as key role since monitoring
is essential in parallel with external audit actions to be implemented.                     
[Action point 07]

Page 11

11 
6.3.3 A new Head of Establishment Premises Handbook was published in May 2025,
replacing the old handbook from June 2015, following the consultation with
representative Service Managers, Heads of Establishment and Head of
Establishment Steering Group. The new handbook has not yet been uploaded
to ERIC, meaning Heads of Establishment do not have access to the current
version, specifically the new Summary of Tasks is required to be accessed by
everyone. At present, only the previous version remains available on the
system.
[Action point 08] 
6.3.4 Training on the newly issued Head of Establishment Premises Handbook has
not yet been fully completed at the time of the audit. Our inquiries confirmed
that several school HoE and non-school HoE have to be trained, indicating that
the rollout remains incomplete. 
[Action point 09] 
6.3.5 In Property Services, multiple suppliers have been appointed based on their
respective areas of expertise to undertake Planned Preventive Maintenance
(PPM) activities across different sites. When upcoming maintenance is
identified, the Property Team raises the relevant work orders within the
Concerto system. All work orders are subject to authorisation by the appropriate
manager through the system. Suppliers are also granted access to the
Concerto system, enabling them to view and manage upcoming maintenance
tasks assigned to them. Notifications are generated through the system to
ensure suppliers are aware of scheduled PPM activities. 
6.3.6 During the Concerto walkthrough testing, a significant number of overdue PPM
tasks were identified. These included statutory, non-statutory, and asset
register based maintenance tasks. Among the overdue statutory tasks, primary
and secondary school properties were included. In our inquiry, management
advised that the backlog was primarily attributable to a single supplier
experiencing resourcing pressures. In addition, the KPI of the supplier reported
for the period October to December 2025 indicates an overall downward trend
in performance. 
October November December
Statutory completion rate 61.54% 17.39% 28.07%
Non-statutory completion rate 42.7% 41.38% 29.63%
Overall completion rate 46.96% 36.36% 28.83% 
[Action point 10] 
6.3.7 In the Concerto system, HoE module is newly embedded to check the duties
done by relevant Business Managers (HoE) and it only includes the schools.
Since there are many other establishments that require proper maintenance
and Compliance Team or Business Manager’s attention, those should be
included in the module soon. Our inquiry has not provided any targeted date on
completion of this.
[Action point 11]

Page 12

12 
6.3.8 The Properties Team confirmed that electrical and mechanical inspections
have been carried out in some of the buildings. However, Structural Survey has
not been carried out along with that. In our inquiry, it was mentioned to us
Building Condition Surveys operate on a five-year rolling programme, managed
by a dedicated Condition Survey Team. These surveys are not recorded within
the PPM system, and the schedule of upcoming surveys must be obtained
directly from the team. We have not yet received this schedule for our review.
[Action point 12] 
6.3.9 In our discussion with the Service Manager Corporate Landlord, it was
mentioned that Council is following SFG20 (the industry standard for building
maintenance). However, this SFG20 system is still in development stage and
not yet fully integrated to the Concerto system. In our opinion for the compliance
this integration is highly important.
[Action point 13] 
6.3.10 Regarding suggested remedial action in the Concerto Remedial Action Bar, it
appears quick actions have not been taken and followed up by the Compliance
Team. For example, regarding Perth Grammar Schools Sports Grammar pitch
servicing have been highlighted as high priority in November 2025 which
require structural engineers work due to movement on column base. However,
it has not yet been completed on our audit date. This section should be cleared
by a responsible person in timely manner.
[Action point 14] 
6.4 To ensure H&S training, incident reporting, and risk assessments are
robust and effective 
6.4.1 There is currently no formal mechanism in place to ensure that all required
training is completed by all employees. Although all mandatory modules are
available through the e-learning platform, there is no effective cross-checking
or oversight. Managers can request a report of their staff to check the training
completions and there is no current direct access for managers to do this via
the PKC Learn system.
[Action point 15] 
6.4.1 During our review on HART team’s H&S, it was notified to us that the staff of
the HART team have been unable to complete e-learning due to lack of
protected time. 
[Action point 16] 
6.4.2 In our inquiry in relation to mandatory H&S training of HART teams it was
noticed that provided mandatory training compliance has significant gaps.
Several training courses are well below expected compliance levels:
• Violence & Aggression Awareness – 25%
• DSE Training – 45%
• Infection Control e-learning – 28% (though the workshop is higher at 87%)

Page 13

13 
• Moving with Dignity – 75%
Out of the 40 mandatory training categories, only 14 have achieved a
completion rate above 50%, which is a significant concern given the high
number of medication errors recorded in Q2 25–26. The auditor is of the opinion
that training compliance must be monitored more rigorously to ensure staff are
equipped with the necessary knowledge and skills to reduce errors and
maintain safe service delivery.
[Action point 17] 
6.4.3 In accordance with the Reporting of Injuries, Diseases and Dangerous
Occurrences Regulations (RIDDOR), the Council must ensure that all
reportable incidents are notified to the HSE within the statutory timeframes.
Serious incidents (including fatalities, specified major injuries, hospital
treatment of non-workers, and dangerous occurrences) must be reported
immediately and without delay, reflecting the requirement for urgent regulatory
notification. All other reportable events must be followed by a full written
submission to the HSE within 10 days, ensuring timely and accurate
compliance with the regulatory process. In cases where an employee is
incapacitated for more than seven consecutive days, the incident must be
formally reported within 15 days of the accident date, consistent with the
statutory reporting thresholds for over 7-day injuries. The H&S Team is
responsible for determining RIDDOR applicability. 
6.4.4 We noted that, on several occasions, RIDDOR reportable incidents were not
submitted within the statutory timelines required by the HSE. In certain cases,
reports were submitted several months after the incident occurred. However,
adherence to these timeframes is essential to maintain compliance and support
effective oversight of workplace health and safety. 
[Action point 18] 
6.4.5 The H&S Team has made renewed efforts to address incidents, however, the
lack of reduction in reportable incidents observed by the auditor has highlighted
the need for stronger support and understanding from all managers. Without
proper safety measures in place, employees remain at risk, insurance costs
may rise due to increased claims, and the Council faces potential harm to the
public as well as reputational damage. It is therefore essential that managers
actively contribute to targeted actions aimed at reducing reportable incidents
across the organisation.
[Action point 19] 
6.4.6 The manager of Direct Services confirmed that approximately 300 Risk
Assessments and Safe Systems of Work are currently in place in his service.
We identified that the volume and complexity of these documents present
challenges in terms of effective management and oversight of H&S. However,
efforts are underway to reduce this complexity, and a substantial review has
been conducted by the H&S Team. A designated responsible officer has been
appointed to oversee and follow up on the review outcomes. Several
improvement actions have been identified within the action plan, and work is
underway to implement them.

Page 14

14 
6.4.7 In accordance with section 53 of the Fire (Scotland) Act 2005 and regulation 9
of the Fire Safety (Scotland) Regulations 2006, fire risk assessments must be
carried out and kept under review regularly. In general practice, this includes
annual review (as adopted across councils, schools, offices and care
environments) and review following any significant change or where the
assessment is no longer valid. 
6.4.8 Scottish Fire and Rescue Service (SFRS) carried out 4 audits at Council
premises during 2025/26. The SFRS also carried out 21 operational visits to
domestic high-rise properties. In our inquiry, it is mentioned that H&S Team
does not monitor outstanding actions from SFRS audit. They mentioned that
this information will be available to the Head of Establishment from each
audited property or to the Housing and Repairs Team for domestic premises.
With the development of Concerto these outstanding actions will be signed off
when the task is completed. However, there is no evidence on the completion
of any actions just now and there is no one responsible person from the H&S
Team to follow up.
[Action point 20] 
6.4.9 The auditor was informed that the H&S Team carry out an annual FRA review
of all buildings with sleeping accommodation such as care homes and other
buildings with significant fire risks such as Friarton Depot. And re-assess
existing FRAs at 24 months, 36 months, 48 months or 60 months frequencies
depending on many factors. However, the fire risk assessment schedule
provided is not completed and the re assessment frequencies have not been
set up properly for the many of the properties.
[Action point 21] 
6.4.10 In relation to the Council Headquarters at 2 High Street, a new FRA was
completed on 27 May 2026 following the significant changes in layout and
occupancy during 2025. However, the assessment identified that although the
overall fire risk is considered tolerable, few high-priority actions remain and
several recommendations from the previous FRA (August 2023) have still not
been implemented. Although fire drills were carried out in March and May 2026,
the existence of outstanding and newly identified issues indicates that fire
safety arrangements require further strengthening to ensure full compliance
and effective risk management. 
[Action point 22] 
6.4.11 Regarding the Pullar house building, the ownership has changed in September
2025, and the last FRA was dated 24 July 2024. In the FRA schedule it has
mentioned that the next FRA is due in July 2026 and in our inquiry, it is
mentioned that there is ongoing discussion with other users of the building
regarding next FRA. However, the FRA is yet to be done.
[Action point 23]

Page 15

15 
7.  Conclusion 
7.1  The Internal Audit review is able to place reasonable assurance on the overall
control environment for arrangements for the compilation of the annual
submissions to the Housing Regulator. The agreed actions, once implemented,
should enable the Internal Audit to place substantial assurance on these. 
8.  Acknowledgements 
8.1  Internal Audit would like to thank all officers who were involved in this audit, 
G Boland, Strategic Lead – Strategic Planning, People & Performance
P Johnstone, People & Culture Manager
L Hamilton, Team Leader- Health & Safety 
M Young, Fire Safety Advisor
F Gamlen, Systems Officer
G Key, Principal Officer – Energy & Engineering
A Cook, Service Manager – Contracts & Facilities
L Peoples, Team Leader -Contracts & Facilities
A Brown, Assistant Fleet Manager
C Shepherd, Team Leader Communities - Repairs & Improvements
N Gibson, Team Leader (HART)
R Ross, Team Leader – Justice
N Taylor, Direct Services Manager
E Bayne, HR Team Leader
S Burke, PA to Strategic Lead Strategic Planning, People & Performance 
9.  Action Implementation & Follow up 
9.1  Responsibility for the maintenance of adequate and effective controls rests with
management. Where the audit has identified areas for management action,
these are identified in the Management Action Plan. Where a decision is taken
by management not to act in response to findings from this review, it is the
responsibility of management to assess and accept the risk arising from non-
implementation. 
9.2  Achievement of the agreed actions is monitored through Internal Audit’s ‘follow
up’ arrangements.

Page 16

16 
10.  Management Action Plan 
Action
Point
Para.
No Finding Risk
Rating Agreed Action & Evidence Action Owner
Target
Completion
Date
1 6.2.2 Our review identified that the H&S
Team does not currently have an
established audit plan in place,
despite this being a statutory
requirement. Although this issue
has been acknowledged within the
Corporate Risk Register (with an
initial completion target of 31
December 2025), the deadline has
since been deferred. During our
discussions, the Team Leader
confirmed that the audit process is
expected to be implemented in the
Team Plan 2026/27.  
4 Agreed action: 
An audit process and programme
for Health and Safety
performance will be piloted and
subsequently implemented as
part of Team Plan 26/27. 
Agreed evidence:
Approved audit plan
L Hamilton
Team Leader-
Health & Safety 
March 2027
2 6.2.3 Our review noted that, in relation to
Risk Register entry SR011, “the
implementation of a robust
corporate Health and Safety policy
and the associated topic-specific
arrangements” has not yet been
fully completed. 
However, we found that no formal
approval had been granted for the
following guidance documents:
3 Agreed action: 
Continue review of supporting
documentation, to align with
updated Corporate Health and
Safety Policy. This is part of
Team Plan 26/27. 
Agreed evidence:
Approved guidance documents
L Hamilton
Team Leader-
Health & Safety 
March 2027

Page 17

17 
• Alcohol and Drug Use Guidance
(HR Guides)
• First Aid Guidance
• Infection Control Guidance
• General Risk Assessment
Guidelines
In addition, no guidance has yet
been developed for the Provision
and Use of Work Equipment
(PUWER). 
3 6.2.4 Our review of H&S practices within
Fleet Management identified that
there is currently no
comprehensive policy in place to
prevent drivers from operating
vehicles while under the influence
of Alcohol or Drugs. Although a
memo referencing an Alcohol and
Drug Policy was issued to all staff
by the Direct Service Manager on
14 March 2025, this communication
alone is insufficient. Internal audit
opinion’s is that there should be a
robust, council wide Drug and
Alcohol policy. 
3 Agreed action: 
There are a Management
Arrangement and Guidance in
place. Even though there is no
control sheet on documents, they
have all been through Employee
Joint Consultative Committee
(EJCC). 
Managers should identify this
and put in place suitable and
sufficient control measures to
address risks from drugs and
alcohol. The People & Culture
Manager will explore approaches
adopted by other local authorities
to understand potential options
available and agreed to take
further discussions with trade
unions. 
Agreed evidence:
P Johnstone
People &
Culture
Manager
January
2027

Page 18

18 
• Board minutes 
• Approved new drug and
Alcohol policy 
4 6.2.6 During our review we have noticed
many insurances claimed due to
various reason including fire at
properties, trip/ fall, driver errors
etc. However, there is a lack of
effective coordination between the
H&S Team and the Insurance
Team, despite the clear importance
of this collaboration and explicit
requirement within organisational
policies. 
3 Agreed action: 
• Agree with Insurance Team
on quarterly updates.
• Ask for Insurance Team input
into Committee quarterly
reporting.
• Feedback on claims and legal
rulings from Insurance Team
to Health and Safety Team.
• Incorporation of insurance
team information in reporting
and planning carried out by
the Health and Safety Team. 
Agreed evidence:
• Quarterly update reports from
Insurance Team
• Communication with
Insurance Team 
L Hamilton
Team Leader-
Health & Safety 
G Walker
Corporate Asset
Management
Officer 
December
2026
5 6.2.8 Despite recognising the
seriousness of the V&A, there are
gaps in adequacy of planning,
monitoring, and control measures
in place by management to protect
a minority of staff. These gaps are
especially evident for teams such
4 Agreed action: 
Develop and implement
enhanced processes to enable
appropriate access to existing
risk information and systems, in
compliance with relevant legal
and data protection
G Boland
Strategic Lead –
Strategic
Planning,
People &
Performance 
June 2027

Page 19

19 
as Licensing, Environmental
Health, and Food Health and
Safety, where staff may attend
locations or interact with individuals
without full visibility of potential
risks. The absence of consistent
and accessible risk information
limits the ability of managers and
staff to undertake appropriate
precautionary measures, such as
conducting visits in pairs rather
than individually. 
requirements. This should
include establishing a more
coordinated and consistent
approach to sharing V&A risk
information across services. 
Agreed evidence:
Documented procedures on new
or revised processes for
accessing and sharing V&A risk
information. 
6 6.2.9 The Employment Right Act 2025,
effective from April 2026, increases
employer’s responsibility and
liability for preventing harassment,
including sexual harassment.
Employers now need to take “all
reasonable steps” to prevent
sexual harassment in the
workplace. In our inquiry from the
service manager, it was highlighted
challenges in managing this duty
due to third party involvement such
as parents, contractors, agency
workers etc. In our observation, it
indicates that appropriate
preventive arrangements to
address these risks have not yet
been fully established. 
3 Agreed action: 
There are no final guidelines
provided by the government yet
specifically defining “all
reasonable steps”. However,
Sexual Harassment has been
added to the General Risk
Assessment for consideration.
Further arrangements are under
the development stage such as
whistleblowing guidance for
managers and employees and
processes for complaints and
grievances etc. 
Agreed evidence:
Approved whistleblower
guidance
P Johnstone
People &
Culture
Manager
October
2026

Page 20

20 
Approved new processes
developed on Sexual
Harassment 
7 6.3.2 Although the services are provided
directly to HoE, overall oversight
and performance monitoring of
specific contracted services should
be carried out by the Property
Services Team. The responsible
person for the management of HoE
Property Services has been
appointed recently, and monitoring
activities are still under
development stage. It is recognised
this as key role since monitoring is
essential in parallel with external
audit actions to be implemented. 
4 Agreed action: 
All outsourced HoE tasks to be
logged on the HoE Concerto
system, and random sampling to
be provided to support
completion of these checks.  
All H&S issues in relation to
relevant outsourced services to
be discussed as part of relevant
operational monitoring meetings
as required, and all H&S incident
reports to be provided upon
request.  
Agreed evidence:
HoE records on Concerto.
Minutes of operational meetings.
Copies of any relevant
inspections and observations.
Any relevant H&S incident
reports and follow on actions 
A Cook 
Service
Manager –
Contracts &
Facilities
September
2026
8 6.3.3 A new Head of Establishment
Premises Handbook was published
in May 2025, replacing the previous
version from June 2015, following
consultation with representative
1 Agreed action: 
SharePoint site to be signed off,
with updated Handbook
available. Heads of
Establishment who have been
L Hamilton
Team Leader -
Health & Safety 
Completed

Page 21

21 
Service Managers, Heads of
Establishment and Head of
Establishment Steering Group. The
new handbook has not yet been
uploaded to ERIC, meaning Head
of Establishment do not have
access to the current version,
specifically the new Summary of
Task is required to be access by
everyone. At present, only the
previous version remains available
on the system. 
trained have been linked to the
updated Handbook already. 
Agreed evidence:
Link to the updated document 
9 6.3.4 Training on the newly issued Head
of Establishment Premises
Handbook has not yet been fully
completed at the time of the audit.
Our inquiries confirmed that several
school HoEs and non-school HoEs
are still awaiting training, indicating
that the rollout remains incomplete. 
3 Agreed action: 
Final training session is on 2
June 2026 
Agreed evidence:
Updated training completion list
L Hamilton
Team Leader-
Health & Safety 
Completed
10 6.3.6 During the Concerto walkthrough
testing, a significant number of
overdue PPM tasks were identified.
These included statutory, non-
statutory, and asset register based
maintenance tasks. Among the
overdue statutory tasks, primary
and secondary school properties
were included. In our inquiry,
management advised that the
3 Agreed action: 
• To work with current supplier
to improve performance
during current contract which
is due to expire in Apr 2027. 
• Contractor performance also
improved during first quarter
of 2026 and continues to
improve. New contract will
also be in place from Apr
G Key 
Principal Officer
– Energy &
Engineering
April 2027

Page 22

22 
backlog was primarily attributable
to a single supplier experiencing
resourcing pressures. In addition,
the KPI of the supplier reported for
the period October to December
2025 indicates an overall
downward trend in performance. 
2027, and contractor may not
be successful in winning new
contract. 
Agreed evidence:
• KPI for the first quarter 2026
• Contractor award document
2027
11 6.3.7 In the Concerto system, HoE
module is newly embedded to
check the duties done by relevant
Business Managers (HoE) and it
only includes the schools. Since
there are so many other
establishments that require proper
maintenance and Compliance
Team or Business Manager’s
attention, those should be included
in the module soon. Our inquiry has
not provided any targeted date on
completion of this. 
3 Agreed action: 
All other relevant premises to be
added to HoE Concerto
Database.
HoE to be identified and relevant
records to be updated. 
Agreed evidence:
Data base updated with all
relevant HoE information. 
A Cook 
Service
Manager –
Contracts &
Facilities
October
2026 
12 6.3.8 The Properties Team confirmed
that electrical and mechanical
inspections have been carried out
some of the buildings. However,
Structural Survey has not been
carried out along with that. In our
inquiry it was mentioned to us
Building Condition Surveys operate
3 Agreed action: 
A programme for Building
condition surveys for 2026/27 are
currently being reviewed
manually by the in-house building
surveyor and will be issued to the
supplier to undertake these.
Further, development is also
G Key 
Principal Officer
– Energy &
Engineering 
July 2026

Page 23

23 
on a five-year rolling programme,
managed by a dedicated Condition
Survey Team. These surveys are
not recorded within the PPM
system, and the schedule of
upcoming surveys must be
obtained directly from the team. We
have not yet received this schedule
for our review. 
required with Concerto to
automate the programme for
Building condition surveys which
is currently being explored at
present. Structural surveys are
not carried out as standard only
where identified by the building
surveyors in accordance with
Scottish Government core facts
methodology. 
Agreed evidence:
Programme of surveys 
13 6.3.9 In our discussion with the Service
Manager Corporate Landlord, it has
mentioned that the Council is
following SFG20 (the industry
standard for building maintenance).
However, this SFG20 system is still
in development stage and not yet
fully integrated to the Concerto
system. In our opinion for the
compliance this integration is highly
important. 
2 Agreed action: 
SFG20 is to be integrated into
concerto for future contract. It is
not required at present for
current contract as robust and
compliant specifications are in
place already but for
improvement and efficiency for
the new contract this is to be
automated using SFG20. 
Agreed evidence:
Systems will be integrated in
advance of new contract being
awarded in Apr 2027. 
G Key 
Principal Officer
– Energy &
Engineering 
November
2026

Page 24

24 
14 6.3.10 Regarding the suggested remedial
actions recorded in the Concerto
Remedial Action Bar, it appears
that timely actions and follow-ups
have not been carried out by the
Compliance Team. However, it has
been explained to us that the
required work has in fact been
completed, but the system has not
been updated accordingly.
This kind of outdated system
information may result in inaccurate
reporting, misrepresentation of
compliance status, and the
perception that critical actions are
delayed or not performed. 
4 Agreed action: 
Work is currently progressing
with Concerto team and IT
colleagues to investigate
automating of some of the
functions which will free up time
for members of staff to review
remedial tasks. A re-structure in
Property services will also
provide additional resources to
dedicate to this function. 
Agreed evidence:
• Confirmation from
IT/Concerto team on fully
automation
• Reports run on remedial
actions 
G Key 
Principal Officer
– Energy &
Engineering 
December
2026
15 6.4.1 There is currently no formal
mechanism in place to ensure that
all required training is completed by
all employees. Although all
mandatory modules are available
through the e-learning platform,
there is no effective cross-checking
or oversight. Managers can request
a report of their staff to check the
training completions and there is no
current direct access for managers
to do this via the PKC Learn
system.
4 Agreed action: 
• Training records will be part
of the new audit process.
• Ongoing discussion with the
supplier of the platform and
PKC IT to develop an API
(Application Programming
Interface) and potentially
develop a dashboard to
ensure effective tracking and
completion of mandatory
training. 
L Hamilton
Team Leader-
Health & Safety 
J Cassidy
Employee
Engagement
Officer 
March 2027

Page 25

25 
Agreed evidence:
• Training completion records
• New platform to track he is
training completion 
16 6.4.2 During our review on HART team’s
H&S, it was notified to us that the
staff of the HART team have been
unable to complete e-learning due
to lack of protected time. 
3 Agreed action: 
Allocate protected time for staff
to complete outstanding
mandatory e-learning and
monitor progress through locality
co-ordinators. 
Agreed evidence:
Training records showing
completion rates, list of
outstanding training, and periodic
monitoring reports. 
N Gibson
Team Leader -
HART 
August
2026
17 6.4.3 Out of the 40 mandatory training
categories, only 14 have achieved
a completion rate above 50%,
which is a significant concern given
the high number of medication
errors recorded in Q2 25–26. The
audit is of the opinion that training
compliance must be monitored
more rigorously to ensure staff are
equipped with the necessary
knowledge and skills to reduce
errors and maintain safe service
delivery.
4 Agreed action: 
Continue to ensure all staff
complete medication training and
competency assessments and
implement the medication
checklist to reduce errors. 
Agreed evidence:
Medication training and
competency records, checklist
implementation evidence, and
reports demonstrating reduction
in medication errors. 
N Gibson
Team Leader -
HART 
August
2026

Page 26

26 
18 6.4.5 We noted that, on several
occasions, RIDDOR reportable
incidents were not submitted within
the statutory timelines required by
the HSE. In certain cases, reports
were submitted several months
after the incident occurred.
However, adherence to these
timeframes is essential to maintain
compliance and support effective
oversight of workplace health and
safety. 
4 Agreed action: 
• Reinforcement on Incident
Reporting training
• SHSCC reminded of
importance
• Health and Safety Team now
check absence dates, as over
7-day absences have been
the most problematic. 
Agreed evidence:
• Summary of incident reports
to HSE 
L Hamilton
Team Leader -
Health & Safety 
December
2026
19 6.4.6 Despite the continued efforts of the
H&S Team, in the consistent level
of reportable incidents observed
has highlighted the need for
stronger support and
understanding from all managers.
Without proper safety measures in
place, employees remain at risk,
insurance costs may rise due to
increased claims, and the council
faces potential harm to the public
as well as reputational damage. It
is therefore essential that
managers actively contribute to
targeted actions aimed at reducing
reportable incidents across the
organisation. 
3 Agreed action: 
Reinforce through the Strategic
Health and Safety Consultative
Committee (SHSCC) framework
and obtain active support from all
Service Managers to reduce the
number of reportable incidents. 
Agreed evidence:
Quarterly reports on incidents
G Boland
Strategic Lead –
Strategic
Planning,
People &
Performance 
L Hamilton
Team Leader -
Health & Safety 
August
2026

Page 27

27 
20 6.4.9 Scottish Fire and Rescue Service
(SFRS) carried out 4 audits at
Council premises during 2025/26.
The SFRS also carried out 21
operational visits to domestic high-
rise properties. In our inquiry, it is
mentioned that H&S Team does
not monitor outstanding actions
from SFRS audit. They mentioned
that this information will be
available to the Head of
Establishment from each audited
property or to the Housing and
Repairs Team for domestic
premises. With the development of
Concerto these outstanding actions
will be signed off when the task is
completed. However, there is no
evidence on the completion of any
actions just now and there is no
one responsible person from the
H&S Team to follow up. 
4 Agreed action: 
Write to all Heads of
Establishment to remind them to
let the Health and Safety Team
know if they are being visited by
SFRS, and to share actions with
the Fire Safety Adviser.
Email Heads of Establishment
and ask them to update their
action plans and report when
actions are completed. 
Agreed evidence:
• Email correspondence
• Evidence on action
completion
L Hamilton
Team Leader -
Health & Safety 
December
2026
21 6.4.10 The auditor was informed that the
H&S Team carry out an annual
FRA review of all buildings with
sleeping accommodation such as
care homes and other buildings
with significant fire risks such as
Friarton Depot. Other premises
have their FRAs re-assessed at 24
months, 36 months, 48 months or
3 Agreed action: 
Check the work schedule to
ensure it is up to date. 
Agreed evidence:
Updated work schedule
L Hamilton
Team Leader -
Health & Safety 
August
2026

Page 28

28 
60 months frequencies depending
on many factors. However, the fire
risk assessment schedule provided
is not completed and the re-
assessment frequencies have not
been set up properly for the many
of the properties. 
22 6.4.11 In relation to the Council
Headquarters at 2 High Street, a
new FRA was completed on 27
May 2026 following the significant
changes in layout and occupancy
during 2025. However, the
assessment identified that although
the overall fire risk is considered
tolerable, few high-priority actions
remain and several
recommendations from the
previous FRA (August 2023) have
still not been implemented.
Although fire drills were carried out
in March and May 2026, the
existence of outstanding and newly
identified issues indicates that fire
safety arrangements require further
strengthening to ensure full
compliance and effective risk
management. 
2 Agreed action: 
Property action:
• Awaiting costs from supplier
to undertake surveys for fire
doors throughout the building.
It should be noted the building
was fully refurbished and all
fire doors were replaced as
part of refurbishment.
• Other outstanding actions
which relate to fire stopping
will be reviewed by internal
architectural resources
following meeting on 8 June
2026 and a contractor will be
engaged in due course to
carry out necessary remedial
works.  
HoE action:
• Coordinate with Property
Service Team to ensure all
fire safety matters are
addressed collaboratively.
G Key  
Principal Officer
– Energy &
Engineering 
S Walker 
HoE, 2 High
Street, Perth 
December
2026 
January
2027

Page 29

29 
• Complete the mandatory fire
safety self-assessment 
• Remove fire hazards such as
portable heaters, insecure
storage and poor
housekeeping practices within
the building.
• Strengthening the fire safety
management through
frequent checks, training and
record keeping
• Ensure high-risk areas are
secured and enforcing safe
working practices 
Agreed evidence:
• Completed Annual Self-
Assessment and schedule
• Next FRA to ensure previous
actions have been fully
completed
23 6.4.12 Regarding the Pullar house
building, the ownership has
changed in September 2025, and
the last FRA was dated 24 July
2024. In the FRA schedule it has
mentioned that the next FRA is due
in July 2026 and in our inquiry, it is
mentioned that there is ongoing
discussion with other users of the
building regarding next FRA.
2 Agreed action: 
On completion of the revised Fire
Strategy an updated FRA will be
put in place. Any actions arising
from the revised FRA will be
addressed by the HoE for Pullar
House. 
Agreed evidence:
Updated FRA in place
L Hamilton
Team Leader -
Health & Safety 
A Cook 
Service
Manager –
Contracts &
Facilities 
August
2026

Page 30

30 
However, the FRA is yet to be
done.

Page 31

31 
11.  Authorisation 
11.1 The auditor for this assignment was D. Arachchilage. The supervising auditor
was J Clark.
This report is authorised for issue: 
12.  Distribution 
12.1 This report has been distributed to:
T Glen, Chief Executive
C Mailer, Depute Chief Executive
Z Robertson, Director/Chief Officer Perth & Kinross Health & Social care
Partnership
L Simpson, Strategic Lead - Legal & Governance 
S Walker, Strategic Lead - Finance and Business Support
E Ritchie, Strategic Lead - Housing & Communities
F Crofts, Strategic Lead - Environment and Infrastructure
A Singh, Strategic Lead - Children, Families and Justice
J Beveridge, Strategic Lead - Property Services
A Taylor, Strategic Lead - Customer and Digital Services
S Merone, Strategic Lead - Economy, Development and Planning
D Macluskey, Strategic Lead - Education and Learning
C Guild, Strategic Lead - Projects and Programmes
G Boland, Strategic Lead – Strategic Planning, People & Performance
P Johnstone, People & Culture Manager
L Hamilton, Team Leader- Health & Safety
G Key, Principal Officer – Energy & Engineering
A Cook, Service Manager – Contracts & Facilities
A Brown, Assistant Fleet Manager
N Gibson, Team Leader - HART
J McColl, Service Manager - Repairs & Improvements
N Taylor, Direct Services Manager
J Cassidy, Employee Engagement Officer
G Walker, Corporate Asset Management Officer
Committee Services
External Audit

Page 32

32 
13.  Assessment Definitions 
13.1 The following table contains the definitions of the control objective
assessment. 
Control Objective Assessment
Level of assurance Definition
Substantial Assurance A sound system of governance, risk management and control
exists, with internal controls operating effectively and being
consistently applied to support the achievement of objectives in
the area audited.
Reasonable Assurance There is a generally sound system of governance, risk
management and control in place. Some issues, non-
compliance or scope for improvement were identified which may
put at risk the achievement of objectives in the area audited.
Limited Assurance Significant gaps, weaknesses or non-compliance were
identified. Improvement is required to the system of
governance, risk management and control to effectively manage
risks to the achievement of objectives in the area audited.
No Assurance Immediate action is required to address fundamental gaps,
weaknesses or non-compliance identified. The system of
governance, risk management and control is inadequate to
effectively manage risks to the achievement of objectives in the
area audited. 
13.2 The following table contains the definitions applied by Internal Audit in rating
audit findings/actions. 
Risk Rating for Individual Findings
Rating Rating
description
Definition
5 Critical Significant observations / major concerns which require
immediate action. Management will need to add these to the
appropriate Service risk register
Issue represents a control weakness which could cause, or is
causing, severe disruption of the process or severe adverse
effect on the ability to achieve process objectives
4 High Significant observations regarding the absence / failure of key
controls requiring urgent action. Management should consider
adding these to the appropriate Service / divisional risk
register
Issue represents a control weakness which could have, or is
having, major adverse effect on the ability to achieve process
objectives
3 Medium Observations regarding the effectiveness of key controls
requiring reasonably urgent action. Management should
consider these when updating any divisional / team risk
registers
Issue represents a control weakness which could have, or is
having, significant adverse effect on the ability to achieve
process objectives

Page 33

33 
2 Low Minor observations regarding the adequacy of controls which
require action to improve the efficiency, effectiveness, or
economy of operations or which otherwise require to be
brought to the attention of Senior Management
Issue represents a minor control weakness with minimal but
reportable impact on the ability to achieve process objectives
1 Trivial / Minor Very minor observations which will be raised during the audit
and may not be included within the final report
Issue represents a very minor control weakness with
negligible impact on the ability to achieve process objectives.
The issue will be raised during the audit and may not be
included within the final report.