Agenda Document Pack - Audit, Risk and Scrutiny Board - 04/11/2024
Renfrewshire Council · 4 November 2024
Back to Audit, Risk and Scrutiny Board — 4 November 2024 and its agenda
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Notice of Meeting and Agenda Audit, Risk and Scrutiny Board Date Time Venue Monday, 04 November 2024 15:00 Council Chambers (Renfrewshire), Council Headquarters, Renfrewshire House, Cotton Street, Paisley, PA1 1AN MARK CONAGHAN Head of Corporate Governance Membership Councillor Andy Doig (Convener): Councillor Janis McDonald (Depute Convener): Councillor Jennifer Adam: Councillor Chris Gilmour: Councillor John Gray: Councillor Lisa-Marie Hughes: Councillor Robert Innes: Councillor James MacLaren: Councillor Ben Smith: Further Information This is a meeting which is open to members of the public. A copy of the agenda and reports for this meeting will be available for inspection prior to the meeting at the Customer Service Centre, Renfrewshire House, Cotton Street, Paisley and online at http://renfrewshire.cmis.uk.com/renfrewshire/CouncilandBoards.aspx For further information, please email democratic-services@renfrewshire.gov.uk Members of the Press and Public Members of the press and public wishing to attend the meeting should report to the customer service centre where they will be met and directed to the meeting. Hybrid Meeting Please note that this meeting is scheduled to be held in the Council Chambers. However, it is a hybrid meeting and arrangements have been made for members to join the meeting remotely should they wish.
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Webcasting of Meeting This meeting will be filmed for live or subsequent broadcast via the Council’s internet site – at the start of the meeting the Convener will confirm if all or part of the meeting is being filmed. To find the webcast please navigate to https://renfrewshire.public-i.tv/core/portal/home
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Apologies Apologies from members. Declarations of Interest and Transparency Statements Members are asked to declare an interest or make a transparency statement in any item(s) on the agenda and to provide a brief explanation of the nature of the interest or the transparency statement. AUDIT 1 Summary of Internal Audit Reports for the period 1 July to 30 September 2024 Report by Interim Chief Auditor. 1 - 10 2 Internal Audit & Counter Fraud Progress & Performance for period 1 July to 30 September 2024 Report by Interim Chief Auditor. 11 - 16 3 Summary of Internal Audit Activity in Partner Organisations for period 1 July to 30 September 2024 Report by Interim Chief Auditor. 17 - 24 4 Audit Scotland Report – The National Fraud Initiative in Scotland 2024 Report by Interim Chief Auditor. 25 - 66 MONITORING & REVIEWING SERVICE DELIVERY PERFORMANCE POLICIES AND PRACTICE 5 Risk Report November 2024 Report by Director of Finance & Resources. 67 - 98 6 Audit Scotland Report on ‘Tackling Digital Exclusion’ Report by Director of Finance & Resources. 99 - 110
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7 Actions Monitoring Report - Dargavel Primary School Report by Chief Executive. 111 - 146
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___________________________________________________________________ To: Audit, Risk and Scrutiny Board On: 4 November 2024 ___________________________________________________________________ Report by: Chief Auditor ___________________________________________________________________ Heading: Summary of Internal Audit Reports for period 1 July to 30 September 2024 ___________________________________________________________________ 1. Summary 1.1 In line with the Public Sector Internal Audit Standards, Internal Audit must communicate the results of each engagement to the Board. To comply with this requirement, Internal Audit submits regular reports on the findings and conclusions of audit engagements to the Audit, Risk and Scrutiny Board. 1.2 Appendix 1 provides details of audit engagements completed during the period 1 July to 30 September 2024 with the overall assurance rating and the number of recommendations in each risk category. The committee summary for each report is also attached. For each audit assignment where recommendations have been made, the relevant managers have put action plans in place to address the issues raised. 1.3 In addition to the reports listed in the Appendix, Internal Audit has an ongoing commitment to: • A range of corporate and service initiatives; • Progressing of information security matters in partnership with ICT and Legal Services; • The regular provision of advice to departmental officers; • The provision of internal audit services to the associated bodies for which Renfrewshire Council is the lead authority and to OneRen and Renfrewshire Health and Social Care Integrated Joint Board; Item 1 Page 1 of 146
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• Co-ordination of the Council’s corporate risk management activity; • Management of the counter fraud team; • Management of the risk management and insurance team. ___________________________________________________________________ 2. Recommendations 2.1 Members are invited to consider and note the Summary of Internal Audit Reports finalised during the period from 1 July to 30 September 2024. ___________________________________________________________________ Implications of the Report 1. Financial - None 2. HR & Organisational Development - None 3. Community Planning – Safer and Stronger - effective internal audit is an important element of good corporate governance. 4. Legal - None 5. Property/Assets - None 6. Information Technology - None 7. Equality & Human Rights – None 8. Health & Safety – None 9. Procurement - None 10. Risk - The summary reported relates to the delivery of the risk-based internal audit plan. 11. Privacy Impact – None 12. COSLA Implications – None 13. Climate Risk – None 14. Children’s Rights - None ________________________________________________________________ Author: Karen Campbell, Interim Chief Auditor– 07768354651 Page 2 of 146
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Appendix 1 Renfrewshire Council Internal Audit Service Update for Audit, Risk and Scrutiny Board Final Audit Reports issued from 1 July – 30 September 2024 Category Service Engagement Assurance Rating Recommendation Ratings Critical Important Good Practice Service Improvement Assurance Finance & Resources Non-Domestic Rates Reasonable Assurance 0 2 3 0 Environment, Housing & Infrastructure Transportation and Fleet – External Vehicle Hire Limited Assurance 1 5 2 0 Environment, Housing & Infrastructure Waste Management Limited Assurance 2 4 5 1 Note – No assurance rating can be given in respect of investigation assignments Assurance Level Substantial Assurance • There is a sound system of internal control designed to achieve the objectives of the area being reviewed. • The control processes tested are being consistently applied. Reasonable Assurance • The internal control processes are generally satisfactory with some areas of weakness being identified that could put some objectives of the area being reviewed at risk. • There is evidence that the level of non-compliance with some of the control processes may put some of the objectives of the area being reviewed at risk. Limited Assurance • Weaknesses in the system of internal controls are such as to put the objectives of the area being reviewed at risk. Page 3 of 146
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• The level of non-compliance puts the objectives of the area being reviewed at risk. No Assurance • Control processes are generally weak with significant risk to the achievement of the objectives of the area being reviewed. • Significant non-compliance with control processes leaves the processes/systems open to error or abuse. Recommendation Rating Service Improvement Implementation will improve the efficiency / housekeeping of the area under review. Good Practice Implementation will contribute to the general effectiveness of control. Important Implementation will raise the level of assurance provided by the control system to acceptable levels. Critical Addresses a significant risk, impacting on the objectives of the area under review. Page 4 of 146
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Internal Audit Report Finance & Resources Non-Domestic Rates (A0082/2024/001) Date: September 2024 COMMITTEE SUMMARY Audit Objectives The objectives of the audit were to ensure that: a) There is an adequate system in place to ensure the calculation and payment of non- domestic rates. b) All exemptions and discounts have been properly applied. c) All NDR income due is properly accounted for and recorded on the system. d) All accounts have been issued in line with statutory timescales. e) All income due to East Renfrewshire Council has been remitted to their bank account. f) Outstanding debt at the year-end is being appropriately managed. Audit Scope 1. Interviewed the appropriate officers to ascertain the system in place in relation to the billing, collecting and monitoring of NDR income and updating for any recent changes. Identified any areas for improvement. 2. Undertook a series of tests to ensure the system was adequate and operating as intended. 3. Prepared a certificate for East Renfrewshire Council based on the outcome of the audit. Key Audit Assurances 1. There is an adequate system in place for the calculation and payment of Non-Domestic Rates. 2. All exemptions and discounts tested were properly applied. 3. All NDR income due is properly accounted for and recorded on the system. 4. Demand notices are issued according to statutory timescales. 5. All income due to East Renfrewshire Council has been remitted to their bank account. Key Risks Where income and refund reconciliations are not carried out regularly, errors may not be identified timeously. Page 5 of 146
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Internal Audit Report Finance & Resources Non-Domestic Rates (A0082/2024/001) Date: September 2024 Overall Audit Opinion The audit identified that satisfactory controls are in place for the billing and collection of NDR. Reviews of NDR reliefs, granted on the basis of a prior year's applications, have not been carried out in the 2023/24 financial year because management needed to consider the impact of changes in legislation, specifically relating to reliefs, which superseded the normal review process. Evidence for current year reliefs and refunds were available for the samples tested. However, some actions that management stated would be put in place after previous audit recommendations are not fully implemented. It was noted that staff changes have resulted in income and refund reconciliations not being carried out regularly. Also, a significant number of historic credit balances were found to still exist on the NDR system, for which no actions had been taken to identify if these should be cleared or result in refunds to customers. Recommendations in the report to address areas of weakness identified will, if implemented, help strengthen the controls in place for NDR. Management Commentary We are currently in the process of implementing the audit recommendations. Detailed plans have now been put in place to undertake reviews and independent checks on Non-Domestic Reliefs and Discounts. A procedure note has been drafted detailing the process to be followed by staff to review and action credit balances. In relation to the income and refund reconciliations, this is a complex area and we are currently working with our external partners on plans to improve the current process. Page 6 of 146
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Internal Audit Report Environment, Housing & Infrastructure Transportation and Fleet - External Vehicle Hire (A0025/2024/001) Date: August 2024 COMMITTEE SUMMARY Audit Objectives In order to achieve best value when a vehicle is required, there is a centralised service operated by Environment, Housing & Infrastructure Service for the external hire of vehicles. Senior Management Team recognised that there had been a complete change of staff responsible for operating this service and therefore requested a review of the processes in place to ensure that they were adequate. The objectives of the audit were to ensure that: a) There is a clear process for obtaining external vehicle hires and determine if there are any exceptions that do not go through the hire desk and identify the reasons for this. b) There is an authorisation process in place for requesting an external hire. c) There is a clear justification of business need for each hire. d) Contracts are in place for external vehicle hires where necessary and only contracted suppliers are being used. e) Hire costs are being verified prior to processing the invoices and are in line with the contracted rates. f) Determine if costs are recharged and if so, ensure that recharges are accurate. Audit Scope 1. Interviewed the appropriate officers to understand the arrangements in place for administering hire vehicles. 2. Carried out sample testing to confirm the adequacy of the controls in place over hire vehicles. Key Audit Assurances A contract framework has been put in place by Scotland Excel covering vehicle hires. Through sample audit testing we ascertained that all hires are procured from approved suppliers that are on this framework. Key Risks 1. Council staff could be unaware of how to request a vehicle hire as no document guidance could be found. 2. Unsanctioned expenditure spend could be committed as the internal controls surrounding the request and ordering processes for external vehicle hires was found to be unsatisfactory. Page 7 of 146
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Internal Audit Report Environment, Housing & Infrastructure Transportation and Fleet - External Vehicle Hire (A0025/2024/001) Date: August 2024 3. There is a risk that incorrect rates could be being charged and paid for as there are no verification checks in place to confirm that hire costs on received invoices are in line with the most up to date contracted rates from Scotland Excel. Overall Audit Opinion Hiring external vehicles on behalf of Council Departments is one of the services the Fleet and Sustainable Transport section is responsible for. The current processes being carried out in relation to this task need to be amended to ensure there is a satisfactory level of internal control, particularly in relation to the ordering and authorisation processes. Clear, concise instructions also need to be readily available to services to ensure they are aware of the process to follow for requesting the hire of a vehicle and this would help services to submit properly completed hire request forms to the hire desk. The auditor made recommendations to address these issues. Management Commentary We are currently in the process of actioning the recommendations. Procedures for both service staff and fleet management staff are being finalised detailing the processes to be followed when an external hire is required. The procedures for fleet management staff will cover the checks that require be undertaken when a request is received as well as the ordering, payment and recharging processes. Page 8 of 146
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Internal Audit Report Environment, Housing & Infrastructure Waste Management (A0028/2024/001) Date: August 2024 COMMITTEE SUMMARY Audit Objectives The objectives of the review were to ensure that: a) There is an adequate management and supervisory structure in place with clearly defined roles and responsibilities for the collection of commercial waste. b) There is procedural/guidance documentation in place in relation to commercial waste which has been communicated to and is easily accessible by staff. c) Up to date route lists, which include the number of bins to be collected from each commercial property, are issued and followed by operatives. d) Any deviations from the route lists, including missed uplifts are properly authorised and there is an adequate audit trail which supports any changes. e) There are appropriate contracts in place with commercial customers. f) Arrangements are in place within the service to ensure that commercial clients are invoiced accurately, non-payment is notified timeously and services suspended where required and any updates to invoicing are communicated to the debtors’ team. g) There are appropriate Key Performance Indicators (KPI’s) in place which are adequately monitored by management and when necessary, action is taken to investigate and resolve any issues where targets are not met. Audit Scope 1. Interviewed the relevant officers and obtained the required information and documentation relating to commercial waste uplifts. 2. Prepared a series of tests to meet the detailed audit objectives. Key Audit Assurances 1. An adequate supervisory structure is in place with clearly defined roles and responsibilities. 2. Route lists are prepared and issued to operatives detailing the number of bins to be collected from each commercial property. Key Risks 1. Outstanding debts will continue to rise in the absence of a policy for dealing with the service provision to those customers who do not pay their invoices. 2. Income is not maximised where customers are not issued with invoices or where invoices are incorrect. Overall Audit Opinion Although roles and responsibilities relating to the provision of the commercial waste service are clearly defined and processes are in place in relation to providing this service, issues were identified in relation to the invoicing of customers for the uplift of commercial waste. Furthermore, concerns were identified in relation to the level of outstanding debts for the uplift of commercial waste. Although work has commenced by the Waste Service to determine the information available on clients not paying their invoices, there is no formal policy in place for staff to follow regarding the continued provision of the Page 9 of 146
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Internal Audit Report Environment, Housing & Infrastructure Waste Management (A0028/2024/001) Date: August 2024 service for clients with outstanding debts and this needs to be addressed as soon as possible. For these reasons, assurance within this area was found to be limited. Management Commentary We are currently working on implementing the recommendations. Processes are being amended to ensure invoices are correct. Commercial customers are required to submit Duty of Care documents annually and when these are received the service provided and subscription invoice will be checked to ensure they are accurate. Prior to suspension of the service, a review/reminder process is now in place to ensure these documents are returned by customers if they wish to continue with the service. In relation to the outstanding debt, we are working with our Finance and Resources colleagues to ensure procedures are tightened up to ensure customers pay for the service timeously and if they fail to pay, suspension of service action will be invoked. Page 10 of 146
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___________________________________________________________________ To: Audit, Risk and Scrutiny Board On: 04 November 2024 ___________________________________________________________________ Report by: Chief Auditor ___________________________________________________________________ Heading: Internal Audit and Counter Fraud Progress and Performance for Period to 30 September 2024 ___________________________________________________________________ 1. Summary 1.1 The Internal Audit Annual Plan was approved by the Audit, Risk and Scrutiny Board on 18 March 2024. Internal Audit measures the progress and performance of the team on a regular basis using a range of performance indicators. This report monitors progress from 1 April 2024 to 30 September 2024, in terms of the delivery of the Audit Plan for the year and compares actual performance against targets set by the Director of Finance and Resources. 1.2 In terms of Counter Fraud, no formal performance targets for fraud investigation have been established for the following reasons. A major part of their work involves being the single point of contact (SPOC) for the Department for Work and Pension’s (DWP) Single Fraud Investigation Service and the Service Level Agreement for this work contains time targets for completing this work. The types of fraud referrals received to date are wide ranging and the team’s objective is to concentrate on investigating those referrals considered to contain the greatest fraud risk. They are also involved in promoting fraud awareness and assisting with the implementation of adequate fraud prevention measures within the Council. 1.3 All of the Internal Audit Team and Counter Fraud Team are currently working on a hybrid basis and also undertake home/site visits when the need arises. We also provide advice and support where necessary to council services. Item 2 Page 11 of 146
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1.4 The report details progress against local and national initiatives involving Internal Audit and the Counter Fraud Team from 1 April 2024 to 30 September 2024. ___________________________________________________________________ 2. Recommendations 2.1 Members are invited to note the Internal Audit and Counter Fraud Team progress and performance to 30 September 2024. _________________________________________________________ 3. Background 3.1 The progress and performance of the Internal Audit Team is subject to regular monitoring using a number of performance measures. The Director of Finance and Resources has set annual targets for the team to demonstrate continuous improvement. In terms of the Counter Fraud team, there are time targets in place for responding to requests from the DWP’s Single Fraud Investigation Service. Due to the diverse nature of fraud referrals no formal performance targets have been established and the outcomes from investigations is regularly monitored by management. 3.2 Internal Audit and the Counter Fraud Team support a variety of local and national initiatives through participation in professional practitioner groups and co-ordination of national initiatives such as the National Fraud Initiative. 3.3 This report measures the progress and performance of both the Internal Audit and Counter Fraud Team for the period from 1 April 2024 to 30 September 2024. 4. Internal Audit Team Performance (a) Percentage of audit plan completed as at 30 September 2024 This measures the degree to which the Audit Plan has been completed. Actual 2023/24 Annual Target 2024/25 Audit Plan Completion Target to 30 September 2024 Audit Plan Completion Actual to 30 September 2024 93.2% 90.0% 45% 51.5% Actual performance is ahead of target. Page 12 of 146
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(b) Percentage of assignments complete by target date This measures the degree with which target dates for audit work have been met. Target 2024/25 Actual to 30 September 2024 95.0% 100% Actual performance is ahead of the target set for the year. (c) Percentage of audit assignments completed within time budget This measures how well the time budget for individual assignments has been adhered to. Target 2024/25 Actual to 30 September 2024 95.0% 100% Actual performance is ahead of the target set for the year, although this is likely to reduce over the remainder of the year. (d) Percentage of audit reports issued within 6 weeks of completion of audit field work This measures how quickly draft audit reports are issued after the audit fieldwork has been completed. Target 2024/25 Actual to 30 September 2024 95.0% 100% Actual performance is ahead of the target set for the year, although this is likely to reduce over the remainder of the year. 5. Review of the 2024/25 Internal Audit Plan 5.1 Our 2024/25 Audit Plan is subject to ongoing review in light of any organisational risks arising, and also to determine whether any assignments will have to be amended or cancelled as result of us being unable, for any reason, to undertake the work planned. At this stage we are not recommending any further amendments to the plan. 5.2 However this may change over the second half of the year as the team are currently involved in a number of audit investigations and therefore a substantial amount of the contingency budget is being spent. 5.2 In addition, the team is also carrying a vacancy since the retiral of the Chief Auditor in June and the Assistant Chief Auditor is covering this post. A vacancy factor was built into the Plan. 5.3 Discussions are continuing with the Chief Financial Officers (Section 95 Officers) of Inverclyde Council and West Dunbartonshire Council to consider the resilience risks facing Internal Audit and Counter Fraud Page 13 of 146
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Teams and with the assistance of Renfrewshire Council’s Project Management Team, work is ongoing to explore possible options which would address the resilience issues all three councils are facing. As all three teams work differently, this is taking some time to collate the information required. The potential models identified, highlighting the associated issues, risks and benefits will be considered at a future Finance, Resources and Customer Services Policy Board. 5.4 It should be noted that the delivery of financial savings is not an objective of this exercise, and each Chief Financial Officer is committed to maintaining the current level of resource. 5.5 The Audit Plan progress will be closely monitored over the next period and any changes required to the Internal Audit Plan will be brought to this Board for approval. 6 Counter Fraud Team Progress and Performance 6.1 In line with the Service Level Agreement, the Counter Fraud Team act as the Single Point of Contact (SPOC) to route potential housing benefit fraud referrals to the DWP, liaise with the Council’s Housing Benefit Team and DWP Fraud Officers and retrieve the necessary evidence for the DWP Fraud Officers from the Housing Benefit System. Where a suspicion of fraud arises, the team investigate and report their findings to management. Where appropriate, follow-on action is taken, such as reporting the matter to Police Scotland for further investigation, or directly to the Procurator Fiscal. In addition, they also work jointly with DWP Fraud Officers on criminal fraud investigations which focuses on the investigation and prosecution of the Local Authority administered Council Tax Reduction Scheme and Social Security benefit fraud. In addition to investigation work the team also undertake fraud prevention work. 6.2 During this quarter, we have mainly been working on the various fraud referrals and we are continuing to validate any bank account or remittance contact changes received from the Council’s suppliers and contractors. 6.3 The financial and non-financial results for the period (April 2024 to September 2024) are noted in the table below. Financial Outcomes Period to 30 September 2024 (£) Cash savings directly attributable to preventative counter fraud intervention 2,720 Cash recoveries in progress directly attributable to counter fraud investigations 35,103 Notional savings identified through counter fraud investigation, (e.g. housing tenancy and future council tax) 181,689 Page 14 of 146
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Housing Benefit Savings Attributable to Joint Working by Counter Fraud and DWP Counter Fraud Officers 40,490 Other DWP Benefit or Tax Credit Savings identified through other Counter Fraud work or through joint working with DWP 63,385 Non-Financial Outcomes Period to 30 September 2024 Housing properties recovered 2 Housing applications amended/cancelled 2 Housing Allocation Priority Changed 0 Blue badge misuse warning letters issued 15 Blue Badges Cancelled 2 Supplier/Contractor Checks Undertaken 83 6.4 Our notional savings are based on the methodology prepared by the Cabinet Office. 7. Local and National Initiatives Scottish Local Authorities Chief Internal Auditors Group 7.1 The Local Authorities Chief Internal Auditors Group met in September and presentations were received from Audit Scotland on their best value area of focus - workforce planning and from the Improvement Service on how to utilise the data held on their system for the Financial Sustainability indicators which form part of the Local Government Benchmarking Framework. 7.2 New Global Internal Audit Standards are being introduced from January 2025 and an update was received from a member of the Internal Audit Standards Sub-Group which has been established to help implement these standards. It has now been confirmed that new Public Sector Internal Audit Standards will be issued by CIPFA in draft format for consultation very soon and will be introduced in April 2025 and that no changes to local government working practices will be required until the new standards are formally issued. 7.3 On receipt of the draft Public Sector Internal Audit Standards, a review will be undertaken to assess what amendments are required to our current internal audit processes to enable us to fully conform to the new standards. Scottish Local Authorities Investigation Sub-Group 7.4 The Local Authorities Investigation Sub-Group also met in September and various useful updates from other local authorities was provided regarding the work they are currently undertaking. Page 15 of 146
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National Fraud Initiative 7.5 We are currently preparing for the next National Fraud Initiative. The required communications, notifying staff and the appropriate Renfrewshire residents that their data is about to be submitted to the Cabinet Office as part of the data matching initiative has been undertaken. Data files are now being checked and will be submitted before the submission deadline date. 7.6 A separate report providing details of the outcomes of the last exercise is also being submitted to this Board. Implications of the Report 1. Financial - The Council has in place arrangements to recover the any overpayments identified from the work of the Counter Fraud Team and the National Fraud Initiative. 2. HR & Organisational Development - None 3. Community Planning – Safer and Stronger - effective internal audit is an important element of good corporate governance. 4. Legal - None 5. Property/Assets - None 6. Information Technology - None 7. Equality & Human Rights - None 8. Health & Safety – None 9. Procurement - None 10. Risk - The progress and performance reported relates to the delivery of the risk-based internal audit plan and the mitigation of the risk of fraud and error. 11. Privacy Impact – None 12. COSLA Implications – None 13. Climate Risk – None 14. Children’s Rights - None ________________________________________________________________ Author: Karen Campbell – 07768354651 Page 16 of 146
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___________________________________________________________________ To: Audit, Risk and Scrutiny Board On: 4 November 2024 ___________________________________________________________________ Report by: Chief Auditor ___________________________________________________________________ Heading: Summary of Internal Audit Activity in Partner Organisations July 2024 to September 2024 ___________________________________________________________________ 1. Summary 1.1 Members of the Audit, Risk and Scrutiny Committee expressed an interest in the outcomes of audits undertaken in partner organisations. A proposed revision to the Audit, Risk and Scrutiny Board’s Terms of Reference, to facilitate this, was agreed at Council on 4 May 2024. 1.2 This report provides members with a summary of the internal audit arrangements within each partner body and a summary of the internal audit activity from1 July 2024 to 30 September 2024. 1.3 Renfrewshire Valuation Joint Board – Internal audit services are provided by Renfrewshire Council’s Internal Audit Service. An audit on the non-domestic rates valuation system is currently in progress and will be reported upon to the Renfrewshire Valuation Joint Board once finalised. 1.4 Scotland Excel Joint Committee - Internal audit services are provided by Renfrewshire Council’s Internal Audit Service. An audit has been finalised in relation to contract monitoring (implementation of collaborative procurement) and was reported to the Executive Sub-Committee on 23 August 2024. A summary of this audit engagement is included at appendix 1 of this report. 1.5 Renfrewshire Integration Joint Board - Internal audit services are provided by Renfrewshire Council’s Internal Audit Service. An audit on the processes followed for financial planning has commenced and the fieldwork is currently ongoing. An exercise to ensure that previous internal audit Item 3 Page 17 of 146
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recommendations have been implemented by their due date has also commenced. 1.6 Glasgow City Region City Deal – Internal audit services are provided by Glasgow City Council Internal Audit Services, finalised reports for each completed audit engagement are reported to the Glasgow City Region Cabinet and the reports are shared with member Council’s. During the reporting period, one audit review on the UK Shared Prosperity Fund (SPF) Assurance Framework across Glasgow City Region was completed and has been included at appendix 2. ___________________________________________________________________ 2. Recommendations 2.1 All of these Audit Reports and Summaries have been submitted and considered by the partner organisations’ audit committees. Members are therefore invited to note the content of the audit reports and audit summaries. __________________________________________________________________ Implications of the Report 1. Financial - None 2. HR & Organisational Development - None 3. Community Planning – Safer and Stronger - effective internal audit is an important element of good corporate governance. 4. Legal - None 5. Property/Assets - None 6. Information Technology - None 7. Equality & Human Rights – None 8. Health & Safety – None 9. Procurement - None 10. Risk - The summary reported relates to the delivery of the risk-based internal audit plans for the partner bodies 11. Privacy Impact – None 12. COSLA Implications – None Page 18 of 146
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13. Climate Risk – None 14. Children’s Rights – None. ________________________________________________________________ Author: Karen Campbell, Interim Chief Auditor Page 19 of 146
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Internal Audit Report Scotland Excel Contract Monitoring – Implementing Collaborative Procurement (A0008/2024/005) Date: July 2024 COMMITTEE SUMMARY Audit Objectives The objectives of the audit were to ensure that: 1. All Members views are sought on potential future frameworks. 2. Member engagement in framework development is widely sought and obtained from relevant clients and their views and requirements are taken into consideration as much as possible. 3. Member likely usage is obtained from reliable sources and taken into consideration when frameworks are being established. 4. Frameworks are fair and equitable for all relevant members. 5. Communication and publicity regarding new frameworks is adequate for members. 6. A satisfactory mobilisation strategy has been approved and implemented. 7. Member framework usage is being monitored and addressed as early as possible. 8. Any major issues/problems raised by Members re the utilisation are escalated to the Executive Team at an early stage. 9. Member involvement in the framework management process is maximised throughout the lifespan of the framework. Audit Scope 1. Interviewed relevant officers within Scotland Excel to obtain the required information relating to processes for member visibility of forthcoming frameworks. 2. Prepared a series of tests to meet the above objectives. Three contracts were selected for testing purposes. Key Audit Assurances 1. All members views are sought on potential future frameworks through various methods of communication such as regular Business Reviews by Project & Account Managers. 2. Member engagement in framework development is widely sought and obtained from relevant clients and their views and requirements are taken into consideration as much as possible, by the Commercial User Intelligence Group Meetings held regularly throughout the year. 3. Member likely usage is obtained from reliable sources and taken into consideration when frameworks are being established, by the Contract Steering Group. 4. Regular Business Review meetings ensure that frameworks are fair and equitable for all relevant members. 5. Communication and publicity regarding new frameworks is adequate for members, using Prior Information Notices. 6. For the sample of contracts tested, a satisfactory mobilisation strategy has been approved and implemented. 7. Member framework usage is being monitored and addressed as early as possible, by the User Intelligence Group. 8. Any major issues/problems raised by members re the utilisation are escalated to the Executive Team at an early stage by Category Managers. Page 20 of 146
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Internal Audit Report Scotland Excel Contract Monitoring – Implementing Collaborative Procurement (A0008/2024/005) Date: July 2024 9. Meetings with Project Account managers ensure member involvement in the framework management process is maximised throughout the lifespan of the framework. Key Audit Risks There were no key risks identified during the audit. Overall Audit Opinion The audit identified that satisfactory arrangements are in place for member visibility of forthcoming frameworks. Scotland Excel staff and processes encourage member participation in framework development to maximise usage and deliver benefits for all members. As a result, there were no audit findings identified during this review and the auditor has made a provision of substantial assurance for the areas tested. Management Commentary N/A as no key risks were identified. Page 21 of 146
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Internal Audit | Chief Executive’s Department and Neighbourhoods, Regeneration and Sustainability | Mini Comp B Process 0 Introduction Audit Opinion Main Findings Action Plan Internal Audit Glasgow City Region City Deal Shared Prosperity Fund - Assurance Framework Compliance Final Report August 2024 FS 57095 Page 22 of 146
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Internal Audit | Glasgow City Region City Deal | SPF Assurance Framework Compliance 1 Introduction Audit Opinion Main Findings Action Plan 1 Introduction 1.1 As part of the agreed Internal Audit plan, we have carried out a review of the UK Shared Prosperity Fund (SPF) Assurance Framework compliance arrangements across Glasgow City Region (GCR). 1.2 SPF is administered by the UK Government (UKG) and provides funding for local investment by March 2025, with all areas of the UK receiving an allocation from SPF via a funding formula rather than a competitive process. 1.3 The GCR is the only area in Scotland to adopt a regional approach to SPF, receiving in the region of £73m over the 3- year period between April 2022 and March 2025. While the GCR Programme Management Office (PMO) has overall programme responsibility as the Lead Authority, delivery will take place, in the main, at the Member Authority level, with a small number of projects being administered at a regional level. A SPF GCR Assurance Framework was created to support member authorities in the administration of SPF and outlines the key requirements that should be adopted throughout the course of the 3-year funding period. 1.4 The objective of the audit was to ensure that that member authorities are complying with the requirements outlined in the SPF Assurance Framework and that an adequate audit trail is maintained to support this. The scope of the audit included: • Documented policies and procedures, roles and responsibilities. • Governance and monitoring arrangements. • Reporting activities to track the progress and adherence to the SPF Assurance Framework. • The Change Control process. • Reporting requirements to the GCR PMO and UKG, and • Record keeping arrangements to maintain an audit trail. 1.5 This audit did not include a review of the governance arrangements for individual SPF funded projects at both a regional or member authority level. The review focused on the governance and reporting arrangements between the member authorities and the GCR PMO. Page 23 of 146
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Internal Audit | Glasgow City Region City Deal | SPF Assurance Framework Compliance 2 Introduction Audit Opinion Main Findings Action Plan 2 Audit Opinion 2.1 Based on the audit work carried out, assurance can be taken that the control environment is satisfactory. 3 Main Findings 3.1 We are pleased to report that a number of key controls are in place and generally operating effectively. The SPF Assurance Framework was developed by the PMO, in partnership with UKSPF Lead Officers from each member authority, when the funding initiative was first introduced and rolled out by the UK Government in 2022. Key officers responsible for SPF within both the PMO and member authorities are fully aware of their role in the process and the requirements that are outlined in the Framework. All relevant officers at each member authority were provided with details of the document and this has been made readily available to all appropriate staff. 3.2 We noted that there are appropriate monitoring and reporting activities in place across the GCR and within each member authority. This includes internal reporting within each organisation and more widely across the different GCR Support Groups. Member authorities are also required to submit returns to the PMO on both a quarterly and 6-monthly basis. We were satisfied that these were submitted as required and any discrepancies are appropriately investigated by the PMO. 3.3 Although there has been no requirement for the PMO to complete a formal Change Control process to date, we were satisfied that staff were aware of the thresholds and occasions where a formal change control should be adopted. We also noted that there were appropriate arrangements in place across the Region to ensure that documents relating to SPF were adequate retained for audit purposes and where required these were restricted to relevant staff. 3.4 The audit has been undertaken in accordance with the Public Sector Internal Audit Standards. 3.5 We would like to thank officers involved in this audit for their cooperation and assistance. 3.6 It is recommended that Cabinet notes the content of this report. Page 24 of 146
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1 ___________________________________________________________________ To: Audit, Risk and Scrutiny Board On: 4 November 2024 ___________________________________________________________________ Report by: Interim Chief Auditor ___________________________________________________________________ Heading: Audit Scotland Report – The National Fraud Initiative in Scotland 2024. ___________________________________________________________________ 1. Summary 1.1 Audit Scotland’s report on the National Fraud Initiative (NFI) 2022/23 was published in August 2024 and is attached at Appendix 1. 1.2 The report highlights that Scottish public bodies have recorded outcomes of £21.5 million arising from the 2022/23 exercise. The 2022/23 figure has increased by approximately £6.6 million since the last exercise and the increase has been across most data match areas. The NFI outcome figures include amounts for fraud and error detected as well as an estimate for those future losses that have been prevented. However it is not clear whether underlying levels of fraud have increased since the reports states that there have been improvements in the recording of the results by participating bodies and there has also been a change in the estimation methodologies which has contributed to higher outcomes in some areas. 1.3 Renfrewshire Council’s approach and outcomes for the 2022/23 exercise is attached at Appendix 2. 1.4 Our self-assessment of our arrangements in preparation for the 2024/25 exercise is also included in Appendix 3. ___________________________________________________________________ Item 4 Page 25 of 146
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2 2. Recommendations 2.1 It is recommended that the Audit, Risk and Scrutiny Board: • note the report from Audit Scotland, and • note Renfrewshire Council’s current arrangements, outcomes and self-assessment to support the 2024/2025 NFI exercise. _________________________________________________________ 3. Background 3.1 The NFI aims to detect and prevent fraud and error through a national data matching exercise across public bodies carried out by the Cabinet Office and overseen, in Scotland, by Audit Scotland, with the aim of identifying instances of possible fraud or error. Overpayments that are identified through the initiative allow public bodies to take appropriate action to recover the money. 3.2 The initiative, which is co-ordinated in this council by internal audit, operates biennially with the data downloaded and electronically matched in year one and the results issued, investigated and reported in year two. In relation to this report data was downloaded from our systems in September 2022 and uploaded onto the secure NFI web portal in October 2022, to be matched against other council data or other participant data. 3.3 The Audit Scotland report highlights 3 recommendations for councils to consider in relation to counter fraud activities and their response to the National Fraud Initiative. These are summarised below along with the current arrangements in Renfrewshire Council and any identified improvement actions: 1. Maximise the benefits All participants should ensure that an appropriate level of resource is available to deliver NFI follow-up activities in an efficient and effective manner, in line with local priorities. The Interim Chief Auditor co-ordinates the NFI exercise in Renfrewshire Council. Time is included in the counter fraud work and audit plan and there is regular engagement with services throughout the National Fraud Initiative. If any issues are identified in progressing the matches, these are highlighted to Senior Management for action. Revenues and Benefit services have included NFI match investigation in their work plan. Page 26 of 146
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3 2. Self-appraisal The NFI self-appraisal checklist is used as part of planning for the 2024/25 exercise. The Interim Chief Auditor completes the NFI self-appraisal checklist as part of the planning arrangements for each NFI exercise and the completed checklist for the 2024/25 exercise is attached in Appendix 3 of this Report. Only one improvement action has been identified and that is to include reference to the National Fraud Initiative in the Council’s Code of Corporate Governance. 3. Follow-Up Activity Arrangements Participants should put in place arrangements for monitoring follow-up activity, and where it is necessary seek to understand reasons for low or nil outcomes. Internal Audit is responsible for co-ordinating the exercise and regularly review outcomes. Where any control issues are identified, meetings are held with the appropriate parties to highlight them and determine any action required. Processes followed to investigate matches are also reviewed where low and nil outcomes are recorded. 3.4 The Council has made financial savings of £401,199 as a result of investigative work on the 2022/2023 NFI matches and further future estimated savings of £810,056 have also been noted. Non-financial outcomes relate to 2 housing properties being recovered, 11 housing applications being amended or cancelled and 152 blue badges being cancelled. ___________________________________________________________________ Page 27 of 146
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4 Implications of the Report 1. Financial - The Council has in place arrangements to recover any financial overpayments identified through the National Fraud Initiative. 2. HR & Organisational Development - None 3. Community Planning – Wealthier and fairer – The National Fraud Initiative (NFI) exercises make a significant contribution to the security of public sector finances by confirming that services are provided to the correct people and by eliminating fraud and error. 4. Legal – None 5. Property/Assets - None 6. Information Technology - None 7. Equality & Human Rights - None 8. Health & Safety - None 9. Procurement - None 10. Risk – Priority is given to investigating matches with a higher risk of fraud and error. 11. Privacy Impact – There is a requirement to take best reasonable attempts to notify people of the NFI exercise as part of the preparation for the exercise. This requirement has been complied with. 12. Cosla Policy Position – None 13. Climate Risk – None 14. Children’s Rights - None ___________________________________________________________________ Author: Karen Campbell, Interim Chief Auditor Page 28 of 146
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Prepared by Audit Scotland August 2024 The National Fraud Initiative in Scotland 2024 Page 29 of 146
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2The National Fraud Initiative in Scotland 2024 Contents Key messages 3 Recommendations 4 1. Introduction 5 2. Overall outcomes 7 3. NFI delivery 11 4. Specific match areas 14 5. Pilot exercises and future developments 25 Appendix 26 Accessibility You can find out more and read this report using assistive technology on our website www.audit.scot/accessibility. Audit team The core audit team consisted of: Tim Bridle, under the direction of Cornilius Chikwama. Page 30 of 146
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3Key messages Key messages Key messages Key messages 1 Fraud against the public sector costs the taxpayer money and can undermine both confidence in government and the delivery of public services. The proactive detection and prevention of fraud using the National Fraud Initiative (NFI) remains vitally important to public sector financial management as public bodies continue to recover from Covid-19 and to deal with the impact of the cost-of-living crisis. 2 NFI savings and outcomes have increased from £14.9 million in 2020/21 to £21.5 million in 2022/23, with increases across most data match areas. However, savings from council tax single person discounts are slightly reduced and additional outcomes in some areas are attributable to changes in estimation methodologies. Overall, it is not clear whether underlying levels of fraud have increased since 2020/21. 3 NFI governance and follow-up arrangements remained sound for most participating bodies over the period covered by the 2022/23 exercise. However, when compared to previous exercises, slightly fewer bodies have been assessed by their auditors as having fully satisfactory arrangements, and there remains scope for some bodies to follow up on data matches more effectively. Page 31 of 146
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4Recommendations Recommendations Participating bodies should: • Ensure that an appropriate level of resource is available to deliver NFI follow-up activities in an efficient and effective manner, in line with local priorities. • Use the NFI Self-Appraisal Checklist as part of planning for the 2024/25 exercise. • Put in place arrangements for monitoring follow-up activity, and where it is necessary seek to understand reasons for low or nil outcomes. Page 32 of 146
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5 1. 1. Introduction 1. Introduction The proactive detection and prevention of fraud using the National Fraud Initiative (NFI) remains vitally important to public sector financial management as public bodies continue to recover from the Covid-19 pandemic and to deal with the impact of the cost-of-living crisis. 1. Fraud against the public sector costs the taxpayer and can undermine both confidence in government and the delivery of public services. The National Fraud Initiative (NFI) is a proactive data matching exercise designed to identify and prevent fraud. It remains vitally important during a time of ongoing financial pressure as public bodies continue to recover from the Covid-19 pandemic and to deal with the impact of the cost-of- living crisis. 2. The Public Sector Fraud Authority (PSFA) oversees the NFI across the UK, and Audit Scotland leads the exercise in Scotland, working with a range of Scottish public bodies and their external auditors. The NFI takes place every two years, and this report considers the outcomes from the 2022/23 exercise. Statutory basis for NFI 3. We carry out the NFI under powers introduced by the Criminal Justice and Licensing (Scotland) Act 2010 and incorporated in Part 2A of the Public Finance and Accountability (Scotland) Act 2000. It is important for all parties involved that this exercise is properly controlled, and that data is handled in accordance with the law. The Audit Scotland Code of Data Matching Practice includes a summary of the key legislation and controls governing the NFI data matching exercise. Participating bodies 4. In 2022/23, 110 public sector bodies in Scotland participated in the NFI, submitting data and following up on matches. The Scottish Government also submitted data for another 17 central government bodies who share their systems for payroll and/or creditors. Many councils also submit payroll data for their Arm’s-Length External Organisations (ALEOs). Across the UK there are over 1,100 participating bodies and data matching takes place across them all. Page 33 of 146
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1. Introduction 6 Main data match areas in 2022/23 5. The main data match areas for the 2022/23 NFI exercise were: • Payroll • Creditor payments • Council Tax (Single Person Discounts and Reduction Scheme reliefs) • Pensions • Housing Benefit • Housing Tenancy and waiting lists • Blue Badges (disabled parking) • Adult concessionary bus travel (new in 2022/23 exercise). 6. The 2022/23 NFI exercise matched new data from His Majesty’s Revenue and Customs (HMRC) using powers under the Digital Economy Act (2017). 7. Non-Domestic Rates Small Business Bonus Scheme (NDR SBBS) matching was postponed for the 2022/23 exercise due to the national NDR revaluation exercise in 2023. Results will be reported as part of the 2024/25 exercise. Basis for reported outcomes 8. All monetary outcomes included in this report are on a cash basis, prior year totals have not been adjusted to reflect inflation or changes in estimation methodologies since amounts were originally reported. Details of estimate methodologies used can be found at Appendix. Page 34 of 146
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72. Overall outcomes 2. Overall outcomes Overall outcomes from the NFI have increased from £14.9 million in 2020/21 to £21.5 million in 2022/23. Overall outcomes by type 9. The value of outcomes from the NFI, recorded since our last report, total £21.5 million (up from the £14.9 million in 2022). The cumulative value of outcomes from the NFI in Scotland since participation started in 2006/07 now stands at around £180 million. Exhibit 1 shows NFI outcomes by type for 2022/23 and the previous three exercises. Exhibit 1. NFI outcomes by exercise and type, 2016/17 to 2022/23 Reported outcomes have increased to £21.5 million in 2022/23. Source: Audit Scotland analysis of NFI outcomes 0 10 25 2022/232020/212018/192016/17 £ million £17.8m £15.3m £14.9m £21.5m 3.1 2.7 4.2 6.8 9.2 7.0 6.2 8.9 5.5 5.6 4.5 5.7 Actual savings: overpayments and additional income Forward savings estimates: from overpayments, additional income and prevented fraud Notional outcome estimates: not directly linked to actual overpayments or additional income, eg blue badges, housing tenancy and waiting lists 10. Increased outcomes reported in 2022/23 partly reflect improvement in recording of results as bodies continue to recover from Covid-19. There have also been changes to estimation methodologies which contribute to higher outcomes in some areas (details of methodologies can be found in the Appendix). It is not possible to extrapolate from these figures that underlying levels of fraud have increased. Page 35 of 146
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2. Overall outcomes 8 Outcomes by data match area 11. Most monetary outcomes from the NFI accrue to councils, the Scottish Public Pensions Agency and the Department for Work and Pensions (DWP) in the form of savings arising from council tax, pensions and housing benefits matches. 12. Many participating bodies only submit payroll and creditors datasets for matching, and this limits the monetary outcomes available to them. However, overpayments associated with duplicate creditor payments and payroll matches are not insignificant. NFI outcomes analysed by main data match area, are shown for the last three exercises in Exhibit 2 (page 9). Page 36 of 146
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2. Overall outcomes 9 Exhibit 2. NFI outcomes by area and exercise Most savings arise from Council Tax, Pensions and Housing Benefits matches. Notional outcome estimates Forward savings estimates Overpayments and additional income 0 1 2 3 4 5 6 Care Home Payments Payroll Concessionary Bus Travel Creditors Housing waiting lists Council Tax Reduction Scheme Housing Tenancy Housing Benefit Pensions Non-Domestic Rates Blue Badges Council Tax SPD Care Home Payments Payroll Concessionary Bus Travel Creditors Housing waiting lists Council Tax Reduction Scheme Housing Tenancy Housing Benefit Pensions Non-Domestic Rates Blue Badges Council Tax SPD Care Home Payments Payroll Concessionary Bus Travel Creditors Housing waiting lists Council Tax Reduction Scheme Housing Tenancy Housing Benefit Pensions Non-Domestic Rates Blue Badges Council Tax SPD £ million 2020/21 2018/19 2022/23 Page 37 of 146
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2. Overall outcomes 10 Notes: 1. Non-Domestic Rates Small Business Bonus Scheme data was first submitted for the 2020/21 exercise but did not form part of the 2022/23 exercise due to the revaluation exercise taking place in 2023. 2. Care home payments have not been matched since 2018/19 due to legislative constraints. 3. Adult concessionary bus travel was a pilot exercise in 2020/21 and has been mainstreamed in 2022/23. Source: Audit Scotland analysis of NFI outcomes Wider benefits of NFI 13. The NFI also delivers benefits which are more difficult to quantify. These include its fraud deterrent effect and the financial governance assurance it provides to bodies where no issues are identified (Exhibit 3). Exhibit 3. Non-monetary benefits of NFI Source: Audit Scotland Acts as a deterrent to potential fraudsters Can provide assurance that systems are operating well Can identify where system improvements are required Page 38 of 146
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113. NFI delivery 3. NFI delivery NFI governance and follow-up arrangements remain sound for most participating bodies. However, when compared to previous exercises, appointed auditors assessed slightly fewer bodies as having fully satisfactory arrangements. Auditor assessments 14. NFI governance and follow-up arrangements remain sound for most of the 110 bodies in Scotland that participated in the 2022/23 exercise. However, several bodies have struggled with delivery and there remains some scope for improvement. 15. We asked auditors to assess participating body NFI arrangements, and rate them as Green (satisfactory), Amber (mostly adequate) or Red (unsatisfactory). Auditor returns for 2022/23 included a slightly increased number of amber and red ratings Exhibit 4 (page 12). 16. In most cases amber or red assessments reflect deficiencies with follow-up activity. Participating bodies routinely cited the lack of adequate resources as the main reason for delay or lack of progress with follow-up activity. 17. Our NFI Self-Appraisal Checklist includes requirements for participating bodies to consider Leadership, Commitment and Communication. The checklist also asks NFI key contacts and users to consider potential improvements to the efficiency and effectiveness of follow-up activity. The checklist can be found on our Counter Fraud webpage and has been updated for the 2024/25 exercise. Page 39 of 146
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3. NFI delivery 12 Exhibit 4. Auditor assessments of NFI delivery arrangements Amber and red assessments were up slightly in 2022/23. Source: Audit Scotland analysis of Auditor Returns Percentage Satisfactory Mostly adequate Unsatisfactory 0 10 20 30 40 50 60 70 80 90 100 Colleges 2022/23 Colleges 2020/21 Colleges 2018/19 CG 2022/23 CG 2020/21 CG 2018/19 NHS 2022/23 NHS 2020/21 NHS 2018/19 LG 2022/23 LG 2020/21 LG 2018/19 Page 40 of 146
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3. NFI delivery 13 18. Exhibit 5 shows the main determinants of successful NFI delivery that participating bodies should be focusing on to strengthen their arrangements. Exhibit 5. NFI participation – main determinants of success Successful delivery of NFI requires a clear commitment to a well-thought-out approach that optimises the use of available resources to follow up matches appropriately. Source: Audit Scotland 19. Audit Scotland will continue to work with bodies to support effective and efficient delivery of NFI through its ongoing engagement activities. Knowledge Resources Leadership Effective NFI delivery Page 41 of 146
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144. Specific match areas 4. Specific match areas NFI outcomes have increased in most data match areas in 2022/23. However, savings from council tax single person discounts decreased slightly, and increases in some areas are partly due to changes in estimation methodologies. Payroll 20. The number of payroll and multi-contract working frauds identified as a result of the NFI has increased. There were 12 cases identified in 2022/23. This is the highest number since 2016/17, which is the last exercise for which immigration data was matched. Overpayments and case numbers for the 2022/23 exercise are shown alongside those for the three previous exercises at Exhibit 6. Exhibit 6. Payroll outcomes and case numbers by NFI exercise There has been an increase in the level of identified fraud in 2022/23. Note. Notional outcomes of £5,685 per case are allocated where staff resign or have been dismissed (Appendix). Source: NFI management information 0 80 140 2022/232020/212018/192016/17 0 8 16 2022/232020/212018/192016/17 Number of cases Overpayments £ thousand 13 8 3 12 £20,000 £129,000 £27,000 £100,000 Notional outcomes Page 42 of 146
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4. Specific match areas 15 Creditor payments 21. Participating bodies submit details of payments made to people or organisations supplying them with goods and services. Data is matched by the NFI to identify potential duplicate payments. Bodies identifying duplicate payments often refresh procedures and tighten controls to reduce future risk. 22. In 2022/23 outcomes worth £0.75 million were identified from 146 duplicate payments across 31 bodies. This is broadly in line with previous exercises as shown in Exhibit 7. Exhibit 7. Duplicate creditor payment savings and case numbers by NFI exercise £0.75 million of recoverable duplicate creditor payments was identified in 2022/23. Source: NFI management information 0 0.6 1.2 2022/232020/212018/192016/17 Number of duplicate payments Overpayments £ million 168 147 144 146 £0.6m £1.1m £0.5m £0.75m 130 150 170 2022/232020/212018/192016/17 Page 43 of 146
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4. Specific match areas 16 Adult Concessionary Bus Travel 23. Following a successful pilot exercise in 2020/21, adult concessionary bus travel mortality screening was rolled out to councils in 2023. The National Entitlement Card Project Office, working in partnership with councils, submitted details of all live travel passes for matching. 24. The NFI identified 99,600 travel passes that belonged to holders who had died. Transport Scotland was able to check usage of these passes and identified that 1,075 had been used after the date of death. 25. The full fare value of fraudulent bus trips associated with these passes amounted to £0.31 million, with a cost to Transport Scotland of around £0.18 million, based on the applicable reimbursement rates to bus companies. 26. The cancellation of these passes will prevent future fraudulent use with an estimated value of £0.45 million (based on £420 per travel pass used fraudulently, see Appendix (page 26). The resultant saving to Transport Scotland is estimated at around £0.25 million based on current reimbursement rates.1 Council Tax Single Person Discounts 27. People living on their own, or in some cases with adults who can be ‘disregarded’, are eligible for a 25 per cent single person discount (SPD) on their annual council tax bill. The NFI matches SPD recipients to the electoral register and to other datasets to identify where other adult residents have not been declared on applications, have subsequently turned 18 or have moved in. 28. Councils withdrew £1.8 million worth of SPDs because of the NFI. The additional income, based on a forward projection of annual savings for two years, in line with the Cabinet Office methodology, equates to an additional £2.7 million. These amounts are shown together and alongside savings for the previous three exercises in Exhibit 8 (page 17). 29. Only 19 councils recorded NFI activity in relation to SPDs, as more councils are now making use of third party providers for data matching and follow-up. Seven councils using third-party providers now record no NFI outcomes (an increase of two from the previous exercise). 1 Total outcomes for this area (Exhibit 2) includes a notional amount of £0.91 million relating to the pilot exercise in 2020/21 (based on the Cabinet Office methodology at the time which applied £550 to each travel pass cancelled). Page 44 of 146
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4. Specific match areas 17 Exhibit 8. Council Tax SPD savings and case numbers by NFI exercise Case numbers and savings from single person discounts decreased in 2022/23. Source: NFI management information Thousand 4,846 4,588 3,720 3,419 1.8 2.6 2.7 Case numbers0 3 6 2022/232020/21 2018/19 2016/17 0 3 6 2022/232020/212018/192016/17 £4.4m £4.9m £4.6m £4.5m 3.1 1.8 2.8 1.5 2.9 1.7 2.7 1.8 Forward savings estimate Discounts removed £ million Council Tax Reduction Scheme (CTRS) 30. Council tax reduction is available to low-income households in Scotland. The NFI matches CTRS data to other datasets, such as payroll and pensions, for example, to identify undeclared income. 31. In 2022/23, additional council tax income of £0.92 million was identified because of follow-up on NFI matches (up from £0.65 million in 2020/21). Savings and case numbers are shown alongside those from the previous three NFI exercises in Exhibit 9 (page 18). Page 45 of 146
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4. Specific match areas 18 32. Actual additional income from the removal of council tax reductions has increased, as have forward savings estimates. The forward savings estimate methodology has, however, changed with savings now based on 33 weeks, compared to the 21 weeks previously used. Exhibit 9. Council Tax Reduction Scheme savings and case numbers by NFI exercise Total potential savings from CTRS have increased to £0.92 million in 2022/23. Source: NFI management information 115 280 772 395 Case numbers0 400 800 2022/23 2020/212018/192016/17 0.0 0.5 1.0 2022/232020/212018/192016/17 £0.48m £0.30m £0.65m £0.92m 0.08 0.23 0.09 0.38 0.12 0.53 0.23 0.69 Forward savings estimate Reductions removed £ million 33. Only 18 councils identified savings from CTRS, with most savings arising from matches to pensions (around 40 per cent) and payroll (around 30 per cent), where income had not been declared. Page 46 of 146
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4. Specific match areas 19 Housing Benefits 34. Housing benefits (HB) help people on low incomes pay their rent. HBs in payment continues to decrease as more benefit recipients move on to universal credit. 35. The DWP’s Verify Earnings and Pensions alerts service has also impacted HB savings from NFI as alerts are sent directly to councils for investigation, allowing them to follow up outside the NFI process. We no longer match HB to payroll and pension as part of the NFI. 36. There has, however, been an increase in reported savings in 2022/23 due to the inclusion of late DWP savings from the 2020/21 exercise which was affected by Covid-19. Exhibit 10 shows the HB overpayments and forward savings reported for the current and previous three NFI exercises. Exhibit 10. Housing Benefit savings by NFI exercise 2022/23 includes significant late DWP savings from the 2020/21 exercise. Source: NFI management information 0.0 1.5 3.0 2022/232020/212018/192016/17 £2.1m £2.8m £1.2m £2.2m 2.1 0.7 1.4 0.7 0.3 0.9 0.4 1.8 Forward savings estimate Overpayments £ million 37. HB matches involving suspected fraud are referred to the DWP for investigation and resultant savings are not attributed back to councils. In 2022/23 almost £2 million of savings arose from these referrals. £0.2 million of savings was identified locally by 17 councils, largely from the follow-up of matches to student loans. Page 47 of 146
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4. Specific match areas 20 Exhibit 11. Pensions savings by NFI exercise Follow-up activity and recording of outcomes in 2020/21 was impacted by Covid 19. Source: NFI management information 0 3 6 2022/232020/212018/192016/17 £5.4m £3.2m £1.5m £5.6m 2.8 0.40.7 4.8 0.1 1.4 5.1 0.5 Estimated forward savings Actual overpayments £ million Pensions 38. The NFI is an efficient and effective way for the Scottish Public Pensions Agency (SPPA) and councils that administer pensions to check that they are only paying pensions to people who are alive. 39. The follow-up of matches has led to the identification of actual overpayments of £0.5 million as at 31 March 2024, with projected forward savings amounting to a further £5.1 million. These savings are shown along with those reported for previous exercises in Exhibit 11. 40. Forward savings are estimated based on a potential payment period from the date overpayments are identified until the date the deceased pensioner would have reached the age of 85 (consistent with actuarial assumptions used to value public sector pension schemes). 41. In 2022/23 we have seen improved follow-up of pensions matches. However, not all overpayments identified had been recorded by 31 March 2024. Late savings will be reported as part of the 2024/25 exercise as a result. Page 48 of 146
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4. Specific match areas 21 Exhibit 12. Blue Badges outcomes and case numbers by NFI exercise There have been higher levels of recorded cancellation in 2022/23 than for recent exercises. Source: NFI management information 0.0 2.0 4.0 2022/232020/212018/192016/17 Badges cancelled Notional outcomes £ million Thousand 4,505 3,215 4,616 5,140 £1.8m £2.6m £2.7m £3.3m 0 3 6 2022/232020/212018/192016/17 Blue Badges 42. The Blue Badge scheme allows individuals with mobility problems to park for free at on-street parking meters, in ‘pay and display’ bays, in designated Blue Badge spaces, and on single or double yellow lines in certain circumstances. Badges are sometimes used by unauthorised persons after the badge holder has died. Not only is this an offence under the Disabled Persons’ Parking Badges (Scotland) Act 2014, but it may also result in parking spaces being denied to people who legitimately use the Blue Badge scheme. 43. The NFI matches Blue Badges issued to records of deaths, enabling badges to be cancelled. The number of badges cancelled in 2022/23 has gone up to 5,140, as shown at Exhibit 12. Page 49 of 146
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4. Specific match areas 22 44. The increased number of cancellations, together with a new estimate multiplier, has resulted in a higher notional outcome value. The Cabinet Office estimation methodology now applies £650 per badge cancelled (compared to £575 per badge in 2020/21). Housing Tenancy 45. With reported housing shortages and high levels of homelessness, tenancy fraud is increasingly an issue for councils. Where fraudulent subletting exists, it means that properties are not available to house people who are in most need and this can be costly to councils. 46. The NFI uses council housing tenancy data to identify possible cases where tenants may have sublet their property. It also helps identify cases where the tenant has died, and the property is either empty or has other individuals living in it. 47. As a result of the 2022/23 exercise, councils were able to identify and recover ten properties. A housing association property was also identified and made available for social housing. The numbers of properties recovered along with the notional outcome estimates for the last four exercises are shown at Exhibit 13 (page 23). 48. Notional outcomes of £78,300 are allocated per property recovered (£93,000 in 2020/21). This is based on an average four-year fraudulent tenancy and includes estimated costs of temporary accommodation for genuine applicants; legal costs to recover property; re-let cost; and rent foregone during the void period between tenancies. 49. In addition to recovery of properties, NFI has enabled several councils to update tenancy details where there has been legitimate succession following a bereavement. Page 50 of 146
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4. Specific match areas 23 Exhibit 13. Housing Tenancy outcomes and case numbers by NFI exercise Tenancies recovered as a result of NFI have remained in double figures in 2022/23. Source: NFI management information 0.00 0.50 1.00 2022/232020/212018/192016/17 £ million 2 1 10 11 £0.09m £0.19m £0.93m £0.86m Notional outcomes Tenancies recovered0 6 12 2022/232020/212018/192016/17 Housing Waiting Lists 50. Councils maintain waiting lists for council housing, and in some cases for all social housing in their area. The NFI matches waiting list data to housing tenancy data and other data sets, enabling undisclosed changes in circumstances to be picked up. This enables removal of ineligible applicants from the waiting list, stops inappropriate allocations, and accelerates allocations to people in genuine need of social housing. 51. In 2022/23 we have seen an increase in the number of applicants removed from waiting lists as a result of NFI. Notional outcomes have also increased as shown in Exhibit 14 (page 24). Page 51 of 146
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4. Specific match areas 24 52. Notional outcomes are attributed to applicants removed from the waiting list on the basis that social housing could have been allocated inappropriately. The estimation methodology allocates £4,283 per case removed from the waiting list (an increase from £3,240 per application in 2020/21). Exhibit 14. Housing Waiting List outcomes and case numbers by NFI exercise More applicants have been removed from the waiting list in 2022/23 than in previous exercises. Source: NFI management information 0.0 0.8 1.4 2022/232020/212018/192016/17 £ million 90 230 187 280 £0.7m £0.3m £0.6m £1.2m Notional outcomes Applicants removed from waiting list0 150 300 2022/232020/212018/192016/17 Page 52 of 146
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255. Pilot exercises and future developments 5. Pilot exercises and future developments Social Security Scotland took part in a pilot data-matching exercise which identified limited fraud and error. We are also exploring the possibility of involving wider public sector bodies in the 2024/25 NFI exercise on a voluntary basis. Social Security Scotland – benefits pilot 2022 53. In 2022 a pilot exercise was undertaken with Social Security Scotland (SSS) to identify any instances where claimants received support but were not residing in Scotland, or where claimants appear to have claimed benefits more than once (eg, from more than one Scottish address). The pilot exercise included payments made in the three-month period from April to June 2021. 54. Around 45,000 lines of data relating to benefit payments were submitted for matching, resulting in the identification of 367 claimants who appeared to be residing outwith Scotland. Following review and corroboration of addresses by SSS there were just 17 cases where claimants were not entitled to benefits. Overpaid benefits of £16,450 were identified, a further £20,000 could have been paid out in relation to these claims, over the remaining eligibility periods. 55. Despite the identification of fraud and error, the number and value of cases was not deemed sufficient to justify the inclusion of this match type in the main biennial NFI exercise in 2022/23. The intention is to run another pilot in 2024/25 which may also include Adult Disability Payments for the first time. Inclusion of bodies on a voluntary basis 56. There are potential benefits from expanding the NFI to include more public sector bodies in Scotland. We invited Scottish housing associations and universities to participate in the 2024/25 NFI on a voluntary pilot basis. 57. While no universities have volunteered for participation, we are working with several interested housing associations. At this time, it is unclear how many of those interested will actually participate. Page 53 of 146
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26Appendix Appendix Estimated outcomes methodologies In some cases NFI outcomes include an estimated element for forward savings or for where no monetary value can be recovered The NFI uses the term ‘outcomes’ to refer to the financial value of fraud, error and overpayment that can be attributed to NFI data matching. In some cases NFI outcomes include an estimated element which seeks to capture: • The value of loss from a fraud or error detected because of an NFI match, in instances where no monetary value can be recovered - such as the value of recovering a property from a tenant who has fraudulently obtained that tenancy. We have called these ‘notional outcome estimates’ in our report. • The value of any future losses that may have been incurred without intervention as a result of an NFI match. For example, the value of future overpayments prevented through detecting and stopping a fraudulent or erroneous housing benefit claim. We have called these ‘forward savings’ in our report. Most NFI datasets have a methodology to calculate estimated outcomes. These methodologies account for: • data relevant to the fraud problem, including national published data and data from previous NFI cases • the policy context relative to the fraud problem • any regional variances that may result in the generation of estimate methodologies specific to a region or area • alignment where possible with relevant estimated savings methodologies used in other central government departments. All methodologies are reviewed prior to the start of each new NFI exercise. Any changes are reviewed by the Cabinet Office NFI Governance Board and approved by the Cabinet Office Fraud Prevention Panel. This panel consists of cross government counter fraud experts (including representatives from DWP, HMRC, NHS, MOD, BEIS, DFID, NAO, etc.) who review and challenge, where necessary, methodologies for calculating the estimated value of fraud prevention initiatives across government departments. Page 54 of 146
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Appendix 27 Once approved, these methodologies are built into the NFI web application to enable the estimated outcomes element to be automatically generated. A summary of the outcomes methodology calculations applied to NFI datasets is set out in the following table: Data match Basis of calculation of forward savings and estimated outcomes Council tax single person discount Forward savings – Annual value of the discount cancelled multiplied by two years. Council tax reduction scheme Forward savings – Weekly change in council tax discount multiplied by 33 weeks (increased from 21 weeks in 2020/21). Housing benefit Forward savings – Weekly benefit reduction multiplied by 21 weeks. Pensions Forward savings – Annual pension multiplied by the number of years until the pensioner would have reached the age of 85. Housing Tenancy Notional outcomes – £78,300 per property recovered, based on average four–year fraudulent tenancy. Includes: temporary accommodation for genuine applicants; legal costs to recover property; re–let cost; and rent foregone during the void period between tenancies (reduced from £93,000 in 2020/21). Housing waiting lists Notional outcomes – £4,283 for each case based on the annual estimated cost of housing a family in temporary accommodation, the duration a fraud may continue undetected and the likelihood a waiting list applicant would be provided a property (increased from £3,240 in 2020/21). Blue Badges Notional outcomes – Number of badge holders confirmed as having died multiplied by £650 to reflect lost parking and congestion charge revenue (increased from £575 in 2020/21). Concessionary bus travel Forward savings – Number of bus passes used fraudulently multiplied by £420. Based on average fraudulent use and reflecting two years forward use. Payroll Notional outcomes – £5,685 for each employee dismissed or resigns as a result of NFI matching. (up from £5000 in 2020/21). Page 55 of 146
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The National Fraud Initiative in Scotland 2024 Audit Scotland, 4th Floor, 102 West Port, Edinburgh EH3 9DN Phone: 0131 625 1500 Email: info@audit.scot www.audit.scot ISBN 978 1 915839 46 6 Page 56 of 146
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Appendix 2 National Fraud Initiative 2022/2023 Renfrewshire Council Summary of arrangements and outcomes Page 57 of 146
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1. INTRODUCTION The National Fraud initiative is a biennial data matching exercise run by the UK Cabinet Office and overseen in Scotland by Audit Scotland. It supports the Council’s commitment to protecting public funds and preventing and detecting fraud. Each local authority across the UK alongside other government organisations such as the NHS and Department for Work and Pensions participate under the relevant Public Finance legislation, which in Scotland is the Public Finance and Accountability (Scotland) Act 2000. Information Security Participation in the exercise is communicated across the Council’s social media platforms to inform our customers and staff. All information is shared and stored in line with the Council’s privacy policy. Page 58 of 146
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2. PROCESS All matches generated from the data matching exercise require an outcome. To allow Audit Scotland and the Cabinet Office to report accurately across all organisations involved the outcomes available are prescribed and used by all organisations. Possible outcomes Updates for 2022/24 The Cabinet Office have included 1 new area for investigation – Adult concessionary bus travel (not our responsibility to investigate) and postponed Non-Domestic Small Business Bonus Scheme matching due to the national NDR revaluation exercise in 2023. External Auditor Assessment of Arrangements Our external auditors have stated in their Renfrewshire Council Group Annual Accounts 2023/24 in relation to 2023/24 NFI exercise that :- The most recent NFI exercise was for 2022/23. There has been a good level of follow-up activity at Renfrewshire Council with 100% of Very High Risk matches processed in most areas. As of March 2024, all reports have been closed except for two which the Council is waiting for further information from. The audited body has engaged well with the NFI exercise. The Council had a good level of follow up activity, meaning that most matches have been closed down. In addition, the body has strong governance arrangements in relation to communication and transparency of NFI. No savings identifiedClosed - Already known •These are matches that after investigation it is identified that the information available in the match has already been reported and acted on within the time of the data being uploaded and the match being released. No savings identifiedClosed - No Issue •After investigation the information received from the match has no impact on the benefit or service received. Savings identifiedClosed - Error •Savings are identified however the cause is considered to have been error and not fraud. Savings identifiedClosed - Fraud •A full investigation is carried out and evidence is identified to indicate that a material benefit was gained by the failure of the subject to declare information No savings identfiedClosed - Not selected for investigation •The match details do not offer sufficient evidence to allow for an investigation No savings identifiedClosed - referred to DWP •The match information relates primaily to state benefits that require to be investigated by the DWP. Page 59 of 146
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2. PROCESS All required datasets were exported in September 2022 and submitted to the National Fraud Initiative web portal. The National Fraud Initiative data matching cases were released on the web portal in January 2023. The matches are categorised by the fraud risk area and risk score. The risk score matrix has been designed by the Cabinet Office and is established to assist organisations to prioritise the resources required to carry out the match investigation to those most likely to identify savings and error or fraud. Renfrewshire Council process 2022 All Matches 2022 High Risk 2020 All Matches Housing Benefit claimants 67 51 85 Payroll 103 52 105 Housing Tenants 828 369 316 Blue Badge Parking Permit 524 524 522 Housing Waiting List 79 55 191 Council Tax Reduction Scheme 770 405 1326 Creditors 822 74 2160 Procurement 92 31 66 Business Rates 183 183 127 Business Grants N/A N/A 3 cumulative total 3468 1744 4901 Analysis of Renfrewshire council NFI matches 2022/24 Matches allocated ‘high risk’ status are prioritised for investigation. Blue Badge Parking Permit matches and Creditor matches are passed to the service to assess and any suspected fraud escalated to the Counter Fraud team to pursue. Housing Tenant matches saw the most significant increase in total number of matches from the previous exercise in 2020/21 and this was as a result of new matches to the data supplied by HMRC. Page 60 of 146
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3. RESULTS 2022/23 Fraud and error identified by Renfrewshire Council Staff Fraud Area No. of cases Actual Overpayment Estimated Savings CTRS1 40 £55,711 £13,753 HB2 1 £16,527 £3,925 Housing Tenancy 2 N/A3 £156,600 Waiting List 11 N/A £46,753 Procurement 0 0 N/A Payroll 0 0 N/A4 Blue Badge 152 N/A £98,800 Creditors 0 0 N/A NDR5 16 £104,117 £83,451 CT Discount6 534 £224,843 £406,414 All 756 £401,199 £810,056 Overall outcomes are down slightly from the previous exercise. The main reason for this is that for the matches that the Counter Fraud Staff investigate, a lot of work was undertaken during the previous exercise to investigate and close down a lot of the lower risk matches to prevent them from being listed again in this exercise. We were able to undertake this work as it was during the pandemic and some of our other work could not be undertaken as a result of the restrictions in place. The financial savings in excess of £401,000 are set to be recovered following the Council’s usual debt recovery processes. Our participation in the 2022/23 NFI exercise is estimated to have prevented further financial loss to Renfrewshire Council in excess of £810,000. 1 Council Tax Reduction Scheme 2 Housing Benefit 3 There are no Actual Overpayments recorded for Housing Tenancy, Waiting List and Blue Badge fraud and error cases 4 There are no Estimated Savings recorded for Payroll and Creditors fraud and error cases 5 Non-Domestic Rates / Business Rates 6 Council Tax Discounts Page 61 of 146
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Self-Appraisal for NFI 2024/25 – Appendix 3 Part A: For Those Charged with Governance: Leadership, Commitment and Communication Yes/No/Partly Is Action Required? 1. Are we aware of emerging fraud risks and have we taken appropriate preventative and detective action? Yes - National Anti-Fraud Network and other anti-fraud network alerts are subscribed to and monitored for emerging fraud risks. Attendance at regular SLAIG/SLACIAG meetings provide opportunity for the sharing of best practice across local authorities to improve and develop preventative controls and detective methods. No 2. Are we committed to NFI? Has the council/board, audit committee and senior management expressed support for the exercise and has this been communicated to relevant staff? Yes - Counter Fraud Team work jointly with operational services to investigate matches. Training is provided to operational teams and NFI outcomes reported to the CMT and the Audit, Risk and Scrutiny Board. No 3. Is the NFI an integral part of our corporate policies and strategies for preventing and detecting fraud and error. And do we make reference to NFI in our governance codes and statements? Partly - There is a Counter Fraud Policy in place, and it is incorporated into the Counter Fraud Business Plan. Reference to NFI will be added to Corporate Code of Governance. Yes: Interim Chief Auditor - 31/03/25 4. Does our Key Contact have sufficient authority and time to ensure that NFI is delivered effectively? Yes. No 5. Has the approach to follow up of different NFI match types been clearly set out and reported as part of the bodies NFI planning process? Yes - We review high risk matches in the first instance and then undertake a risk analysis to decide what our approach will be for the remainder of the matches. No Page 62 of 146
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Self-Appraisal for NFI 2024/25 – Appendix 3 6. Are NFI progress and outcomes reported regularly to senior management and elected/board members (eg, the audit committee or equivalent)? Yes - Counter fraud activity outcomes, including NFI results are reported quarterly alongside the outcome and performance report presented to the Audit, Scrutiny and Risk board. Audit Scotland's NFI reports are shared with Senior Management. The overall NFI outcomes and results are reported at the end of the biennial exercise. No 7. Where we have not submitted data or used the matches returned to us (eg, council tax single person discounts), are we satisfied that alternative fraud detection arrangements are in place and that we know how successful they are? Yes - Risk based assessment of matches, high risk matches given priority. We have established regular data matching exercises in regard to Housing Waiting List, Licensing and Council Tax discounts and Reductions. Revenues and Benefits have recently established a Review Team which will carry out checks and reviews aimed at ensuring accuracy in Council Tax discounts and reductions. The effectiveness of data matching exercises is demonstrated in the outcomes and corrections identified; these are reported as part of the quarterly reports to board. No 8. Does internal audit, or equivalent, monitor our approach to NFI and our main outcomes, ensuring that any weaknesses are addressed in relevant cases? Yes - Internal Audit is responsible for co-ordinating the exercise and regularly review outcomes identified. The findings from the NFI are considered as part of Internal Audit annual planning. No 9. Do we review how frauds and errors arose and use this information to improve our internal controls? Yes - This is considered in the annual audit planning. Meetings are held with the appropriate parties where issues are identified to improve internal controls. No 10. Do we need and have access to fraud investigation officers to enable frauds to be followed up fully? Yes - Counter Fraud officers are part of the Internal Audit Team. No 11. Do we publish, as a deterrent, internally and externally the achievements of our fraud investigators (e.g. successful prosecutions)? Yes - Report to members of the Audit, Risk and Scrutiny Board. Other publicity is considered on a case-by-case basis. No Page 63 of 146
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Self-Appraisal for NFI 2024/25 – Appendix 3 Part B: For NFI Key Contacts & Users Leadership, Commitment and Communication Yes/No/Partly Is Action Required? 1. Are we aware of emerging fraud risks and taken appropriate preventative and detective action? Yes - NAFN and other anti-fraud network alerts are subscribed to and monitored for emerging fraud risks. Service departments are made aware of any fraud risks we are alerted to. Attendance at regular SLAIG/SLACIAG meetings provide opportunity for the sharing of best practice across local authorities to improve and develop preventative controls and detective methods. No 2. Are we investing sufficient resources in the NFI exercise? Yes - Time is included in the counter fraud work and audit plan and regular engagement with services through counter fraud team monitoring. Revenues and Benefit services have included NFI match investigation in their work plan. No 3. Do we plan properly for NFI exercises, both before submitting data and prior to matches becoming available? This includes considering the quality of data and being clear about the approach to follow up of different match types. Yes - Full planning process and detailed action plan in place. Resource made available within the Counter Fraud Team to prepare for the upload of data to the NFI portal this includes a quality check of the data prior to upload. No 4. Where NFI outcomes have been low in the past, do we recognise that this may not be the case the next time, that NFI can deter fraud and that there is value in the assurances that we can take from low outcomes? Yes - Considered as part of risk-based assessment and consideration given to the deterrence our involvement has in the NFI exercise on potential fraud. No 5. Do we confirm promptly (using the online facility on the secure website) that we have met the fair processing notice requirements? Yes - Deadline met. No 6. Do we plan to provide all NFI data on time using the secure data file upload facility properly? Yes - Detailed action plan in place to ensure compliance, this has been successfully fulfilled in previous exercises. No Page 64 of 146
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Self-Appraisal for NFI 2024/25 – Appendix 3 Part B: For NFI Key Contacts & Users Effective Follow Up of Matches Yes/No/Partly Is Action Required? 7. Do all departments involved in NFI start the follow up of matches promptly after they become available? Yes - Monitored by Internal Audit and any resource difficulties are discussed with the service and the Director of Finance & Resources. No 8. Do we give priority to following up high-risk matches, those that become quickly out of date and those that could cause reputational damage if a fraud is not stopped quickly? Yes - Risk based assessment of matches. High risk matches are prioritised, consideration is also given to matches that may cause increased hardship if further delay in correction. No 9. Are we investigating the circumstances of matches adequately before reaching a ‘no issue’ outcome, in particular? Yes. No 10. Are we drawing appropriately (in health bodies) on the help and expertise available from NHS Scotland Counter Fraud Service? N/A N/A 11. Are we taking appropriate action in cases where fraud is alleged (whether disciplinary action, penalties/cautions or reporting to the Procurator Fiscal)? Are we recovering funds effectively? Yes - All relevant actions are considered. No 12. Do we deploy resources in proportion to risks, and scale down work on match reports where early work has not found any fraud or error? Yes - Risk based assessment of matches, where high risk matches show no fraud or error low risk matches are not considered for investigation. However, this is reviewed on a report-by-report basis and where there is a potential for hardship or reputational damage consideration is given to deploying resources to investigate low risk matches. No 13. Where the number of high-risk matches is very low, are we adequately considering the medium and low-risk matches before we cease our follow-up work? Yes - We will undertake a small sample of medium and low risk matches to determine if we are likely to get any outcomes. No 14. Overall, are we deploying appropriate resources on managing the NFI exercise? Yes - Any resourcing issues are discussed with the Service and Director of Finance & Resources as appropriate. Counter Fraud resources are committed within the workplan to the NFI exercise. No Page 65 of 146
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Self-Appraisal for NFI 2024/25 – Appendix 3 Part B: For NFI Key Contacts & Users Effective Follow Up of Matches Yes/No/Partly Is Action Required? 15. Are we recording outcomes properly in the secure website and keeping it up to date? Yes - Monitored by Internal Audit No 16. Do staff use the online training modules and guidance on the secure website, and do they consult the Cabinet Office NFI team if they are unsure about how to record outcomes (to be encouraged)? Yes - Training is provided to staff responsible for following up matches, training includes notifying of online training modules and videos available on NFI web application. No 17. If, out of preference, we record some or all outcomes outside the secure website, have we made arrangements to inform Audit Scotland and the Cabinet Office NFI team about these outcomes? Yes - This is included in the Report notes. No Page 66 of 146
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___________________________________________________________________ To: Audit, Risk and Scrutiny Board On: 4 November 2024 ___________________________________________________________________ Report by: Director of Finance and Resources ___________________________________________________________________ Heading: Risk Report, November 2024 ___________________________________________________________________ 1. Summary 1.1 Each year the Board considers and approves the council’s risks. 1.2 This paper sets out the latest position in managing the council’s risks, at the mid- year point. The appendices attached provide details of: • 1: longer-term or imminent strategic risks • 2: longer-term significant corporate risks • 3: service risks • 4: assurance levels for business-as-usual risks ________________________________________________________________________________ 2. Recommendations 2.1 It is recommended that the Board approves the report. _________________________________________________________ 3. Background 3.1 The key areas of risk previously reported to the Audit, Risk & Scrutiny Board in May 2024 were: Strategic Risks: Very High Economy Very High Reducing inequalities High Migration and asylum related impacts High Global environmental sustainability and route to Net Zero High Strategic sustainable planning for people and assets Corporate Risks: Very High Successful Cyber Attack Very High Financial sustainability High Asset management - ongoing High Commercial vehicle & operators license High Financial Stability High Delivery of the Dargavel solution High Organisational learning from Dargavel High Workforce planning, recruitment, and retention High Delivery of homeless duties Moderate Administering elections Moderate National Care Service - governance and financial implications Item 5 Page 67 of 146
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3.2 The strategic and corporate risk profile for the council in terms of its longer-term or imminent risks was as shown in the matrix below: Evaluation: Low Moderate High Very High Total LT or Imm Strategic Risks: 00 00 03 02 05 LT or Imm Corporate Risks: 00 02 07 02 11 3.3 Risks are evaluated using the Council’s adopted risk matrix; this involves multiplying the likelihood of a risk occurring by its potential impact. Risks are then evaluated as either ‘low’ (green), ‘moderate’ (yellow), ‘high’ (amber) or ‘very high’ (red). 3.4 It was noted that all service departments were revisiting their risk profiles on an ongoing basis to ensure good visibility of all risks across services. This work being captured in Appendix 3. 3.5 In recent weeks, the Corporate Risk Management Group has worked with service colleagues and risk owners to ensure risk information is readily available for this mid-year progress report. 3.6 The movement in risk profile since the May risk report to Board is summarised as follows: - Risks added/ NEW Strategic/ Corporate/ Service – nil report - Risks remaining, where scoring has Strategic/ Corporate/ Service – nil report - Risks remaining, where scoring has Strategic – nil report Corporate – nil report Service – RAAC in the learning estate - remedial works have almost completed, and the score is reduced to a low, acceptable risk, and is being removed from this report for local monitoring by Environment, Housing and Infrastructure (EHI) Services until completion. - Risks escalated from service/s to strategic or corporate - Nil report - Risks escalated from 'business as usual’ to strategic or corporate - nil report - Risks removed or de-escalated to service Strategic – nil report Corporate o The two risks relating to Dargavel (both high) have now been removed with any ongoing actions being monitored through business-as-usual activities or service risk registers. For example, future school capacity planning features on the Children’s Service risk register. o Following external review of the council’s fleet operations, the risk (high), relating to the Commercial Vehicle and Operators License has been de- escalated to EHI service. o Administering elections, the risk (moderate) is de-escalated to Finance and Resources service. The next scheduled election is 2026 however election preparedness is ongoing. Service – RAAC, as above. Page 68 of 146
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- Horizon Scanning and other points of note Firstly, in May, we highlighted three potential areas of risk on our radar that we were currently monitoring for possible addition to appropriate risk registers. At this mid-year review, the following updates can be noted. - Increasing public interest around the process of council decision making This had initially been brought to the Corporate Risk Management Group’s attention following a petition for judicial review lodged with the Court of Session regarding Mirin and Milldale services. The petition was subsequently withdrawn. In addition, the recent Accounts Commission report (a follow up to the Section 102 notice), did not draw out any further concerns, and so with this in mind, the risk will not be added to the corporate risk register and will hereafter be removed from this section of the report. - Emerging duties and current uncertainty around implications This was previously debated in relation to examples in scope which included the United Nations Convention on the Rights of the Child (UNCRC), the new equalities duty, and consumer duties. Since the previous risk report the UNCRC legislation has come into place and council papers have required to have UNCRC implications captured. Implementation and monitoring of other duties and their potential implications are still being monitored for risk, by the relevant lead services. - The increasing use of artificial intelligence (AI) In May we had noted that we were seeking to better understand the risks that AI might pose to council operations and reputation. Dis/misinformation and impact on council reputation as a trusted voice amongst stakeholders and communities is where we may be impacted and so this continues to be on our radar at present. In terms of the use of AI within the council, there is very limited use at present. Secondly, there are two specific care related matters we are closely monitoring. - The proposed National Care Service – governance and financial implications. This is, has been, and indeed continues to be recorded as one of our corporate risks. With COSLA’s recent withdrawal of support for the Bill in its present form, the situation is now more uncertain than before. There is no change to the scoring at present, but the shift in context is highlighted here. - Health and Social Care Partnership - financial stability As reported on 13 September to the Renfrewshire Integration Joint Board Audit, Risk and Scrutiny Committee, there is an increasing likelihood that the Integration Joint Board may require to enter financial recovery in the next financial year. This risk is now reflected within the context for the council’s financial sustainability risk and there is close monitoring of the position between senior council officers and colleagues in the HSCP, and the risk of knock on financial and service delivery risks that may arise should the position deteriorate. 3.7 With all of 3.6 in mind, the risk strategic and corporate risk profile is therefore now as follows: Evaluation: Low Moderate High Very High Total LT or Imm Strategic Risks: 00 00 03 02 05 LT or Imm Corporate Risks: 00 01 04 02 07 Page 69 of 146
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3.8 Appendix 1 provides the detail for 05 longer-term or imminent strategic risks. Appendix 2 provides the detail for 07 longer-term or imminent corporate risks. Appendix 3 provides the detail for 20 longer-term or imminent service risks. Appendix 4 provides the assurance levels (to date) for business-as-usual risks. 3.9 The strategic and corporate risks are aligned with the council plan themes that were approved in 2022. Strategic Moderate riskVery high risk Economy Reducing inequalities High risk Migration and asylum related impacts Global environmental sustainability and route to Net Zero Strategic sustainable planning for people and assets Corporate Moderate risk National Care Service Very high risk Successful Cyber Attack Financial sustainability High risk Asset management - ongoing Financial Stability Workforce planning, recruitment and retention Delivery of homeless duties Page 70 of 146
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__________________________________________________________________ Implications of the Report 1. Financial Recurring costs associated with the measures in place for each risk are considered proportionate to the level of risk, and new planned actions are also considered to be cost effective. The financial requirements to support the risks should be met within the budget of each relevant risk owner, nevertheless, any unplanned and unbudgeted cost pressures that arise in relation to any of the risks identified will be subject to review in consultation with the Director of Finance and Resources. 2. HR & Organisational Development – not relevant to report recommendations 3. Community/Council Planning – effective risk management supports the delivery of all community/ council plan outcomes 4. Legal – not relevant to report recommendations 5. Property/Assets – not relevant to report recommendations 6. Information Technology – not relevant to report recommendations 7. Equality & Human Rights – not relevant to report recommendations 8. Health & Safety – not relevant to report recommendations 9. Procurement – not relevant to report recommendations 10. Risk – as per the subject matter of this report 11. Privacy Impact – not relevant to report recommendations 12. Climate Risk – not relevant to report recommendations 13. Children’s Rights – This report does not present a new policy, function, or strategy, nor a substantive change to an existing policy, function or strategy which will have an impact on children’s rights. The report itself is therefore largely neural on children. However, management of certain risks described in the report support a number of the Articles contained within the United Nations Convention on the Rights of the Child (Incorporation) (Scotland) Act 2024. For example, managing the risk relating to ‘Community and Public Safety’ supports Articles: • 19 – protection from violence • 34 – protection from sexual abuse • 35 – protection from sale and trafficking • 36 – protection from exploitation 14. Cosla Policy Position – not relevant to report recommendations _________________________________________________________ Author: Karen Locke, Risk Manager 14/10/2024 Email: riskmanager@renfrewshire.gov.uk Page 71 of 146
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5 | P a g e Appendix 1: Strategic Risks, longer-term or imminent • ECONOMY – building an inclusive, green and resilient economy Context Risk Statement Owned by Current Controls Likelihood Impact Evaluation SRR.24.01.01 Economy Renfrewshire’s economy faces challenges such as: growing the working age population; more closely aligning the Education and skills provision with the needs of local employers; and achieving a strong and inclusive economy. The risk therefore is that significant economic improvement and upskilling of local workforce is difficult to progress until the current landscape improves and our investment programmes are completed Head of Economy and Development Head of Finance and Procurement Programme Director – City Deal & Infrastructure (1) Capital investment such as investment in housing and heritage assets; supporting Scotland’s investment by identifying and developing opportunities such as AMIDS1 and supporting local businesses seeking to export to new markets (2) Developing skills interventions to address the risks of unemployment, in particular those in low-paid employment, and parents. (3) Support for local businesses to bid for council contracts (4) Support for local businesses to become more carbon neutral 05 05 25 V.High Renfrewshire’s economy has well established strengths in transport (including Glasgow Airport), retail (including Braehead), manufacturing (including significant international exports) and construction and major initiatives such as AMIDs are key to future growth. There is a risk that failure to support economic growth will have a negative impact on residents, businesses, and public services. Action Codes Actions Latest Note Assigned To Date Status CESIP22.01.02 Maximise funding for regeneration of Renfrewshire’s places through grant submissions to external sources including UK and Scottish Governments. The Regeneration and Place Team have successfully secured funding through various external sources. Between 21/22 and 25/26 it has been allocated £2.9m from the Place Based Investment Fund for capital regeneration projects. Between 22/23 and 23/24 we have received £1.5m in funding for capital and revenue regeneration spend from the Shared Prosperity fund. The Council has consistently been successful in RCGF funding applications, most recently receiving £800k in funding for the PACE theatre project. Four applications have been submitted this year for the 24/25 allocation. We were invited to Stage 2 for two of these applications, which were duly submitted in November 2024. An application was also submitted this year to the Scottish Governments Vacant and Derelict Land Investment Programme (VDLIP) and again we were successful in progressing to Stage 2, with a further application submitted in November. However, all these applications have subsequently been put on hold by the Scottish Government indefinitely whilst a decision is made on the regeneration grant funding as a whole. However, due to funding reductions to the Scottish Government’s Regeneration funding, it has recently been announced that both the RCGF and VDLIP schemes have been put on hold indefinitely. Head of Economy and Development 31-Mar- 2026 1 Advanced Manufacturing Innovation District Page 72 of 146
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6 | P a g e Funding worth £85k has been secured from SEPA to investigate the potential deculverting and environmental enhancement of the Candren Burn in Ferguslie. The Regeneration team will continue to explore external funding opportunities to help deliver our place shaping agenda. CESDP21 - 01 - 27 Monitor benefits of City Deal Projects, including AMIDS, Clyde Waterfront and Renfrew Riverside and City Region wide employment programmes. Monitoring of benefits reported through the City Region PMO is ongoing. Note: City Region wide employment programmes delivered a number of years ago and no longer monitored. Programme Director - City Deal and Infrastructure 31-Mar- 2025 CESDP21 - 01 - 13 The transformation of Paisley on the back of the Action Plan is advancing at pace. Goals such as creating an international culture and heritage destination and acting as a stimulus for property investment, development and re-use has already been realised. A number of significant regeneration projects have successfully concluded (the Town Hall, the Arts Centre and the new Culture and Learning Hub in the High Street). The restoration of the Museum is also currently progressing. The publication of the Paisley Vision document acts as a further catalyst to inspire future development in and around the town centre. The Town Centre Strategies align with the guidance and principles outlined in NPF4. Chief Economic and Regeneration Manager 31-Mar- 2026 CESIP23 - 01 - 02 Work with the development partner and stakeholders to maximise the potential of AMIDS for Renfrewshire Development partner (Buccleuch) now in place with LLP joint venture company now set up. Work ongoing to secure new opportunities at AMIDS. Investment zone bid has been submitted to City Region. Construction of phase 1 which will deliver the next building on site, is progressing through the design phase. Construction of this phase is due for completion in 2025. Branding exercise underway to develop a core brand for AMIDS. This will see the launch of material and a specific website. Work ongoing with strategic advisory group to develop AMIDS further as well as discussions with key public and government agencies for support. Programme Director, City Deal and Infrastructure 31-Mar- 26 CP.22.02.01 Develop an Investment Proposition for Renfrewshire that is clear on our economic ambitions for place Two reports have been commissioned to analyse Renfrewshire’s Growth Sectors. The first highlighted that there are several opportunities which Renfrewshire needs to capitalise on to support the growth of its economy further. The second report aims to reconcile existing priorities, team capacity and skills engaged in the economic development and regeneration functions of the Chief Executive’s Department, with the future opportunities and challenges outlined in the first report and the Council’s Economic Strategy. This report highlights that there is a requirement to grow and increase visibility of Renfrewshire’s inward investment proposition to drive future economic growth and development. A new web page has been created which signposts the area’s Head of Economy and Development 31-Mar- 25 Page 73 of 146
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7 | P a g e main investment locations. (https://www.renfrewshire.gov.uk/article/13818/Renfrewshire- investment-prospectus) Future works includes looking at developing a dedicated investment page on the Invest Renfrewshire webpage. Moreover, a dedicated website to drive investment at AMIDS is being developed and is hoped to be launched later this year. CP.22.02.07 Develop a Community Wealth Building Plan for Renfrewshire Community Wealth Building featured as a key theme in the 2024 Renfrewshire Economy Conference. A workshop on the principles and strategies of Community Wealth was delivered to council colleagues, senior management and local businesses from all sectors as part of the conference agenda, which was supported by the Procurement Team. The workshop provided the opportunity for engagement, discussion, collaboration and practice sharing across colleagues and organisations. Agreed actions from the workshop will be taken forward to form working groups and to inform the next steps in progressing Community Wealth Building in Renfrewshire. A new Community Wealth Building Co-ordinator role has been created to drive forward community wealth as a key development area for Renfrewshire. The Co-ordinator will progress the council’s role as an anchor organisation through strong internal engagement and alignment of Community Wealth Building aims with council policies, practices and work streams. A key focus for the Co-ordinator will be to progress the development of a Renfrewshire Community Wealth Building Partnership. The partnership will collaborate on building resources, identifying new initiatives and raising awareness and engagement of the principles of Community Wealth Building across all of Renfrewshire’s business, communities and people, creating a strong community of practice. Head of Economy and Development with Head of Finance and Procurement 31-Mar- 25 CESDP21 - 01 - 03 Support and grow supply chain management and knowledge exchange among manufacturing SMEs to supply Scottish / UK businesses and global supply chain A key aim of the recent Growth Sectors report is for the Council to identify opportunities for local supply chain growth and development. For the past 18 months the Economic Development and Procurement teams in the council have been developing and delivering a wide range of new supports to local businesses to encourage them to bid for public sector contracts. This builds on existing work with the Supplier Development Programme and Business Gateway support. The main driver of this is work around the Community Wealth Building agenda and the aim of increasing and sustaining local economic growth and also increasing council, and other public sector spend, in the local area. NMIS has recently been approved a £100k allocation from the Business Challenge Fund to support and bring together manufacturing SMEs for innovation development and new productivity models. The programme commences in April 2024 for 12 months. Head of Economy and Development With Head of Finance and Procurement 31-Mar- 2025 Page 74 of 146
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8 | P a g e • PLACE - working together to enhance wellbeing across communities • FAIR - nurturing bright, happy and healthy futures for all Context Risk Statement Owned by Current Controls Likelihood Impact Evaluation SRR.24.02.02 Reducing inequalities in Renfrewshire If we don’t have a coordinated approach to tackling inequalities across Renfrewshire (including for example, the causes and consequences of poverty), this could jeopardise the effort in reducing both the short-term impacts on households but also have wider long-term consequences on attainment and health for people living on low incomes. Head of Policy & Partnerships (1) Fairer Renfrewshire Programme (2) Attainment Challenge and Pupil Equity Funding (3) Strong partnership working (e.g. Community Planning Partnership (CPP). Advice Partnership, Empowering Communities Forum, Improving Life Chances, CPP Board (4) Community Plan identifies ‘Fair’ priorities with associated actions relating to cost of living crisis, addressing the impact of alcohol and drugs, and a just transition to Net Zero. Social Renewal Plan has been developed through a programme of analysis, research, and engagement. 05 05 25 V.High The Council plays a key role in tackling inequalities and providing the best possible services to our communities, particularly those who are experiencing the poorest outcomes. As well as our focus on health and wellbeing, we are also committed to support vulnerable individuals, groups or communities through early intervention and prevention, responding to poverty, supporting routes to employment as well as dealing with welfare reforms. The pandemic is thought to have exacerbated existing inequalities in terms of for example educational attainment, health, poverty and mental health. There is a significant focus on ensuring that people receive the economic and wellbeing support that is needed, with a real opportunity to work in a different way, and to tackle some of the existing inequalities across communities as we do this. The current cost of living crisis impacts disproportionately on particular groups in society. In the short term, significant focus is on supporting food insecurity and supporting people on low incomes to maximise income and seek advice with income and debt management. Action Codes Actions Latest Note Assigned To Date Status CESIP22.03.01 Develop the new Fairer Renfrewshire programme. The Fairer Renfrewshire Sub-Committee has been meeting since August 22 and a Fairer Renfrewshire Officers Group made up of officers from across services is meeting monthly. Work with partners to develop the Fairer Renfrewshire Programme is ongoing. There are four key emerging themes which are shared across all elements of the programme, and these are: •Improving financial security •Advancing equality of opportunity •Building community capacity and resilience •Listening to lived experience The Fairer Renfrewshire Sub-Committee has been meeting since August 2022 and a Fairer Renfrewshire Officers Group from across services is meeting monthly. In March 2023 existing funds were brought together into a single resource for Fairer Renfrewshire at around £5million, and partners are working together to further develop the programme. There are four key emerging themes which are shared across all elements of the programme, under which key projects are being funded: · Improving financial security · Advancing equality of opportunity · Building community capacity and resilience · Listening to lived experience Strategic Partnerships & Inequalities Manager 31-Mar- 2025 Page 75 of 146
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9 | P a g e The new School Support service is now in place across all Renfrewshire secondary schools. This service, provided by Renfrewshire Citizens Advice Bureau (RCAB), embeds advice workers in schools, and referrals can be received by pupils over 16, parents/carers, and school staff. Advice Works is providing a Family Support service to families with younger children, which can be accessed by telephone or online. Both services provide support to maximise family income and both also receive referrals under the new school meal debt processes, which prioritises supporting families. Winter Connections ran for a 2nd year in Winter 23/24, providing opportunities for communities to come together and take part in free activities and including food. This has contributed to wellbeing over the winter. The Fairer Renfrewshire Panel has provided insight in a number of areas including holiday provision in Renfrewshire, with the Panel contributing to the plans for our ‘Summer of Fun’, both for summer 23 and 24, the Council’s new School Meal Debt processes, digital exclusion employability, especially parental employability. CESIP22.03.02 Develop the Trauma Informed and Responsive Renfrewshire Programme Trauma Road map approved by Leadership Board in February 2024 and will now be progressed and implemented on a partnership basis. Head of Policy & Partnerships 31-Mar- 2024 CESIP22.03.03 Deliver the Stigma/Language Matters project. I Am Me were commissioned to deliver a training resource for Council staff on stigma and its impact, with a specific focus on people who use alcohol and drugs. The I Am Me team have engaged with a group of people with lived experience to develop and test the materials. The materials are in the final stage of review and will be available on the Council's iLearn platform within the next quarter, and work is ongoing with colleagues in HR and Comms to promote the new resources and encourage uptake. Work is underway to launch the resource in Summer 2024. The due date has been revised to 30 September 2024 [Q2 update due 15 October] Head of Policy & Partnerships 30-Sep 2024 * * CESIP22.03.09 Carry out an evaluation of the Tackling Poverty programme and develop a transition plan for mainstreaming this work. Work has been underway with services to review projects and to transition to Fairer Renfrewshire funding arrangements, 24/25 funding proposals to be presented to Leadership Board on 1 May 2024. Strategic Partnerships & Inequalities Manager 30-Sep- 2023 CP.22.01.09 Develop new options for services and partners to work together more closely across localities to provide advice and support to local people and develop community capacity. We are progressing new connected communities approach - considering how we develop our ‘front door’ services for people accessing advice and support; exploring family advice services; and developing options for locality working. Head of Policy & Partnerships 31 Dec 25 Page 76 of 146
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10 | P a g e CESIP23 - 01 - 01 Deliver a participatory budgeting framework for the Council This year £1.2M was allocated by Environment, Housing & Infrastructure through their #Youdecide programme. The project delivery is well underway, and an evaluation report is being finalised. The updated CONSUL site for Renfrewshire is now ready to be put into use. Arrangements are being put in place for the Data Analytics teams to manage the site in the interim while a permanent host is agreed. A range of services have undertaken training in CONSUL to enable potential future PB projects to take place within their services. The planning of the £25k PB project for Johnstone Christmas event is ongoing with a steering group including residents being formed and the group are currently planning the initial engagement work. Strategic Partnerships & Inequalities Manager 31-Mar- 24 CP.22.03.08 Take forward the recommendations of the Alcohol and Drugs Commission The Alcohol and Drug Change Programme is in its final phase and during 2024/25 evaluation work will be undertaken and responsibility for governance and oversight will transition to Renfrewshire Alcohol and Drug Partnership. The Programme Board will continue to meet in 2024 until those arrangements have been finalised. As the funding associated with the Programme will also come to an end, decisions will be required as to the future of projects in receipt of test-of-change funding. Qualitative research has been commissioned to support project leads in gathering information about the impact of their work which can support decision making. This research will also help inform the programme evaluation which will be reported in the autumn. ▪ Several projects have been mainstreamed or completed: o The Alcohol and Substance Awareness Education pack is in use in education establishments across Renfrewshire. o The additional specialist training for First Crisis means that specialist support for people using alcohol or drugs is now part of the core First Crisis service. o The Youth Health and Wellbeing pilot has concluded. o Two research pieces on Hidden Harm and Family Support are complete. o The Alcohol Policy post has ended, and elements will be incorporated into a new ADP post. o Connecting and Caring Renfrewshire is near completion, with only the evaluation element to complete. o Recovery Change Fund has concluded. ▪ Several projects have funding remaining and so continue: o MYLA, supporting people to sustain settled housing. o Safeguarding Vulnerable Young People, creating additional pastoral support for a small number of pupils in a Renfrewshire secondary school. Head of Policy & Partnerships 31-Mar- 25 Page 77 of 146
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11 | P a g e o Peer support work as part of CIRCLE. o HARRT, delivering mobile outreach services for those not currently engaged with other services. o Stigma/Language Matters, a training resource for staff. Specific work on trauma is part of the wider Trauma Informed and Responsive Renfrewshire programme. This action will be closed and the final evaluation work and transition to new governance will be reported as part of the Fairer Renfrewshire programme. CP.22.03.02 Work with partners to support Renfrewshire residents through the cost-of-living crisis Fairer Renfrewshire continues to deliver range of supports with partners to respond to the cost-of-living crisis. This includes Summer Holiday Funding, Winter School Clothing grants, schools advice etc. Strategic Partnerships & Inequalities Manager 31-Dec- 23 CESIP22.03.07 Develop mechanisms for supporting individuals with lived experience of poverty to influence policy in this area Fairer Renfrewshire Lived Experience was established over the past 18 months, supported by the Poverty Alliance and Star project. The Panel has a regular programme of meetings and has engaged with services, partners and elected members on issues identified. Officers will continue to work with Panel and ensure there is a strong link to the wider Fairer Renfrewshire programme. Strategic Partnerships & Inequalities Manager 31-Mar- 24 CESIP23.03.02 Develop the Fair Food Renfrewshire strategy. The Fair Food Renfrewshire Steering Group, which met initially in September 2023 has continued to meet. A baselining exercise was carried out to establish the current position within Renfrewshire regarding three priority areas: Working to reduce, then eradicate food poverty, by promoting a collaborative approach across all communities, ensuring a dignified and fair access to healthy and affordable food for all. Increased access and availability of growing grounds in every town and village within Renfrewshire. Widen access and availability to educational opportunities regarding nutrition and cooking skills, and wider use of "home economics" type classes within education, health, and community settings. The survey will inform the Fair Food Renfrewshire Plan, and Renfrewshire is pursuing membership of Sustainable Food Places. Strategic Partnerships & Inequalities Manager 31-Dec- 24 CESIP23.03.01 Deliver targeted programmes of community-based adult literacy and numeracy, ESOL, digital, personal and social development, and family learning activities in response to identified need and as set out in Renfrewshire’s CLD Strategy 2021-24 (CF) 61 courses and activities delivered across Renfrewshire between Jan-March 24, with the following delivered weekly: • 12 numeracy courses for adult learners and families with Fun With Numbers and Talk, Learn & Do delivered in 2 primary and 6 early years campuses. • 10 New Scots groups working on their languages skills and integration into the community though Beginners ESOL classes and conversation sessions, including Community Development Manager 31-Mar- 26 Page 78 of 146
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12 | P a g e a new Craft, Culture and Conversation group established for older Ukrainian refugees in Gallowhill. • 7 adult literacies sessions for people needing help with reading, writing, spelling or numbers both in-person and online. • 18 groups for learners wanting to build confidence, skills and self-esteem with a range of activities including crafting, sewing, singing, gardening and growing and lively discussion-based sessions including an evening tabletop gaming sessions for autistic adults from the Lived Experience group. • 10 digital learning groups including Get Safe Online, Digital Beginners and Digital Life Skills supporting people access technology. • 4family Play and Learn events were held in February on school in-service days for parents and younger children to have fun together with games and creative activities in Southend Action Centre, Bargarran CLD Centre and Glenburn Learning Centre. CESIP23.03.03 Continue to deliver new approaches to Building Communities and identify further new opportunities for locality area-based support which builds community capacity. “Take the Lead” was launched in May 2023 to promote responsible dog walking behaviours, primarily to reduce instances of dog fouling within communities. Dog owners who sign the Pledge agree to adhere to good practices such as picking up after their dog. Signatories receive a free lead, mobile dog fouling dispenser, (bags included) and bandana promoting the Campaign. The Green Spaces, Play Parks and Villages Investment Fund has supported 104 community projects since its launch in 2018. In 2023, 16 projects have been supported including gala days, community gardening projects and community murals. Feedback from communities demonstrates the Team’s support is appreciated and the funds bring neighbourhoods together, as well as deliver physical improvements. Community Development Manager 31-Mar- 26 Page 79 of 146
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13 | P a g e Context Risk Statement Owned by Current Controls Likelihood Impact Evaluation SRR.24.02.03 Migration and asylum related service pressures The pace at which asylum dispersal and refugee resettlement has taken place in Renfrewshire since 2022 has been significant, and beyond anything previously experienced. Partnership governance structures have been established to enable partners to share information and to identify and respond to issues as these emerge. In the short term, these are anticipated to be in relation to potential pressure on local education, health and social care services. There are significant pressure on, homelessness and housing services, given the tightness of the current housing market locally and on children’s social work due to availability of foster care and residential provision. Head of Child Care & Criminal Justice Head of Policy and Partnerships Head of Housing Services (1) The Migration and Resettlement Strategic Group meets regularly to review and discuss developments across all migration and resettlement programmes. This group is comprised of senior officers from across appropriate council services. (2) Asylum Dispersal meetings are held once every two weeks with senior council officers and representatives from the UK Government Home Office and their agent Mears. (3) Liaison Meetings with Migrant Help are held approximately once every six weeks with senior council officers and other partner organisations such as Police Scotland and HSCP. (4) The Renfrewshire Community Protection Chief Officer Group receives regular updates on migration and asylum issues and any emerging issues. (5) The Renfrewshire Community Protection Member Officer Group receives regular updates on migration and asylum issues and any emerging issues. (6) Updates are provided, as required, to the Leadership Board of the council. 04 04 16 High Migration/ Ukraine/ Asylum programmes - this is an area which is developing and could be a potential major issue moving forward. The impact of the conflict in Ukraine is reflected within the Financial Sustainability Risk, but only in relation to pricing volatility and global supply issues. The risk here is wider ranging and includes: - Ukrainian Displaced Persons - Home Office Asylum dispersal programme – use of hotel accommodation in Renfrewshire - – increase in volume and speed of decision making - Unaccompanied Asylum-Seeking Children – new requirement from UK Government for Renfrewshire to provide for children and young people under the National Transfer Scheme - Syrian/ Afghan resettlement programme - Support to ensure effective resettlement to New Scots Action Codes Actions Assigned To Date Status Ongoing Monitoring Page 80 of 146
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14 | P a g e • GREEN – leading Renfrewshire to Net Zero Context Risk Statement Owned by Current Controls Likelihood Impact Evaluation SRR.24.03.04 Global environmental sustainability and route to Net Zero (Renamed from Climate, Sustainability risk) A key risk to the Council is that it may not achieve its target to become net zero by 2030 in both its own operational emissions and Renfrewshire’s area-wide emissions. Decarbonising our domestic and non-domestic properties and fleet alone will require significant capital investment. In terms of reducing Renfrewshire’s area-wide emissions there are challenges around influencing behavioural changes, and a risk that others do not contribute towards the 2030 target. The climate emergency also brings a risk to the Council in terms of increased frequency of severe weather events may lead to more instances of damage to Council infrastructure and property, interruptions to service delivery and increased demands on services, often with little notice. There is risk to life, transport disruption and pollution to the local environment, as well as impact adversely on the local economy if businesses are unable to operate. The Council has a requirement to provide immediate response and manage the adverse effects of more frequent and severe weather emergency situations, including support to local communities and businesses. Head of Climate, Public Protection and Roads (1) Renfrewshire’s Plan for Net Zero has specific objectives to reduce emissions, and these are included in other key documents such as the Council Plan (2) Governance through the Planning & Climate Change Policy Board (3) Development of Costed Delivery Plans and a Climate Delivery Action Plan. (4) Sustainable Communities Fund – to support local people to develop sustainable projects that will promote or improve community collaboration, health and wellbeing, local spaces, economic development, biodiversity and the environment. (5) Use of an emissions modelling tool to quantify the impact of actions, inform future targets and present emissions data. (6) A Project and Carbon Footprint Register 04 04 16 High Climate change is expected to continue and worsen in the future if no action is taken, with increases to mean global temperatures, sea level rises and the increasing frequency and severity of weather events such as floods, heatwaves, droughts and storms. More frequent and intense heavy rainfall events increase the risk of soil erosion and flooding. Severe weather is already affecting public services across Scotland, with operational, reputational, financial and legal consequences. There is also an ongoing impact of severe winter weather including snowfall and freezing temperatures which impact service delivery and the integrity of our roads open space and buildings infrastructure. This shift in weather patterns caused by climate change is also affecting biodiversity across Scotland. Renfrewshire Council declared a Climate Emergency in 2019 and approved the target to work towards being net zero, for both Council estate emissions and area – wide emissions by 2030. In 2022 the Council approved RenZero, the first stage of Renfrewshire’s Plan for Net Zero. This Plan sets out the strategic framework required to work towards our climate change targets. The Planning and Climate Change Policy Board oversee this work. Actions include: leading by example by decarbonising our estate and fleet, publishing our Local Heat and Energy Efficiency Strategy and Delivery Plan, maximising the carbon absorption potential of our natural environment and supporting communities to become more resilient to the impact of extreme weather events. Action Codes New Actions Assigned To Date Status SRR.24.03.04a Continue to report transparently on our emissions to ensure that Renfrewshire’s emissions baseline is clearly understood. Head of Climate, Public Protection and Roads 31-Mar- 25 Page 81 of 146
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15 | P a g e SRR.24.03.04b Develop the Local Heat and Energy Efficiency Strategy Delivery Plan. Head of Climate, Public Protection and Roads 31-Mar- 25 SRR.24.03.04c Identify opportunities for Partnership Delivery Models for clean energy projects such as solar and battery storage Head of Climate, Public Protection and Roads 31-Mar- 25 SRR.24.03.04d Prioritise actions in relation to the biggest emissions sources, where we have the most influence, through project pathfinder approaches for decarbonisation of domestic and non-domestic properties and vehicles to bring scale and pace to emissions reduction. Head of Climate, Public Protection and Roads 31-Mar- 25 SRR.24.03.04e Continue to work with stakeholders to articulate the potential costs and skills required to reach our net zero target. Head of Climate, Public Protection and Roads 31-Mar- 25 SRR.24.03.04f Continue to develop our adaptation measures, as we are aware that mitigation alone will not protect communities from the impact of climate change. Head of Climate, Public Protection and Roads 31-Mar- 25 SRR.24.03.04g Develop a Zero Waste Strategy to minimise waste generation and encourage reuse and recycling to support a more sustainable and circular economy. Head of Climate, Public Protection and Roads 31-Mar- 25 SRR.24.03.04h Explore opportunities for expansion of carbon sinks and other carbon capture technologies. Head of Climate, Public Protection and Roads 31-Mar- 25 SRR.24.03.04i Explore the options around developing a carbon budget for the Council. Head of Climate, Public Protection and Roads 31-Mar- 25 SRR.24.03.04j Continue to work with communities to ensure a holistic approach to tacking climate change is taken and to ensure no community is left behind. Head of Climate, Public Protection and Roads 31-Mar- 25 Forward action linked to Net Zero plan: Climate change action to make Renfrewshire net zero - Renfrewshire Website Page 82 of 146
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16 | P a g e Context Risk Statement Owned by Current Controls Likelihood Impact Evaluation SRR.24.03.05 Strategic sustainable planning for people and assets There is a risk that decisions could be made in the short term, for example to address financial pressures, which may then impact adversely on sustainability goals for the longer term impacting on our communities and organisation. CMT (1) Learning Estate Programme Board established (2) Implementation of the Corporate Asset Management Strategy ensures that property assets are managed effectively and efficiently through the provision of relevant management and performance information (3) The Energy Management Team: ensure energy management initiatives are aligned to the capital investment programme and corporate asset strategy to optimise use of property estate and reduce overall running costs and energy consumption levels. Promote reductions in energy usage and advise employees and residents about energy efficiency (4) Through the Procurement Unit, sustainability and community benefits are considered in the development of all contract strategies, with a Sustainable Procurement Strategy approved in November 2023. 04 04 16 High - Deliver sustainable person-centred public services (the Verity Agreement) and an engaged sustainable workforce - Ensure infrastructure future-proofing, with investment in solar and wind farms, electric charging networks and public transport, showing that taking the right risks right now, can transform communities - For capital projects, ensure new assets are fit for purpose for the future and have sustainable maintenance and repairs strategies - Strategic decision making regarding the estate, including the condition and sufficiency of the learning estate Action Codes Linked Actions Latest Note Assigned Date Status Previous actions in relation to the learning estate/ school capacity planning are now reflected in Children’s Services risk register Further action TBC Page 83 of 146
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17 | P a g e Appendix 2: Corporate Risks, longer-term or imminent • LIVING our VALUES – making a difference together Context Risk Statement Owned by Current Controls Likelihood Impact Evaluation CRR24.04.06 Financial Sustainability If significant cost pressures are not successfully planned for and managed effectively over the medium to longer term, this could jeopardise the financial sustainability of the council and result in a significant impact on availability and quality of front- line services and capital investment resources. Decisions will then be required on the continuity or scope of some services currently offered. Director of Finance and Resources; and Head of Finance and Procurement (1) Revised medium- to long-term Financial Outlook reassessed the various risks to the Council’s short, medium- and longer-term financial sustainability. Refreshed report to Council on 26 September 2024 outlined the immediate financial concerns and plans to address these, including, financial sustainability workstreams, and managed use of reserve balances; however, as the position continues to develop and evolve, close monitoring will be required to ensure that the Council manages costs in the short term and fully appreciates the longer term consequences of actions taken to address short-term risks. Committee reports of this nature cover a wide range of current and future financial and economic factors e.g., Strategic Economic and National Policy Context, Cost Pressures, Pressures on Income and Mitigation Strategies to deal with such uncertainties. (2) A well-developed and embedded budget planning, budget setting and budgetary control system is in place throughout the organisation, and this informs members and officers regarding financial performance and stability. This facilitates robust and transparent decision making and incorporates an escalation process with regards budget management issues which may arise. The Council agreed the 2024/25 budget on 29 February 2024. (3) In conjunction with the medium to longer term financial outlook and the Council’s ongoing financial sustainability workstreams, Renfrewshire Council has been proactive in planning for the future by identifying and agreeing a series of directorate-led savings targets over the medium term (2025/26 to 2027/28). It remains the case that savings will continue to require be generated at scale in order to ensure the ongoing financial sustainability of the Council. (4) There is close financial monitoring of the agreed savings to ensure that they are delivered within the agreed timescales, or where this is not possible, to understand and reschedule planned delivery to achieve the associated objectives. Monitoring is undertaken via a combination of financial and operational measures, actions and related update reports. (5) Regular updates and bespoke reports are provided to CMT and the Council with regards the national fiscal position, likely developments 05 05 25 V.High Financial recovery from global events - Potential reduced income from NDR/CT over the medium term as full economic implications of the cost-of-living crisis, in particular energy cost inflation, continue to impact local businesses and communities - Volatility in the global supply chains leading to shortage of labour and materials following Brexit and the outbreak of the Ukraine war Best value report - Recommendation in Best Value report to prioritise how services need to be provided in future to be funded from within available resources. Cost and Income pressures - Future grant settlements and the level of funding available. - Implications of national economic policy choices to protect certain services from real-terms reductions in funding such as the Police and NHS - Local Government pay settlements, and non-payroll inflation - Demographics and demand pressures, such as an ageing population with increased associated service demands, and Page 84 of 146
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18 | P a g e increases in demand for children’s social care - HSCP financial situation and real risk of entering financial recovery in 2024/25 - Implications of welfare policies and poverty levels, exacerbated by cost- of-living crisis. - Reductions in income from fee- generating services such as car parking; implications of the national economic recovery and associated risks/uncertainty in economic factors e.g., interest rates and inflation. - Implications of third party provider financial stability, such as childcare providers in current economic climate - Liability for predecessor organisations, in light of the removal of the limitation period for historic child abuse claims and the impact on the council through close liaison with national groups e.g., CIPFA DoFs, COSLA and the Scottish Government. This liaison remains critical in ensuring the Council is aware of potential financial developments and is in a position to influence these. (6) The CMT now has a regular formal focus on financial sustainability, with one meeting in four being a Financial Sustainability and Transformation Board. These spotlight director-led savings and any associated policy changes or risks for discussion. (7) Managing the level and use of reserves has been a key tool in addressing the costs of the pandemic, therefore the planned use of reserves in the medium term, and the Council’s Capital Investment and Treasury Management Strategy, are key to ensuring ongoing financial sustainability. (8) Reports and publications from Audit Scotland in relation to the Local Government financial outlook, financial planning and related developments and improvements are supplemented with a Renfrewshire context report, with both reports being submitted to the Council's Audit Risk and Scrutiny Board. (9) Energy consumption data and condition surveys are used to identify priority areas for investment in the Council’s estate, support informed investment decisions and formulate the Council’s Capital and Revenue budgets. (10) Regular review of HSCP financial position along with HSCP colleagues Action Codes Linked Actions Latest Note Assigned To Due Status CRR22.05.05a Strategic Property Review and new ways of working / Review of local policy positions Work on all of the financial sustainability workstreams is being progressed with updates regularly to Council. Agreed budget changes will then be incorporated into the General Fund base budget in future years to capture the recurring savings. [Some due dates extended from original to 2025 as certain workstream targets were phased across financial years] Director of Environment, Housing and Infrastructure 31-Mar- 2025 CRR22.05.05b Charging, fees and commercialisation / review of Council risk Director of Finance and Resources 31-Mar- 2025 CRR22.05.05c Strategic review of procurement Head of Finance and Procurement 31-Mar- 2023 CRR22.05.05d Connected Communities Chief Executive (Head of Policy and Partnerships) 31-Mar- 2025 CRR22.05.05e Digital Strategy Director of Finance and Resources 31-Mar- 2025 CRR22.05.05f Council Tax and Tax Policy Director of Finance and Resources 31-Mar- 2023 Page 85 of 146
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19 | P a g e Context Risk Statement Owned by Current Controls Likelihood Impact Evaluation CRR24.04.07 Successful Cyber Attack Regardless of the Council’s technical preparedness for a cyber attack, the threat remains acute and present, as evidenced by successful attacks on partner bodies, with the risk of significant impact on council operations. CMT For security reasons, technical security controls are not published in the public domain. 04 05 20 V.High Context: The risk has been updated from cyber attack to risk of a successful cyber attack as more and more this risk comes closer to home, despite the sophisticated technical security protocols and cyber architecture in place, and for those organisations who have been impacted by successful attacks, we see that the effects are devastating. No matter what technology is deployed, the risk is materially impacted by individual employee behaviours – i.e. learning how to recognise a cyber attack and keeping that knowledge up to date by reading cyber updates and doing mandatory cyber training, being alert to phishing attacks and understanding the need for rapid escalation should an error inadvertently be made and criticality of urgently reporting when they have reacted to a phishing email and explaining all actions taken. Action Codes Linked Actions Latest Note Assigned Due Date Status As agreed by the Corporate Management Team Page 86 of 146
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20 | P a g e Context Risk Statement Owned by Current Controls Likelihood Impact Evaluation CRR24.04.08 Financial Stability If significant short-term costs and income losses are not closely monitored and understood, this could destabilise the finances of the Council to an extent beyond the financial resilience of the Council, resulting in a need for immediate cost control measures, or short-term savings which have an immediate impact on service delivery. Head of Finance and Procurement (1) Revenue budget monitoring reports to Policy Boards focus on the forecast year-end outturn position rather than the historic periodic position, so that significant variances are reported early, and any mitigating steps can be taken. This is already highlighting severe price pressures (such as contractual inflation) across different services. The impact of pay inflation is also highlighted through this reporting mechanism. (2) Review of Financial Sustainability workstreams following approval of the 2024/25 Revenue Budget to ensure targets remain achievable. (3) Clear analysis of the Council’s reserves position and potential for reprioritisation or redirection; including the development of plans to rebuild financial resilience of the Council in the medium term. (4) Ongoing discussion with directors to understand the financial consequences of the current economic climate for each service and how these will be managed. (5) Review of capital plan and ongoing projects to ensure clear understanding of phasing of potential spend. 03 05 15 High Context: Imminent shorter- term risk for financial stability, recognising the immediate financial situation of the Council (note: the medium to longer-term financial position is captured under financial ‘sustainability’) Action Codes Linked Actions Latest Note Assigned Due Date Status Ongoing monitoring CRR24.04.09 – Removed: Commercial vehicle and operator licence compliance Page 87 of 146
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21 | P a g e Context Risk Statement Owned by Current Controls Likelihood Impact Evaluation CRR24.04.10 Asset Management - Ongoing Effective governance and management of the council’s property assets is essential, otherwise there is a significant risk of harm, financial loss, service disruption, non- compliances, fines, rising energy costs and inability to recover losses via insurance proceeds Director of Environment , Housing & Infra- structure. Head of Economy & Developmen t Services Corporately: Key responsibilities with regards to the Estate span 2 specific service departments, but they come together through a CAMIS Development Group (Corporate Asset Management Information System) which is taking forward a workplan to more effectively consolidate and oversee asset management risk Heads of Service: Effective asset management in practice on the frontline is included within the new Risk Assurance model which went live on 1 April 2023. All UFAS related works should be completed by March 2025. Responsible person inventory currently being updated for all properties. 03 05 15 High Context: GOVERNANCE – roles and responsibilities - Estates (Leases – by and from the council, and on behalf of HSCP) - Facilities management (security, housekeeping, statutory duties/ inspection, maintenance, repair, building fire risk assessment) - Property services (capital works, and CAMIS development) - All services (inspection inventories and response, people elements of fire risk assessment) OTHER MATTERS IN SCOPE - Fluorescent Lights – requiring LED replacement. We continue to work through this and spot replacements will be on a like for like basis, however, larger complete renewal is being considered for Renfrewshire House. - Action in relation to Unwanted Fire Alarm Signalling and upgrade costs. Ongoing action to replace signalling equipment across the estate including changes to any activations/protocols to ensure this is being managed appropriately (responsible of duty holder on site) Codes Linked Actions Latest Note Assigned Due Status CRR22. 05.10d Undertake gap analysis to identify activities that take place outside of the CAMIS environment and consider if these can be brought into CAMIS by way of system development Due to competing demands, development work on CAMIS has moved to virtual environment and slower than initially planned. Work still being undertaken to assess what sits outside CAMIS and what can be brought in. Discussions with other Local Authorities that use CAMIS to see what can be added with Health and Safety module being reviewed. Due date therefore amended to June 2024, 2025. CAMIS Developmen t Group 30-Jun- 2025 CRR22. 05.10e Explore data and status monitoring Whilst CAMIS is noted to be a good repository for data, development work is required to improve the data and how it can be easily accessed. Due to resource requirements elsewhere in the Council, this has been delayed. However, conversations continue virtually to assess what can be done to improve CAMIS for users to ensure robust, up to date data is stored within the application. Due date therefore amended to June 2024, 2025. Engagement continues with Concerto and recent developments. Short life working group currently discussing the property “Responsible Person” to ensure known across the entire portfolio. CAMIS Developmen t Group 30-Jun- 2025 CRR24.04.11 – Removed: Delivery of the Dargavel solution CRR24.04.12 – Removed Organisational learning from Dargavel investigation Page 88 of 146
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22 | P a g e Context Risk Statement Owned by Current Controls Likelihood Impact Evaluation CRR24.04.13 Workforce planning, recruitment and retention There is a national shortage in the UK labour market for certain trades and professional services. For Renfrewshire Council that is impacting on certain specialist recruitment campaigns. This combined with diminution of salaries, the reality is that there is a risk the council may lose key personnel, it may be very difficult to recruit suitably qualified and skilled officers for compliance, advisory, investigative and assurance work, with significant impact on statutory responsibilities and slippage in professional activity. Director of Finance & Resources (1) Data analytics to look at areas of risk, trends both recruitment and attrition. (2) Ensuring we hire the right people in the first place by having solid recruitment methods (3) Offering workplace flexibility which can help enhance work life balance, and burnout (4) Creating opportunities for development (5) Partnering with employability, community, and further/higher education programmes to support the Council as an employer of choice 04 04 16 High Workforce planning risk is captured by our model for business-as-usual risk, however over recent months it has been clear that a live issue is emerging in relation to recruitment and retention challenges, particularly for various trades and professional services. Particular pressure points at April 2024: • Soft FM and building services • Hard FM and property services • Legal and Registrars • Social services • Others, as being identified/ confirmed Action Codes Actions Latest Note Assigned To Date Status CRR23.04.13a Agreed to introduce a working group focussed on workforce planning, the purpose of this is to look at new and innovation ways to support the recruitment, retention and upskilling of the Councils workforce. Workforce planning group now formed and an initial meeting held, further meeting dates have been scheduled. Work streams have been identified. Head of People and OD 31-Oct- 2023 CRR23.04.13b Review our recruitment training for managers with a focus on supporting onboarding, induction, and development support. Training has been reviewed and updated in line with the new policy provisions. Induction processes have been reviewed and updated Head of People and OD 31-Aug- 2024 CRR23.04.13c Develop an Equality, Diversity and Inclusion strategy, this aim of this is to enable colleagues to have equity of opportunity within the council during the whole employee lifecycle Complete, EDI plan was approved at the FARS board in February 2024. Head of People and OD 31-Dec- 2023 CRR23.04.13d Introduce a programme that enables our colleagues voice and provides platform for recognition Partially complete within some council services, work continues to drive this across the organisation. Development of employee recognition is in the early stages. [Date amended 31/12/23 to 31/12/24] Head of People and OD 31-Dec- 2024 CRR23.04.13e Continue the roll out of our Health & Wellbeing strategy, ensuring colleagues can have the best experience at work The H&WB plan was approved at the FARS board in February 2024. There is ongoing work underway to drive the 4 themes identified within the plan and target specific work groups. We have trained more mental health first aiders to support the workforce. Head of People and OD 31-Dec- 2024 Page 89 of 146
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23 | P a g e Context Risk Statement Owned by Current Controls Likelihood Impact Evaluation CRR24.04.14 Delivering homeless duties It is becoming more difficult to fulfil our statutory duties for providing accommodation so breaches may occur with an increase in rough-sleeping and reputational harm. Director of Environment, Housing & Infrastructure (1) Monitored at weekly Housing SMT meetings with Head of Service and senior housing managers (2) Reports to Communities and Housing Policy Board (latest May 2024) (3) The Council’s stock of furnished properties being used to provide temporary accommodation for those who have nowhere to stay has been increased on a stepped basis to 276 (4) Additional staffing resources have been appointed within Homeless Services, with 3 x Accommodation Officer and 2 x Housing Options Adviser posts now filled on a temporary basis to support the Councils response to the increase in homelessness. Also, extension of 2 temporary posts to improve access to support, housing options advice and advocacy for tenants in the private rented sector (5) Two additional Housing Support Officer posts have now been created and filled on a temporary basis to help ensure the legal duty to assess the support needs of those who are homeless and ensure these needs are met can be complied with (6) Attendance at regular multi-agency meetings regarding utilisation of temporary hotel accommodation 04 04 16 High We are at risk of being unable to provide temporary/ settled accommodation for the increased number of homeless applicants, Ukraine and Afghan resettlement programmes, and those asylum seekers living in Renfrewshire receiving positive decisions. Action Codes Actions Assigned To Date Status CRR24.04.14a In response to the increase in the level of homelessness over the last two to three years, The Council has increased its target to provide 55% of general lets to homeless applicants in 2024/25 and this was approved by the Policy Board in March 2024. Head of Housing Services 31/03/2025 CRR24.04.14b Deliver the key initiatives detailed in Renfrewshire’s Rapid Rehousing Transition Plan, including, the provision of adequate temporary accommodation, increasing the number of lets to homeless in order to meet needs, provide assistance to help new tenants resettle, and upscaling the provision of wraparound support initiatives such as Housing First. Homeless & Housing Support Services Manager 31/03/2025 Page 90 of 146
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24 | P a g e Context Risk Statement Owned by Current Controls Likelihood Impact Evaluation CRR24.04.15 National Care Service – governance and financial implications Cause: Consultation and negotiation breakdown in relation to fundamental elements of the Bill, with Government continuing to pursue this Policy. Event: Legislation for the new National Care Service being passed with insufficient resourcing or detail on how the service will operate, and unclear lines of accountability. Effect: The council will face further financial and operational pressures and increased risk in terms of liabilities for both the council and HSCP. CMT (1) Maintaining a watching brief through various professional networks 03 03 09 Moderate Under current proposals for the planned National Care Service, staff will continue to be employed by councils. However, under the terms of a partnership arrangement, legal responsibility for the service is to be ‘shared’ between the health service, councils, and Scottish government, with councils also responsible for buildings and the delivery of services. Parliament approved the general aims of the National Care Service (Scotland) Bill at Stage One with significant amendment to follow at Stage Two. Further to Stage Two consultation, COSLA has withdrawn support (in addition to trade unions), for the Bill in its present form, and the situation is now more uncertain than before. The risk statement is updated to reflect the above. Action Codes Actions Assigned Date Status Monitoring only CRR24.04.16 – De-escalated to service: Administering elections Page 91 of 146
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25 | P a g e Appendix 3: Service Risks Risk (Cause and effect) Risk Capture Service RR Project RR H&S PLAN Evaluation Low Moderate High Very High Means of Monitoring Board Risk-Reporting SIP Project Board H&S Planning Group Notes Chief Executive’s Service (1) Discontinuation of Shared Prosperity Fund If there is a change in government and the SPF ceases, funding for current economic development and place- based initiatives would be reduced by £5-6m. Service RR Moderate Board Risk-Reporting Renfrewshire Council benefits from the Fund through the Glasgow City Region arrangements. The current arrangements end in March 2025 and as yet, a replacement has not been identified. (2) AMIDS - Investment Zone status If AMIDS were not to achieve Investment Zone status it could dampen placeshaping ambitions and weaken local economy Project RR Moderate Board Risk-Reporting Investment Zone status would enhance the attractiveness of the site to investors, as status means various tax reliefs as well as practical support from the Scottish Government. The designation of an alternative site could reduce the appeal of AMIDS. Children’s Services (3) Future school capacity planning If demand projections are not sufficiently robust there is a risk that the learning estate will be insufficient over the longer term Service RR High Board Risk-Reporting Robust demand projections (core projection, potential upper scenario and a long-term view) for scale and timing of short-term peak demand to inform decisions. Process and arrangements to support and provide detailed monitoring and updates to projections, for updates to actual data sets to facilitate a continual re-assessment of longer-term trend and likely requirements/ decision point required in relation to deployment of potential additional interventions. Options identified to deliver, if required, additional capacity (both temporary capacity and permanent long-term capacity) to ensure the council can respond appropriately to the potential for upper end demand scenarios and or temporary demand peaks to emerge. (4) Portfolio Management Unintended delays in progress in each of the three portfolios listed below will impact on our ability to ensure that children and young people thrive, learning and achieve: 1. Curriculum, learning, teaching and assessment; Project RR Moderate Project Board Effective governance arrangements are in place with oversight, leadership and direction being provided by the Portfolio Governance Board which meets on a monthly basis. The three portfolio groups provide updates to the Board. Page 92 of 146
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26 | P a g e Risk (Cause and effect) Risk Capture Service RR Project RR H&S PLAN Evaluation Low Moderate High Very High Means of Monitoring Board Risk-Reporting SIP Project Board H&S Planning Group Notes 2. Inclusion; and 3. Families and Communities (5) Availability of Alternative Care Placement (Foster Care and Residential Care) This could result in a higher level of risk being managed within the community. Service RR Moderate Board/Committee Risk -Reporting Case managed by Social Work Management Teams with contingency plans in place. Environment, Housing and Infrastructure Services (6) Commercial Vehicle and Operators License Renfrewshire Council requires its fleet of vehicles to be effectively managed, otherwise there could be sustained impact in several areas including community care, housing maintenance and repairs, Neighbourhood Services and waste collection. Service RR High Board Risk-Reporting The fleet comprises around 500 vehicles including heavy and large goods vehicles, light vans and cars. The council implements a range of governance and operational measures to ensure ongoing vehicle operator licence compliance. A good report was received following a recent external review of arrangements and the risk has been de- escalated from the corporate risk register to the service. (7) Review of electric vehicle (fleet) infrastructure Risks associated with the installation of charging facilities were managed during the related installation projects. There is however a need to review any residual risks that remain in relation to the siting, inspection, and maintenance of the facilities, to further reduce any risks to people or property within their vicinity. Service RR High Board Risk-Reporting Electric Vehicle fleet comprises around 116 vehicles. The council implements a range of measures to ensure vehicles are roadworthy and serviced accordingly. The EV Charging Infrastructure is electrically tested at final commissioning stage by a competent EV contractor. EV Chargers are serviced annually as part of warranty/ maintenance contract. Chargers are also monitored remotely by ChargePlace Scotland for any faults and site attended by contractor if fault is not able to be fixed by back-office support. (8) Tree Fall and Ash Die Back & Larch Infection With the emergence of Ash Die back in the UK there is now an increased potential for public injury and property damage, awards against the Council, reputational damage and statutory notices Service RR High Board Risk-Reporting The main trigger for this risk was a significant outbreak of Ash Dieback in the UK which is resulting in a significant number of trees within Renfrewshire having to be felled. Work is underway. (9) Housing Regeneration and Renewal Programme Risks associated with delivering £100m regeneration and renewal programme. Project RR High Project Board Risk registers have been produced for each project and are regularly reviewed to identify, manage and mitigate known risks associated with the programme. (10) Last in Block Properties Project RR Moderate Board Report Risk register has been produced and shared with Scottish Government. Page 93 of 146
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27 | P a g e Risk (Cause and effect) Risk Capture Service RR Project RR H&S PLAN Evaluation Low Moderate High Very High Means of Monitoring Board Risk-Reporting SIP Project Board H&S Planning Group Notes Initial discussions have commenced with Scottish Government officials on the feasibility of ‘last in the block’ properties being repaired and used for the resettlement of UDP’s, and a further report will be submitted to the Communities and Housing Policy Board providing an update on progress. Application has been submitted and now been approved in principle by Scottish Government Minister. (11) Housing IT System Replacement Programme Ensuring replacement system procured fulfils all requirements and is delivered within target. Project RR High Project Board Renewal of main system dealing with Housing Services, Housing Asset Management and Homeless Services. (12) Housing Investment Programme Risk of delivering approved capital investment programmes and ensuring stock complies with statutory and regulatory standards. Project RR High Project Board As part of governance arrangements, a new project board is being established. Monthly project teams meetings have been scheduled and risk registers for each programme are being developed. (13) Delivering Homeless duties The risk is of breaching a statutory duty to provide accommodation and would be likely to lead to an increase in rough-sleeping and reputational harm. Project RR High Board Report We are at risk of being unable to provide temporary/ settled accommodation for the increased number of homeless applicants, Ukraine and Afghan resettlement programmes, and those asylum seekers living in Renfrewshire receiving positive decisions. (14) Disposal of Coal Tar Coal tar is now classed as hazardous waste material. There is consequently a knock-on risk to the council’s resurfacing scheme with some moderate delays in only a few locations as alternative solutions are developed. Service RR Moderate Board Reporting We carry out test samples prior to our resurfacing programme, and any that are found to be positive will be removed from resurfacing programme and placed on the surface treatment / recycling programme. This ensures that potentially hazardous material is left in-situ and doesn’t require to be disposed of. (15) Implementation of Local Heat and Energy Efficiency Strategy Key risk is reputational damage if the Council does not deliver on their Local Heat and Energy Efficiency Strategy and Local Heat and Energy Efficiency Delivery Plan. Work is currently underway to develop the delivery plan. Project RR Moderate Board Reporting The Scottish Parliament passed the Local Heat and Energy Efficiency Strategies (Scotland) Order in May 2022. The LHEES Order places a duty on local authorities to prepare, publish and update a Local Heat and Energy Efficiency Strategy and Delivery Plan. (16) RAAC in the learning estate During the check at Castlehead High School, structural engineers identified the presence of RAAC limited to Service RR Low Board Risk-Reporting Estate wide inspection/check for RAAC was undertaken. Only Castlehead HS had a positive result and works to remediate are almost complete. The risk has been Page 94 of 146
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28 | P a g e Risk (Cause and effect) Risk Capture Service RR Project RR H&S PLAN Evaluation Low Moderate High Very High Means of Monitoring Board Risk-Reporting SIP Project Board H&S Planning Group Notes the school gym halls. The inspection concluded that our analysis of the construction materials of the main school building was correct, but that different material, RAAC, had been used in the construction of the gym halls. **RISK now REMOVED** reduced to low and removed from report for local monitoring to conclusion, by EHI. (17) Collection and Disposal of Waste Upholstered Domestic Seating (WUDS) / Persistent Organic Pollutants (POP’s) From 31st January 2024 new guidance came into force that changed the collection, storage and disposal of waste containing Persistent Organic Pollutants (POP’s) which must be separated and sent for incineration. The impact of this could be both financial and environmental. Project RR Moderate Project Board From 1st February 2024 we have allocated additional resources to assist at the Household Waste Recycling Centres (HWRC’s) to ensure that WUDS/POP's waste does not contaminate other waste streams as set out in the Changes to Upholstered Furniture Collection, Storage and Disposal approved by the ILE Board on 24th January 2024. A separate Special Uplift squad has been formed, as part of the Council's Special Uplift Service, to manage the collection of WUDS and POPs. Linwood Household Waste Recycling Centre (HWRC) is the only Council site which accepts POP’s waste. We will monitor waste trends/patterns over the coming year. However, until a full years' data that identifies seasonal demands is available the scale of financial and service risks are difficult to determine. (18) Collection Management / Routing Software for Waste and Recycling Service The Service is looking to improve performance and maximise efficiencies by procuring and implementing a new Waste & Recycling Management/Routing system. This will assist in the setup and day-to-day management of the waste and recycling collection service. There is a risk that during the implementation process the service to customers may fluctuate and they are not kept fully informed. Project RR Moderate Project Board A Project team is being assembled, with cross-service representation to ensure the effective procurement and implementation of the new Waste and Recycling Management System. The project team will be responsible for the planning and implementation of a comprehensive communication strategy at each stage of the project. The service will liaise with colleagues from Customer Services Unit to share information and ensure this is available to customers timeously. Finance and Resources Services Page 95 of 146
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29 | P a g e Risk (Cause and effect) Risk Capture Service RR Project RR H&S PLAN Evaluation Low Moderate High Very High Means of Monitoring Board Risk-Reporting SIP Project Board H&S Planning Group Notes (19) PCI certification Certification is required for taking credit and debit card payments. If certification is not consistently achieved, there is a risk of significant financial penalties applied by our Acquiring Bank and/ or removal of our ability to accept credit & debit cards completely. This would have a significant impact on Customers, Council income and the Council’s digital aspirations. Service RR High Board Risk-Reporting To accept credit and debit card payments the Council is contractually obligated to comply with the Payment Card Industry Data Security Standards (PCI). This must be proven by submitting annual Self-Assessment. Questionnaires that match payment forms taken. Security & Compliance Mgr responsible for PCI compliance across Council. Internal procedures for applying compliance standards to card payment services. Annual independent audit of card payment procedures against PCI standards. PCI Governance Group to be established consisting of representatives from all Services who deliver ‘pay for’ services in the community. Training for staff handling card payments (20) Programme and project management Where some projects might sit outside of the programme management unit’s knowledge/ awareness, there is a risk that those projects fail either in timescales, quality, or costs or even if successfully concluded, do not deliver the intended outcomes. Service RR Moderate Board Risk-Reporting This risk had been on the corporate risk register but project health checks provided reassurance regarding our corporate approach to programme and project management. The risk has therefore been de-escalated back to Finance and Resource Services for monitoring in relation to arrangements for smaller projects that might sit outside of the programme management unit’s awareness. (21) Administration of elections While there are no planned electoral events until 2026, election preparedness is important on an ongoing basis to respond to snap elections or by-elections. If we are not prepared and do not monitor on an ongoing basis the supply chain relied upon for various elements of the then there is a risk that we will struggle to deliver the administration of an event with significant reputational impact. Service RR Moderate Board Risk-Reporting The council has a highly experienced group of staff that can be relied upon to lead and deliver on the governance, logistics, risk and contingency workstreams required to deliver an electoral event with integrity. There is also ongoing monitoring of supply chain, such as for printing and distribution of postal votes, ballots papers, availability of electronic voting equipment etc. Page 96 of 146
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30 | P a g e Appendix 4: Business-as-Usual Risks The council has 12 areas of risk monitored via BaURAM © Renfrewshire Council. Each Head of Service (and other officers who report directly to a Service Director), undertake an annual self-assessment against a set of questions for each risk and indicate what level of assurance they can provide in relation to how they and their teams perform in these areas. In keeping with risk management KPIs, the Corporate Risk Management Group monitors % of modules with assurance ratings equal to or greater than reasonable assurance. For year 2 of the model it has been agreed that there should be a schedule of three specific modules to be completed each quarter. The image on the left shows the system output for 2024-25 Q2 The image on the right shows the system output for 2023-24 Q2 for comparison Page 97 of 146
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31 | P a g e While these are the council’s business-as-usual risks, where there is recognised need for specific corporate action in any of these aspects of risk, these are escalated from time to time to the corporate risk register. An example of this is nos. 2 and 7 below. Aspects of these risks are reflected not only within the risk assurance model but are also reflected in the corporate risk register. BAU RISK AREA ENCOMPASSING BAU RISK AREA ENCOMPASSING 1. Community & public safety Child and adult protection Serious and organised crime (external) 2. Asset management Statutory compliance Arrangements for void properties Fleet and other infrastructure ICT hardware and software assets and responsibilities 3. People wellbeing & development Staff health and wellbeing Training and development Corporate and local induction 4. Information handling GDPR compliance Information asset management Information security Records management 5. Health, safety & managing adverse events Staff incident recording RIDDOR arrangements Incident monitoring and trends analysis 6. Programme and project management Governance Compliance with industry standards/ adopted methods 7. Organisation resilience Business continuity: - Staffing resource - ICT and/ or power outages - Facility issue - Cyber security 8. Partnership management Partnership registers Agreements Liabilities 9. Financial control and governance Authorities and delegation Budgeting and accounting Conflict and whistleblowing Insider threat and crime Counter fraud 10. Service planning and performance monitoring Customer engagement Public/ stakeholder engagement KPI trends analysis Links to risk management and service improvement 11. Procurement and contract management Standing orders Roles and responsibilities Monitoring & Performance Mgt 12. Complaints, comments and claims handling Compliance Trends analysis Links to service improvement [Item End] Page 98 of 146
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___________________________________________________________________ To: Audit, Risk and Scrutiny Board On: 04 November 2024 ___________________________________________________________________ Report by: Director of Finance and Resources ___________________________________________________________________ Heading: Audit Scotland Report on ‘Tackling Digital Exclusion’ ___________________________________________________________________ Summary 1. Audit Scotland regularly publishes national reports on matters relating to local government in Scotland. This report provides an overview of the recently published audit on Tackling Digital Exclusion, which has been summarised for Board members and provides an overview of the challenges and recommendations outlined by Audit Scotland regarding digital exclusion in Scotland. 2. As digital technology continues to transform public services, addressing digital exclusion is essential to ensuring that everyone can participate fully in society, access essential services, and benefit from the opportunities that digital connectivity offers. 3. The audit adopted a human rights-based approach, allowing people with experience of digital exclusion and use of digital services to participate in and inform the audit and comprised of the following three parts, which aims to inform, provide assurance, and support improvement: • What is digital exclusion? • How well is the public sector tackling digital exclusion? • Enabling digital inclusion Item 6 Page 99 of 146
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2 Recommendations 4. It is recommended that members of the Audit, Risk and Scrutiny Board: • Note the content of this report; and • Note the considerable collective action already in place across Renfrewshire to support and enable digital inclusion, whilst ensuring no one is left behind; • Note plans to further strengthen digital inclusion activity across Renfrewshire as referenced at paragraphs 25, 26, 34-38 and 43-48. Audit Scotland Report on Tackling Digital Exclusion 5. In August 2024, the Accounts Commission and Auditor General published their joint Digital Exclusion Report, with the overall aim of considering how well public bodies understand digital exclusion and are taking action to reduce it. This briefing considers the context of the report and its recommendations and sets out how Renfrewshire’s person-centred and place-based approaches have been highlighted as an exemplar by Audit Scotland. 6. The report, “Tackling Digital Exclusion,” prepared by Audit Scotland, provides a comprehensive assessment of public bodies’ efforts to address digital exclusion. Digital technology has become integral to everyday life, from public services to education and social connections. However, it notes that not everyone can access or benefit from digital resources. The report also highlights the extent of digital exclusion in Scotland, the public sector’s response to it, and the key challenges ahead. 7. The Report explains that digital exclusion, sometimes called digital poverty, can change over time, and can affect people in many ways, including: • Inability to afford an appropriate device or internet connection; • Not having the skills and confidence to use digital technology; • Having a fear or mistrust of using online services or lack motivation to do it; • Having difficulty in accessing digital services and devices or an internet connection; • Being unable to keep up with the pace of change of digital technology. Key messages from the Audit 8. The Report notes that digital exclusion can have a severe impact on people’s lives and for public service reform to be effective it needs to make sure that digitalisation leaves no one behind. The key messages from the Audit, include: Page 100 of 146
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3 • Digital technology has brought benefits to many of Scotland’s people and communities. • In an increasingly digital world not everyone can get the services and support they need or are entitled to. • This has a severe impact on some people’s lives, which public bodies are often not aware of or do not consider when moving services online. • The public sector response to digital exclusion increased significantly during the pandemic. • But national leadership for tackling this critical issue has weakened since then and momentum has now slowed. • Significant pressures on public finances mean that the Scottish Government and councils are making difficult choices about public spending priorities, including reducing the direct investment in tackling digital exclusion. • All public bodies have a responsibility for enabling digital inclusion in their programmes for reform. The Scope of Digital Exclusion 9. The report presents key statistics that illustrate the prevalence of digital exclusion in Scotland: • 15% of Scotland’s adults lack essential digital skills, such as the ability to turn on a device or browse the internet. • 9% of households lack an internet connection. • Lower-income households are disproportionately affected, with 69% of households earning less than £10,000 having internet access compared to 99% of households earning more than £40,000. 10. Additionally, rural areas often experience poorer connectivity, further exacerbating the exclusion of rural communities from digital services. As digital technology becomes central to public services, the risk of excluding those who lack digital access grows. This exclusion can affect access to healthcare, education, and employment opportunities and can result in greater social isolation. 11. Digital exclusion can prevent individuals from realising their human rights. For example, it can limit their access to education, social security, and healthcare services. The Audit notes that online public services often do not consider the needs of digitally excluded people, placing them at a further disadvantage. The report emphasises that digital inclusion is a fundamental aspect of securing equal access to services and protecting individuals’ rights. Page 101 of 146
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4 The Public Sector’s Response to Digital Exclusion 12. The COVID-19 pandemic accelerated the digitalisation of services and brought digital exclusion to the forefront. During this period, the Scottish Government, councils, and third-sector organisations worked together to mitigate the impact of digital exclusion on vulnerable populations with key initiatives including: • Connecting Scotland: Launched in May 2020, this program provided digital devices, internet access, and skills training to over 61,000 households across Scotland. The initiative supported vulnerable groups, including low-income families, socially isolated older adults, and people at high risk of COVID-19. • Digital Participation Charter: This initiative promotes an inclusive and ethical approach to digital services and provides organisations with tools and resources to foster digital participation. • Place-Based Approaches: Several councils, including Renfrewshire Council, adopted local strategies tailored to address the unique needs of their communities. Renfrewshire’s approach is highlighted as an exemplar in Case Study 3 of the Audit Report, which also references programmes like Stirling Council’s tablet lending service and Perth and Kinross Council’s consultation efforts are examples of place-based responses to digital exclusion. Challenges and Declining Momentum 13. Despite early success, the momentum in addressing digital exclusion has slowed since the pandemic. The report identifies several key challenges: • Weakened National Leadership: Leadership at the national level has diminished, with unclear responsibilities and a lack of coordination in delivering digital inclusion. • Reduced Funding: The Scottish Government reduced its funding commitments to programs like Connecting Scotland. The budget for 2023/24 allocated only £1.3 million, a significant drop from the previous investment of £50 million during the pandemic. • Lack of Clear Strategy: Although the Scottish Government and COSLA launched a national digital strategy in 2021 with the aim to “leave no one behind,” the strategy lacks a clear action plan, roles, responsibilities, and accountability mechanisms. The report highlights the need for a refreshed strategy to address these gaps. Page 102 of 146
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5 Enabling Digital Inclusion 14. To truly enable digital inclusion, public services must prioritise inclusivity in service design and delivery. The report outlines a set of key principles for enabling digital inclusion, which includes: • Collaboration: Cross-sector collaboration is essential, including partnerships between public bodies, third-sector organisations, and private providers. • Accessible Services: Services should be designed to meet the needs of all users, ensuring that non-digital or assisted digital options are available for those who cannot access online services. • Digital Literacy and Confidence: Public bodies should invest in digital skills training for both staff and the public, ensuring that individuals have the confidence to navigate the digital world. • Affordability: Access to affordable devices and internet connectivity is a crucial aspect of digital inclusion, especially for low-income households. Public bodies should support initiatives that make devices and data more accessible. Audit Report Recommendations and Conclusion 15. The report provides detailed recommendations to ensure that digital exclusion is effectively tackled across Scotland, noting specific recommendations for: • The Scottish Government and CoSLA; • The Scottish Government; • CoSLA; • All public bodies, including the Scottish Government, councils, NHS boards and others; and • Councils 16. The report concludes that while digital inclusion is critical to Scotland’s public service reform agenda, efforts to tackle digital exclusion must be revitalised. There is a need for renewed national leadership, clear strategies, and sustained investment to ensure that no one is left behind in the digital age. The Scottish Government and public bodies must work together to develop and implement comprehensive solutions to address digital exclusion and enable equitable access to digital services for all. Page 103 of 146
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6 Enabling Digital Inclusion in Renfrewshire 17. Renfrewshire has a strong history of enabling digital inclusion through multi and cross-sector collaboration with our partners. This work has been commended by Audit Scotland and is highlighted as a case study in their Tackling Digital Exclusion Report. 18. A key recommendation within the Report specifically for Councils is to: • “Work with partners to develop a clear approach to tackling digital exclusion as part of their strategies and plans, based on an understanding of digital exclusion locally, who is affected and how. They should map out local resources and assets across the public, private and third sectors, and provide clear routes to digital support and accessible information on the support available to local communities.” 19. The following paragraphs highlight the breadth of digital inclusion activity being delivered by partners across Renfrewshire to enable digital inclusion and ensure no one is left behind. DigiRen Network 20. DigiRen is one of two key vehicles for both driving and delivering digital inclusion through multi and cross-sector collaboration. 21. Over 180 individuals from over 80 unique local and national organisations, DigiRen represent the Public, Third, Community and Voluntary, Academia and Social Housing sectors that all share a common goal of promoting Digital and Data inclusion in Renfrewshire. 22. In September 2024, DigiRen hosted a joint hybrid event in Paisley Central Library, where almost 100 delegates attended either in person or online. The event coincided with the Digital Poverty Alliance’ National End Digital Poverty Day and provided a platform for Audit Scotland to present their findings from their Report and this was followed by a digital inclusion showcase covering the following themes: • Keeping People Safe, Confident and Protected through our innovative RenSafeOnline Programme • Enabling and empowering older adults using digital; • Enabling and empowering Children and Young People using digital; • Enabling and empowering people within a health and social care setting using digital; Page 104 of 146
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7 23. Audit Scotland commended and highlighted the approach taken in Renfrewshire as an exemplar at the event and members can watch the recording of the event at https://www.youtube.com/watch?feature=shared&v=i29tmmVKOMs Demonstrating impact through cross-sector collaboration 24. Work to understand the impact and provision of digital inclusion in Renfrewshire has been progressed at pace and during 2023/24 DigiRen partners collectively: • Helped over 86k people get online; • Delivered 800+ digital related courses; • Supported around 50 businesses around digital; • Have access to over 100 online safety ambassadors through our RenSafeOnline programme. • Have access to almost 200 Digital Champions • Distributed almost 700 devices / connectivity. 25. In November, DigiRen will be hosting its first every DigiKnow(vember), 5 days of activities to promote digital and data inclusion to help build a digitally inclusive Renfrewshire. 26. Over 20 partners to date, have pledged their support which will involve a series of both online and offline events including, 1-2-1 & group sessions, volunteering opportunities, showcases, webinars and more. Citizens Voice Forum 27. Citizens Voice Forum seeks to co-design digital inclusion solutions by taking a person-centred and place-based approach and by working with organisations involved in delivering digital inclusion as well as those impacted by digital exclusion. 28. Members of Citizens Voice agreed the following priorities and updates have been provided in the paragraphs below: Digital Champions Programme 29. Digital Champions play a key role in helping people build capacity, capability, and digital skills to help them navigate the digital world. 30. Last year, following a successful bid via the Fairer Renfrewshire Fund, a Digital Champion Coordinator was recruited on a 2-year temporary basis. Page 105 of 146
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8 31. The post was filled in May 2023 and is hosted within Renfrewshire Libraries (ONEREN) and continues to play a vital role in promoting digital and data equity across Renfrewshire. 32. To date, the project has: • Supported 696 Learners across 6 libraries. • Issued 156 pre-loaded data SIMs to families from a low-income household. • Recruited and trainee 27 Committed Digital Champion volunteers. • Collectively delivered over 1,000 Volunteer hours. Almost 900 in this year alone. 33. A Digital Champions Network has now launched, and is available to all Digital Champions, or organisations hosting Digital Champions across Renfrewshire, which: • Connects Digital Champions with other Digital Champions and provide a space for Peer-to-Peer support and networking. • Provide up to date information to all Digital Champions or local third sector groups and training offers. • Provide space for organisations to request the support of other Digital Champions in the area. Digizones 34. A Digizone is a place where people can Connect, Learn, and Explore through having online access and offers a variety of services to enhance a person’s digital experience. 35. Digizones will help to further strengthen our approach and help to build a digitally inclusive Renfrewshire by building capacity, capability and awareness of digital inclusion and help tackle loneliness and isolation by bringing people together. 36. This will be delivered using “a trusted face in local place” approach where people will be able to access either a mix or all of the following: • Connectivity; or • Digital Device; or • Digital Skills Support; or • Signposting – to where a person can access digital inclusion supports. 37. A sub-group has been progressing this work at pace and during National Get Online Week, between 14-20 October 2024, Digizones started rolling out in over 21 venues and a mobile Digizone, using the Skoob Mobile, across Renfrewshire. Page 106 of 146
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9 Community-Led Secure Device Recycling Project 38. Council and ONEREN Officers are exploring options to develop a community- led secure device recycling project, linked to employability. The project seeks to provide a pathway for our citizens, communities, and businesses to recycle their digital devices and where possible, devices will be refurbished and used to support digital inclusion in Renfrewshire. Keeping People Safe, Confident and Protected online 39. Evidence shows that if a person is not confident or motivated then they won’t go online. One of the many approaches adopted in Renfrewshire to help Keep People Safe, Confident and Protected Online is via an innovative approach through our RenSafeOnline Programme. 40. RenSafeOnline is a collaboration between Renfrewshire Council and Get Safe Online, the UK’s leading internet safety website, that provides unbiased, factual, and easy-to-understand information on online safety. Its mission is to support Renfrewshire Council’s aspirations by taking a hyperlocal and place- based approach using byte-sized messaging and is available to anyone living, learning, or working in the Renfrewshire area. 41. Lead by the Council’s Security and Compliance Manager, RenSafeOnline is helping to build confidence, capacity, and resilience when it comes to online safety by providing greater awareness of online scams and harms and educating people about the various layers and preventative measures available to keep them safe. 42. To date, RenSafeOnline, through their internationally certified Online Safety Ambassador programme has: • Recruited and trained almost 150 Online Safety Ambassadors; • Issued monthly focussed campaigns via DigiRen Network; and • In March 2024, Renfrewshire hosted its first ever Cyber Escape Room Experience where over 400 people participated by completing a series of puzzles and riddles with the aim of beating the hacker. Connecting Communities through Council Managed Secure Public Access WI-FI 43. Through Renfrewshire Council’s Connectivity as a Service Framework, our Secure Public Access WI-FI is enabling greater collaboration opportunities in the Digital Inclusion space. Page 107 of 146
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10 44. Renfrewshire is recognised as one of the best-connected regions in the UK, with over 92% coverage of gigabit capable broadband; 45. Once fully rolled out Free Secure Public Access WI-FI will be broadcast from up to 180 Council venues, including in 3 town centres across Renfrewshire. 46. Last year, the Council’s Public Access WI-FI helped connect around 60K people to the internet and in terms of Fairness, our infrastructure now offers greater flexibility, particularly: • Across our Learning Estate; by providing internet in areas both inside and outside schools; • Providing Internet Access TO AND THROUGH our Care Homes; • Providing Internet Access TO AND THROUGH our Children’s Homes; • Providing Internet Access in Communal Areas in our Sheltered Housing complexes; and • Supporting many of our vulnerable citizens within a Health & Social Care Setting to get online; Smart Social Housing / Assets 47. Renfrewshire Council has a vision for enabling Smart Social Housing across our portfolio of 12,000 social homes to improve the health and wellbeing of our tenants, to tackle poverty and inequalities head-on, and to enable prevention and service sustainability at scale. 48. Work has been accelerated at pace to determine the financial viability and sustainability of this first-of-type invest to save model. This could result in the deployment of a digital bundle of superfast broadband and IoT environment monitoring into 10,000 social homes. This has the potential to provide the foundation for deploying a portfolio of in-the-home digital solutions to powerfully enable housing as a social determinant of health and to shift the balance of care by keeping people safe, well, and socially connected in their own homes. Page 108 of 146
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11 __________________________________________________________________ Implications of the Report 1. Financial – none arising from the report; however, Audit Scotland publications note the Scottish Government should consider funding priorities and funding requirements for an updated digital strategy and plan for tackling digital exclusion as part of medium-term financial planning. 2. HR & Organisational Development – none arising from the report. 3. Community/Council Planning – none arising from the report, though a key recommendation notes the importance of public bodies building digital inclusion into strategies and design for digital services and reform, aligned with Scottish Digital Services Standards, and carry our equality and human rights impact assessments. 4. Legal - none 5. Property/Assets – none 6. Information Technology - none 7. Equality & Human Rights – none arising from the report, though it notes that requirement for equality and human rights impact assessments when building digital inclusion into strategies and design for digital services and reform. 8. Health & Safety – none 9. Procurement – none 10. Risk – none arising, though the publication referred to highlights that building digital inclusion into strategies is key to public service reform. 11. Privacy Impact – none 12. COSLA Policy Position – none 13. Climate Risk - none arising from this report, though some of the projects which enable digital inclusion e.g. community-led device recycling project, will positively contribute to Renfrewshire Council’s climate agenda. 14. Children’s Rights: none _______________________________________________________ Page 109 of 146
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12 List of Background Papers: Audit Scotland report: Tackling Digital Exclusion __________________________________________________________________ Author: Patrick Murray, Head of Digital, Transformation and Customer Services patrick.murray@renfrewshire.gov.uk Page 110 of 146
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To: Audit, Risk and Scrutiny Board On: 4 November 2024 Report by: Chief Executive Heading: Actions Monitoring Report - Dargavel Primary School 1. Summary 1.1 Following the findings of an independent review into the circumstances of the errors in planning and delivery of primary school provision in the Dargavel area, a SMART action plan was developed detailing the Council’s response with a commitment that updates on this plan would be provided to Audit Risk & Scrutiny Board meetings going forward. 1.2 Findings by the Accounts Commission in relation to their S.102 investigation were reported to the Council on 26 September 2024. That report included the Council’s response to the Accounts Commission, with further work being predominantly addressed through continued engagement and monitoring by the local external audit team through their Annual Audit work and upcoming Best Value audit. 1.3 The appendix to this report provides an update in relation to the Bowles independent review report, the Accounts Commission S.102 report, and the actions related to the report of the Cross Party Working Group. In previous updates, Appendix 1 detailed the position in relation to remaining live actions while Appendix 2 summarised all completed actions from each of the three reviews. There are no open actions remaining, therefore only one appendix is now required and attached detailing the completed actions. Within that appendix Members should note that where an update has changed from that previously reported to the Board, these are shown in italics and underlined. Item 7 Page 111 of 146
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1.4 Given there are no remaining open actions, with all actions either complete or now incorporated into other reporting arrangements, it is intended that there will be no further specific monitoring reports provided to the Board. The Board will receive updates as appropriate through existing monitoring arrangements e.g. risk management updates. 2. Recommendations 2.1 Note the completed actions outlined in the appendix. 2.2 Note that this report will be the final specific monitoring report the Board will receive, with updates being provided to relevant Policy Boards or though risk monitoring arrangements. Implications of the Report 1. Financial – whilst there will be significant capital and revenue implications for the Council in resolving the Dargavel issue, there are no financial implications for the Council as a result of this update report. 2. HR & Organisational Development – the report outlines a leadership development programme with a focus on key issues raised in the independent review around governance, risk management, corporate working and culture. 3. Community/Council Planning – the report outlines ongoing action being taken to develop an engagement and ongoing communication process with affected communities. 4. Legal – none 5. Property/Assets – none 6. Information Technology – none 7. Equality & Human Rights - The Recommendations contained within this report have been assessed in relation to their impact on equalities and human rights. Page 112 of 146
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No negative impacts on equality groups or potential for infringement of individuals’ human rights have been identified arising from the recommendations contained in the report as it is for noting only. If required following implementation, the actual impact of the recommendations and the mitigating actions will be reviewed and monitored, and the results of the assessment will be published on the Council’s website. 8. Health & Safety – none 9. Procurement – none 10. Risk – the report outlines the action being taken in relation to risk management. 11. Privacy Impact – none 12. Climate Risk – none 13. Children’s Rights – none 14. COSLA Policy Position - none Author: Alan Russell, Chief Executive Page 113 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 Action Target Completion Responsible Officer Update Bowles Report Recommendation 1 Build a more robust model of primary school need for Dargavel ‐ the Council should continue to refine its pupil forecast model for Dargavel. Response Objectives Deliver robust projection modelling for Dargavel and PMHS which: ‐ considers live information arising from NHS, pupil & ELC registrations, the pace of development to date, certainty over development size and likely pace of future build out rate, utilises external data analytics and projection expertise to augment and enhance the Council’s in‐house forecasting approach to ensure modelling is robust, underpinned by external challenge and specialist input reflecting the complexity and significant portion of Dargavel that has yet to be developed out over a circa 10 year period, provides modelling output which considers potential future upper scenarios reflecting the high yield factors reflected in the 2023/24 P1 intake to inform immediate decisions on scale of capacity to be delivered as well as planning for potential additional interventions at a future time, delivers modelling output which provides a long‐term view beyond the anticipated completion timeline for Dargavel to ensure the long term impact of Dargavel is modelled and understood, provides modelling output over the long term which indicates both the scale, timing and shape of an anticipated peak in demand that will accompany a development of this scale and nature. This will provide visibility of the anticipated short‐lived peak in demand and long term settled demand to ensure this is appropriately reflected in estate/capacity decisions and in particular to mitigate against delivery of excessive long term / permanent increase in capacity that would result in excess unused surplus capacity over the long term. Provides modelling that can be tested and revised as necessary as new key data becomes available such as P1 and S1 registrations, actual scale and pace of the development and any new developments, which will continue to inform decisions on any future estate interventions if required. Page 114 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 Action Target Completion Responsible Officer Update Complete Council modelling through to the anticipated end date for the housing development (2033/34) based on assumed 4,300 units and available live data. October 2022 Director of Children’s Services Completed October 2022 Engage and appoint Edge Analytics to deliver enhanced modelling approach for both Dargavel primary requirements as well as PMHS out to 2033/34 and updated live datasets. February 2023 Director of Children’s Services Completed February 2023 including additional upper forecast scenarios for Dargavel non‐denominational requirements to support management of risk associated with long term yield remaining at similar level to 2023/24. Informed reports to Education and Children’s Services Board in March and May 2023 Extend Edge engagement to deliver an enhanced model projecting out to 2038 to provide longer term forecast to assess the full impact on the secondary sector and allow identification of likely timing and scale of peak demand encapsulating any relevant updates to live datasets. September 2023 Director of Children’s Services Modelling completed which has identified an anticipated peak period in both primary and secondary sectors and reported to Education and Children’s Services Board in November 2023. Provide update to November Education & Children’s Service Policy Board. November 2023 Director of Children’s Services Two update reports were taken to the November 2023 ECSPB: 1. Learning Estate 2. Dargavel Housing Development – Impact on Denominational Education Provision Update Edge Analytics modelling for newly released national Census data and expand across the whole school estate and establish modelling dashboard to support ease of updating and rapid re‐assessment of revised projection that will be utilised on an ongoing basis over future years, both for Dargavel / PMHS but also as part of the strategic Learning Estate programme. January 2024 Director of Children’s Services A detailed update was provided to the Audit Risk and Scrutiny Board in September 2024 to explain the timeline of events surrounding this action throughout the duration of 2024. In summary, an elongated programme of work was undertaken with Edge Analytics to develop a bespoke model that is suitable for a full school estate projection in Renfrewshire. This action is therefore complete with the successful delivery of this full estate model that incorporates the latest available national and local data sets. This model and the pupil projections will be presented to the October Education and Children’s Services Policy Board. Page 115 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 Bowles Report Recommendation 2 Use of Bishopton Primary - in its future plans the Council should reconsider how surplus capacity at Bishopton can be used effectively. Response Objectives Consider and assess how existing capacity within Bishopton Primary School may be best utilised to support the Dargavel catchment over the immediate term and potentially over the longer term, taking into consideration the uncertainty and risk over the long‐term demand levels that will ultimately emerge for primary education from Dargavel as well as the expectation of a temporary peak period of demand. Provide a report to Education and Children’s Services Board setting out a clear overview as to how Bishopton PS capacity will be utilised to support temporarily over the short term period and how it may be considered amongst other options for use to support Dargavel in the longer term (noting that any such longer term use will be subject to detailed consideration and decision at an appropriate point in future years). Action Target Completion Responsible Officer Update Complete assessment of anticipated P1 intake from Dargavel catchment and assess against revised DPS capacity availability, establish planned P1 intake capacity cap and anticipated P1 intake requiring accommodation at Bishopton Primary School. August 2023 Director of Children’s Services Planned use of Bishopton Primary School along with planned capped entry levels to Dargavel Primary School reported an approved at Education and Children’s Services Policy Board in August 2023. There will be a requirement to annually monitor anticipated and actual P1 intakes carefully to assess adequacy of short term capacity provision across both Dargavel and Bishopton Primary Schools to meet demand pending the second primary school in Dargavel coming on stream. Complete an exercise to assess the timing, scale and range of potential demand level scenarios, in particular understanding the scale and timing of the peak demand and likely settled long term demand. This information will be used to inform the assessment of how Bishopton Primary School could, if required, be potentially be utilised as an option in the longer term. January 2024 Director of Children’s Services Completion of the updated work with Edge Analytics has provided a view of the likely timing and length of the peak demand period – with peak primary demand being forecast in 2033/34 which will fall over the second half of the 2030s to a more settled level. Further work is being progressed to update this information for the recently released 2023 census information and November registration data to inform an overall assessment. Revised roll projections for the entire learning estate are currently being produced. In anticipation of these, work is underway by utilizing current live data and matching this with draft roll projection data to run scenario planning for the short, medium, and long term capacity demand on both Dargavel Page 116 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 Primary and Bishopton Primary. Entire Learning Estate modelling completed and reported to ECSPB October 2024 and which includes a full update on Dargavel / Bishopton and the position short term in 2025 – 2026 and longer term post completion of Dargavel Village development in circa 2033/34. Complete financial analysis to understand the potential financial context of utilising Bishopton Primary School Capacity May 2023 Director of Finance and Resources Bishopton PS is a predominantly 1960s construction and is more than 60 years old. This building will, along with the whole school estate, undergo an updated condition survey over coming months. Notwithstanding, given the underlying age of the building it will inevitably have a limited remaining lifespan before being considered for replacement. Existing surplus capacity if used permanently to reduce the required size of a second Dargavel primary school, will require to be replaced as part of a renewal programme. The determination of the timing of that will be subject to work progressed as part of the strategic learning estate programme. Consequently, it has been assessed that any financial advantage from utilising Bishopton PS will be restricted to a temporary time value of money benefit and consequently will be relatively limited. In addition, there is also a risk that utilising Bishopton PS permanently removes its availability to provide supporting capacity to manage both a temporary peak that may arise from upper end educational demand scenarios and longer term upper end demand. There could be the risk that in such circumstances if Bishopton capacity was no longer available this would lead to higher overall costs over the longer term for the Council. The financial considerations and risks were incorporated into the overall assessment reported as part of the Education & Children’s Services Board report in January. Page 117 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 Action Target Completion Responsible Officer Update Set out overview in a report to the Education and Children’s Services Policy Board in respect to the potential long‐term utilisation of Bishopton Primary School which will be subject to detailed consideration at an appropriate point in future years as actual long term demand trends increasingly emerge. January 2024 Director of Children’s Services Work to allow appropriate recommendation to be made is progressing in line with plans and scheduled to be reported to Board in January 2024. A paper was presented to Board in January 2024 Page 118 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 Action Target Completion Responsible Officer Update Bowles Report Recommendation 3 As the Council progresses its plans to issue supplementary guidance on developer contributions for education it should seek to learn from other Councils in Scotland. A development the size of Dargavel is exceptional and would need its own modelling techniques. However, for smaller developments the Council should create an evidence base to calculate specific yield factors derived from recent developments in Renfrewshire. Such robust data will ease future negotiations. Undertake a desk top review of other local authorities across Scotland and identify key best practice councils to engage. June 2023 Head of Economy and Development Completed Complete detailed engagement with identified best practice councils arising from desk top research Summer 2023 Head of Economy and Development Detailed engagement completed with Fife, Falkirk and West Lothian councils. Complete data analysis exercise of a range of datasets of mixed historic sites across Renfrewshire to provide empirical evidence to support actual pupil yields to inform establishment of appropriate yield factors to be used in future contribution policy. Refresh % capacity of all schools (vs school rolls) Sample research of Pupil Product Ratio (PPR) for developed housing sites (< 10 units) [min 10 site sample] Sample research of PPR for developed housing sites (> 100 units)[min 10 site sample] Sample research of PPR for established / mature housing development to provide longer term perspective (eg. 15 years old) (> 100 units)[min 4 site sample] Identify individual schools where pupil capacity is above notional threshold (85%) October 2023 Head of Economy and Development Work on this is now complete, agreed new draft planning guidance presented to March 2024 PCC Board. Page 119 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 Action Target Completion Responsible Officer Update Identify all known undeveloped housing sites in individual school catchments [Subset of 5] identify all housing sites with current "live" planning application Identify schools where it is anticipated intervention would be required to increase capacity based on potential future housing to be delivered over next 10 years to inform likely future developer discussions. Incorporate into the development of the draft contributions policy targeted to be presented to the Planning and Climate Change Policy Board in January 2024. March 2024 Head of Economy and Development Work on this is now complete, new draft planning guidance presented to March 2024 PCC Board. Bowles Report Recommendation 4 Council needs to work co‐operatively with BAE. Unless the Council and BAE can work together to resolve the current problems, BAE may face accusations, whether founded or not and regardless of Council incompetence, that it has increased its profits at the expense of Council taxpayers. Response Objectives Secure legal ownership of suitable land to facilitate delivery of a second school within Dargavel Village as well as additional land next to existing school site to provide increased flexibility to meet potential future extension of the school and or establishment of greater outdoor space. Secure legal commitment from BAE to provide land remediation and associated infrastructure requirements as part of legal agreement at nil cost to the Council. Secure as part of the legal agreement certainty on consented planning numbers and any associated adjustments to s.75 agreement to reflect revised agreement. Secure with BAE agreement on Heads of Terms for allow for mutual governance approval from each organisation to inform detailed legal agreement drafting and final sign off As soon as possible Chief Executive This was completed and approved by ILE Board end of August 2023 Page 120 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 Action Target Completion Responsible Officer Update was targeted. Secure completed and signed legal missives to deliver in full the objectives outlined above to provide certainty and timing of availability of remediated and infrastructure proofed land to support wider school delivery planning and consultation arrangements that will be progressed by the Council team. August 2023 Chief Executive Legal missives concluded mid‐September 2023 Proposed revisions to S.75 negotiated with BAE Systems were approved by ILE. Revised S.75 signed off by both the Council and BAE Systems to legally conclude matters. August 2023 Head of Economy & Development Approved by Planning and Climate Change Board August 2023 Bowles Report Recommendation 5 Corporate working and organisational culture ‐ although I understand that the Council has sought to improve and strengthen corporate working in recent years, the evidence would suggest there is a long way to go; simply establishing corporate working groups is insufficient if staff are in a mindset of ‘not my problem’. The failure of management oversight, if symptomatic of the Council as a whole, would be deeply disturbing. The Council needs to consider a significant change programme, not just on the of issue of corporate working and personal responsibility, but also its organisational culture and values. It needs plans to build a stronger organisation where constructive challenge is welcomed and there is a clarity of what is expected of all of those in a leadership role. Response Objectives Provide assurance that established programme governance framework and operations of governance for other major capital investment programmes and specifically that the Bowles findings on the historic failings on the handling of Dargavel by officers are not representative of the Council’s current culture and approach to the management and delivery of major programmes. Page 121 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 Action Target Completion Responsible Officer Update The Council is committed to living its values as a learning and collaborative organisation and post COVID was already in the process of re‐establishing an Leadership Development programme for senior leadership teams and managers across the Council in recognition that this required to be reinvigorated post COVID and that there has been significant turnover in management and senior positions over the past three years and this would support growing and maturing the current culture and collaborative connections across the organisation. In response to the Bowles recommendations, the objective is to ensure the new Leadership Development programme is appropriately cognisant and reflective of the key learning points from the Bowles report and takes the opportunity to ensure its coverage seeks to re‐enforce the development of skills related to governance, risk management, commercial risk, corporate working and culture etc and effectively utilises failures referenced in the Bowles report as key examples for learning throughout the programme. Collective reflection and learning of such significant failures – albeit historical – is recognised as an important element of building an effective future culture and ways of working across the organisation. Undertake a health check assessment on major capital programmes to provide reassurance in respect to all aspects of governance, control, reporting and management of programmes. October 2023 Chief Executive supported by CMT City Deal and Infrastructure and Housing Investment Programme Health Check report was submitted to CMT on 21 November 2023. Put in place arrangements to deliver a comprehensive Leadership Development Programme (circa 12 months + programme) for chief officers and senior managers which amongst other things will cover and key areas referenced in the Bowles report in respect to governance, accountability, risk management, collaborative working, member officer relations etc. Commence programme by September 2023 Director of Finance & Resources and Head of HR & OD Contract agreed between the Council and Solace Enterprises to support the design and delivery of leadership development programmes for Chief Officers and Senior Managers. Leadership development programme focus on: Personal resilience Effective Communications and Elected Member Relations Programme Management, Leading and Navigating Strategic Change Risk Management and Governance Transformational Leadership Delivering Corporate/Team Values and Vision The leadership development programmes for chief officers (cohort 1) and all senior managers (cohort 2 &3) are now complete. Page 122 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 Action Target Completion Responsible Officer Update Design and undertake an evaluation process of the Leadership Development Programme for Chief Officer cohort to inform required changes / adjustments to programme delivery for next management cohort. March 2024 Head of HR and OD An evaluation of cohort 1 was carried out and presented to members in the previous report. Cohorts 2 & 3 have just completed are in the process of being evaluated. Bowles Report Recommendation 6 Risk management From documents I have seen the Council was unaware of the scale of risk it was taking in the calculation of pupil numbers. The identified risk in Council documents related to providing the school on time, not that the size of the school may prove to be inadequate. The failure to identify that risk has had two consequences; first the Council has been slow to react to the increase in pupil numbers and second the Council did not negotiate with BAE with that risk in mind. The Council needs to review how it both identifies risk and manages it. Response Objectives Progress actions to provide reassurance in relation to the Council’s current risk management approach, in particular how this is approached, deployed and managed as part of major projects as well as considering and assessing the seniority / appropriateness of officer involvement and related skills across officers involved in the process. A review of risk profiles across all service departments to ensure visibility of all risks and confirmation of where certain risks are being monitored if outwith the standard Risk Reports to the Audit, Risk and Scrutiny Board (i.e., Health and Safety Planning Groups, Service Improvement Plans etc) October 2023 Director of Finance and Resources Risk report submitted to Audit, Risk & Scrutiny Board as planned on 6 November 2023. Page 123 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 Action Target Completion Responsible Officer Update A review of the ‘service risk representative’ roles in each service department to ensure the representatives who sit on the Corporate Risk Management Group are sufficiently involved in risk matters within the service, to feed this into the Corporate Risk Management Group and that they also have authority within the service to provide challenge as a ‘critical friend.’ October 2023 Director of Finance and Resources Action completed. CMT agreed (10 October 2023), that each Director will nominate a Head of Service and one other colleague to support the Head of Service in the role going forward. Delivery of a project risk management workshop specific to the planned new primary school in Dargavel (complete) August 2023 Director of Finance and Resources Workshop delivered covering nature of project risks, risk changes over lifecycle of the project; reminder of Council PM framework and PMU support; key issues re good governance. Delivery of project risk management training with all PMU colleagues (in a train the trainer format) so colleagues are delivering this as part of project kick‐offs to support a more risk focussed culture in the organisation. September 2023 Director of Finance and Resources This was completed on 12/10/2023. PMU staff received a ‘train the trainer’ session to enable them to cover running risk awareness sessions at project kick‐offs to support a more risk focused culture in the organisation. Undertaking a ‘health check’ of project management arrangements across the council to ensure governance, management, reporting and risk management is appropriate to the scale of the project. November 2023 Director of Finance and Resources Compliance review of all PMU supported projects complete. All projects demonstrated a satisfactory level of risk governance and management. An update to the risk management course on iLearn and consideration of whether it should be a mandatory course. December 2023 Director of Finance and Resources The course if now developed and ready to be launched to relevant staff on iLearn. In addition, face to face training of a new “Who’s risk is it anyway” half day course is also being delivered in February and May. Embed and deliver risk management training into the new leadership development programme that is currently under development, particularly in relation to commercial risk December 2023 Director of Finance and Resources Session delivered 12 December 2023, and is included in the training programme for further cohorts. Page 124 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 Action Target Completion Responsible Officer Update Reviewing governance documents to ensure delegations in relation to liability caps are clear and unambiguous. December 2023 Director of Finance and Resources Consultation with Head of Corporate Governance concluded that governance documents do not require amendment, but rather, more training would be required on what was expected within existing delegations. The training was delivered to CMT on 28 November 2023. Governance refresher training sessions have been delivered to every department senior management team in January. Deliver a targeted risk management development day for Chief Officers:‐ Project risk management (and risk simulation exercise) Risk horizon scanning and sustainability (the Global Risk Report) Liability caps and their implications. December 2023 Director of Finance and Resources The training session has been prepared and was delivered to CMT on 28 November 2023. Page 125 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 Action Target Completion Responsible Officer Update It is recognised that Dargavel Village has a significant amount of housing development yet to be delivered (circa 2000 housing units over a 10 year period) and therefore many of the associated risk that existed at the beginning of the development continue to exist today albeit there is live data to inform future projections from the first circa 2,300 units that have been delivered. Manage ongoing education demand risk relating to Dargavel through: The Council therefore continues to face risk and uncertainty in relation to accurately projecting the scale and timing of future education demand which will continue to have inherent uncertainty and risk. In recognition of this the Council will continue to progress the following actions to manage and mitigate this risk:‐ Securing robust long term demand projections which provide both a core projection, potential upper scenario and a long term view of the potential scale and timing of short term peak demand to inform decisions on capacity provision. September 2023 Director of Children’s Services Further updates will be completed in this respect for updated datasets available from November registration data and recently released NRS Census data. A full learning estate projection model has been delivered by Edge Analytics in August 2024. This will directly inform this action. Identify now a range of flexible options that are and will remain available to in future years to deliver, if required additional capacity (both temporary capacity and permanent long term capacity) to ensure the Council can be reassured of being able to respond appropriately to the potential for upper end demand scenarios and or temporary demand peaks to emerge. January 2024 Based on data and a range of scenarios, flexible additional capacity options have been outlined and shared with relevant boards. Page 126 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 Action Target Completion Responsible Officer Update Establish process and arrangements to support and provide detailed monitoring and updates to projections for updates to actual data sets to facilitate a continual re‐assessment of longer term trend and likely requirements / decision point required in relation to deployment of potential additional interventions. January 2024 A schedule is in place with timelines for detailed monitoring and updates to projections and actual data. This will ensure continual re‐assessment of long term trends and likely requirements / decision points required. Work has commenced to map out the next iteration of roll projection release for 2025 with Edge Analytics. This will inform what data sets are required and set a road map and responsibility matrix for who is accountable for obtaining and collating each data set or model input. This also requires input form the Head of Economy & Development to factor in the next iteration of the Housing Land Audit (HLA) to the projection model. Bowles Report Recommendation 7 Whilst protecting the integrity of the planning process, the Council needs to ensure the appropriate involvement of members in such developments. Additional Council Motion Council agrees that in light of the Independent External Review of Dargavel that there is a requirement to convene a cross party body to discuss and review existing governance arrangements of Renfrewshire Council. Response Objectives Assess the extent to which major investment projects have provided sufficient engagement with elected members through both formal governance routes as well as through briefing sessions, engagement sessions, group presentations, site tours etc. Identify any adjustments or improvements required moving forward. Provide officer support to a cross party group to of elected members to agree the remit and progress a discussion and review of the Council’s formal governance arrangements in line with the motion approved. Carry out an assessment of the Audit Risk and Scrutiny Board against CIPFA’s published good practice guide for audit committees. Page 127 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 Action Target Completion Responsible Officer Update Undertake a health check assessment on major capital programmes to provide reassurance in respect to extent to which elected member involvement has been appropriately secured through formal governance reporting as well as via other appropriate informal engagement routes October 2023 Chief Executive supported by CMT City Deal and Infrastructure + housing Investment Programme Health Check report was submitted to CMT on 21 November 2023. Other programmes to be reported to CMT through regular scheduled portfolio update sessions. Support Council Leader and other nominated elected members to determine a review remit, progress the review and develop suitable recommendations. March 2024 Head of Corporate Governance The Cross Party Working Group was established and met five times. A report was submitted to the Council Meeting on 29 February 2024 setting out the findings of the review. The recommendations were agreed by Council. Carry out an assessment of the Audit Risk and Scrutiny Board against CIPFA’s published good practice guide for audit committees and identify any recommendations for change in remit or operational arrangements. December 2023 Director of Finance and Resources The self assessment is complete with recommendations for improved clarity of roles and remits agreed by the ARSB, with formal final approval agreed by Council in May 2024. Bowles Report Recommendation 8 Public confidence These recent events and the matters described in this report will dent public confidence in the Council. The Council should work in an open and transparent manner in the resolution of these issues and particularly with the residents of Dargavel, who have legitimate concerns about the implications for their children during both their primary and secondary education. Response Objectives The key aim has been to provide straightforward messaging and up to date sitreps to ensure publics (and council representatives) have the most up‐to‐date position and the complexity of the issue is explained in a simple and honest way and that parental/carer concerns in respect to the school and educational environment are able to be appropriately discussed through structured engagement arrangements with the parent councils with appropriate agreed actions taken forward. The strategy has been designed to: − Improve the flow and regularity of information to parents and carers and the wider Dargavel community, so they are first to hear about decisions impacting their community. − Ensure parents and carers have access to all projection data available to the council. Page 128 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 Action Target Completion Responsible Officer Update − Introduce direct communication channels with Dargavel residents, enabling all sections of the community to engage on matters that are important to them and making sure the latest information is accessible and easy to find. − Provide residents with a feedback loop to enable them to ask questions of the council in relation to the development and have questions answered quickly. − Include the community in formal planning and design of a new primary school and high school extension. It is recognised that effective communication and engagement is important to building a new relationship between the Council and the Dargavel community, but ultimately it will take the delivery of the solution and investment in long term engagement to reduce local anxiety and fully rebuild trust and confidence in the Council. Develop communication plan to drive tactical engagement, ensuring the Dargavel community and specifically parents and carers kept updated on progress and the decisions being made by Council Boards. November 2022 Head of Marketing and Comms The strategy has directed media and stakeholder engagement in relation to council decisions pertaining to Dargavel, the initial announcement and short‐term mitigation arrangements, and the publication of the Independent external review by David Bowles. The specific activities delivered include: Arranging and hosting two parent and carer meetings, attended by council officers and more than 220 parents or carers. Attending several parent council meetings with all primary schools and PMHS to support direct engagement, discussion on key activities, immediate estate decisions in respect to deployment of modular classrooms and post occupancy adjustments at Dargavel Primary, sharing and discussion of revised projection data and modelling, key council decision points, independent review outcomes. Attending several community meetings from community council, Community Liaison Group as well as supporting coordination and delivery of wider community representative Page 129 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 Action Target Completion Responsible Officer Update round table session to maintain ongoing engagement, sharing of information and data sharing. Updating parents and carers at Dargavel Primary on progress and all reports to Council Boards and decision making in relation to immediate solutions to address capacity issues at Dargavel/ Updating Bishopton Community Council on progress above. Responding to media enquiries, requests for interview and ensuring the media were proactively updated on progress. Ensuring the wider area stakeholders were kept up to date on progress – this includes community representatives, wider Parent Council groups and local and national politicians. Maintaining updated information on the council website Delivered a creative partnership with Glasgow School of Art and Dargavel Primary School to support pupils design the interiors of the new modular classroom block. Deliver a revised comms and engagement strategy to coincide with the return to school period along with timing of key milestone points in relation to post independent review and moving towards confirmation of progress with BAE systems and moving more significantly into a delivery phase. This will ensure long term engagement process continues to build pro‐active and positive engagement to continue to re‐establish trust and confidence across the Dargavel community. August 2023 Head of Marketing and Comms Action Completed. The Dargavel communication and engagement strategy was implemented in October 2022 and reviewed and following the publication of the Bowles Report. The strategy covers engagement throughout the development of long‐term solutions to increase primary and secondary capacity. The strategy: Improves the flow and regularity of information to parents and carers and the wider Dargavel community, so they are first to hear about decisions impacting their community. Ensure parents and carers have access to all projection data available to the council. Has introduced new direct communication channels with Dargavel residents, enabling all sections of the community to engage on matters that are important to them and making sure the latest information is accessible and easy to find. Page 130 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 Provides residents with a feedback loop to enable them to ask questions of the council in relation to the development and have questions answered quickly. Includes the community in formal planning and design of a new primary school and high school extension. Establish a new parent council liaison group to provide a single PC forum (at the request of PC chairs) to provide a streamlined opportunity for consistent engagement and communication with the whole PC community for all schools associated with Dargavel / Bishopton and PMHS and all feeder primaries. August 2023 Head of Education Group has been established and has met following school summer 2023 break with positive feedback from Parent Council Chairs with engagement to date. Establish regular opt‐in digital community newsletter to facilitate regular communication updates direct to interested members of the community. August 2023 Head of Marketing and Comms Action completed. The opt‐in digital newsletter is live. Establish and track key indicators of community sentiment. Ongoing Head of Marketing and Comms The council has an established communication and engagement strategy directing communication and community engagement in relation the delivery of increased school provision for the Dargavel community. New channels of regular communication have been established with the community and the effectiveness of those channels is regularly assessed. The statutory consultation process was assessed by The Consultation Institute as showing considerable good practice. Exit surveys are provided at engagement events to test ongoing effectiveness and a variety of tools are in place to measure engagement with communications and track sentiment, including an annual pulse survey. Develop, deploy (at appropriate key points post formal consultation period) and evaluate a community pulse survey to assess and track community sentiment and view of ongoing handling and satisfaction with delivery of key interventions within the community. Sept 2024 Head of Marketing and comms A baseline survey was completed in September 2024, and will be used for future tracking. The response rate was low, but findings show almost three quarters of respondents believe they have been kept informed by the Council on Dargavel school‐related issues and 70% agree the flow and regularity of information has improved. Engagement was highest through the statutory consultation process and via attendance at public meetings. Results show that while communication is regular and useful, rebuilding trust will take time. Engagement will continue ongoing with the community as increased capacity is delivered. Page 131 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 ACCOUNTS COMMISSION SECTION 102 REPORT – FINDINGS & COUNCIL RESPONSE/UPDATE Community and Other Engagement The council must, as a matter of urgency, conduct a robust and transparent assessment of the effectiveness of its community engagement and then move swiftly to implement any improvements needed. February 2024 Head of Communications and Marketing Action completed. The council’s approach to engagement and the statutory consultation process was assessed by The Consultation Institute as showing considerable good practice. A comprehensive communication and engagement strategy is in place. Please see response to Bowles report recommendation 8 above. The Commission is particularly concerned by the council’s failure both to transparently consider alternative options in relation to expanding secondary school capacity in the area, and to consult or engage appropriately with the community, whom their decision directly affects. This engagement activity will remain ongoing as part of the PMHS extension project through to August 2027 and beyond recognising the long‐term monitoring of school roll projections at the high school. Director of Children’s Services It is accepted that the report to the Education and Children’s Services Policy Board in May 2023 could have articulated the reasons why no other options to address secondary school capacity beyond an extension to Park Mains High School were deemed viable for detailed consideration. Additionally, although engagement in relation to updated school projections and developing plans for a larger extension to PMHS were shared and discussed with the PMHS parent council prior to the May report, plans to expand this engagement process to a wider group to encapsulate all feeder primaries following the board meeting could have been outlined in the report and or considered earlier in the process. Council officers have since May 2023 been progressing positive and ongoing community engagement in relation to the Park Mains extension, principally through the Park Mains Liaison Group which was established to provide a single engagement forum with representatives from the Parent Councils of Park Mains High School and all associated feeder primaries. August 2024 This engagement process has shared and explained detailed pupil projection data, the underlying rationale for the proposed extension decision as well as listening and responding to Page 132 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 concerns and or requests for further information from the wider parent and carer community. This included sharing detailed information on an option promoted by some community representative from Dargavel and Bishopton for a new secondary school for Dargavel, Bishopton and Langbank. As reported through the Education and Children’s Services Policy Board in August 2023, such an option had significant negative implications from a financial, educational, value for money and school estate perspective that discounted it as a credible option for detailed consideration. The Park Mains Liaison Group is proving to be a highly valuable engagement forum, providing a single route of engagement across the wider community as well as a key route to assist the Council to disseminate consistent key messages and information updates across communities through trusted Parent Council communication channels. This engagement approach will inform how non statutory and informal engagement in relation to potential school estate changes and long‐term strategic learning estate work may be taken forward in the future by the Council. Additionally, high levels of positive engagement are being secured as part of the space planning process for the new extension, supporting active parental and carer participation and influence in the design process of the new extension and wider changes to the school that are planned to be delivered. This is increasingly building a positive community commitment and level of direct participation in the delivery of the school extension and improvement project. Page 133 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 Director of Children’s Services The review of the Council’s engagement strategy as referred to above will include a qualitative assessment of the effectiveness of the Park Mains Liaison Group. Lastly, work is being progressed by officers to research how other councils have approached school extension projects, where a statutory consultation process is not required. The objective of this work is to inform the design of a framework to inform any future approach to early informal engagement that can be adopted by the Council in relation to school estate considerations or changes. Desk top work completed to date has identified a mixed picture with several councils having adopted a similar approach to that employed by the Council for the PMHS extension. However, there are some examples of the use of published options appraisals as part of Council reports and identified examples of planned informal engagement strategies deployed as part of long‐term strategic school estate planning which provide some good practice approaches for reference. These individual elements of good practice that are evident across other councils can be collectively brought together and used to inform and guide the development of a proposed framework for use by the Council in its future learning estate strategy (where appropriate this will pay due regard to the Scottish Government guidance on informal engagement that may occur prior to a statutory consultation process). In completing this work consideration will be given to sharing the output across the local authority sector given what appears Page 134 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 to be a level of mixed and inconsistent approaches deployed across the country. We note that the new primary school is subject to a full public consultation. We expect the council to engage meaningfully with the community on this issue, and other decisions on the school estate. Again, we ask that the Controller monitors this situation, and reports to us in June 2024 on progress and earlier if necessary. Consultation process has completed as reported to the Education and Children’s Services Policy Board in May 2024 Director of Children’s Services The Education and Children’s Services Policy board approved the planned consultation programme in January with a report on the outcome of the consultation planned to be brought back to Policy Board in May. A full programme of planned consultation and engagement activity has been developed with input from the Institute of Consultation to bring to the design process experience of recognised best practice deployed across the UK. Full details of the planned consultation process and activity will be provided to the external auditors as well as the opportunity to observe any of the planned information events and or formal consultation meetings. The consultation has now been completed with 817 respondents to the online questionnaire and a further 150 attending the events which were held: 6 informal drop in sessions 4 Information exchanges 2 public meetings Meetings with Parent Councils of both primary schools Meetings with staff and children from both primary schools. Education Scotland also engaged with the community and produced their report of their findings. A final consultation report has been finalised and presented to the Policy Board in May 2024 with approval granted to construct a new primary school on the recommended location. Page 135 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 Learning Lessons and Building Capacity While the council’s initial response to the Bowles report was high level, we are assured by the Controller that its action plan in response is now sufficiently detailed and includes SMART objectives It will be important that this action plan is well‐managed by senior officers and closely scrutinised by elected members of the council. Complete Director of Finance and Resources This action plan and subsequent action plan relating to the s102 report are closely monitored and reported to each cycle of the Audit, Risk & Scrutiny Board. However, there are still significant uncertainties relating to the capacity needed in the long term, and to the completion of the two building projects – the new primary school and the secondary school extension. We therefore request that these matters are closely monitored in the annual audit work, and the Controller uses her powers to report any slippage or other issues to us if necessary. March 2024 Director of Children’s Services Managing the Risk of Future Capacity Uncertainty The inherent uncertainty in relation to long term (15 year) pupil growth projections has been widely reported by the Council over the past year as an ongoing risk through both formal board reports, as well as engagement and communications with communities and in sharing data and reports with the external auditors. This is particularly recognised by the Council in the context of Dargavel Village having approximately 10 years of development still to deliver before achieving completion. It has also been trailed that the Council’s projection work to date with Edge Analytics has identified an expectation of a peak in demand to be reached which will then fall to a stabilised long‐ term level of demand – a similar pattern of demand growth has been evidenced across other similar long term community growth areas in the UK. The Council will regularly monitor actual pupil numbers and update long term projections on a regular basis over coming years as a key response to being able to pro‐actively manage this risk moving forward. Page 136 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 This monitoring process will be key to assess the extent to which actual demand and revised projections is or is not tracking against the current projections that have informed the planned capacity levels that will be delivered by the current learning estate interventions and provide early indication of any risk of material deviation. The planned annual monitoring and updating approach that will be deployed over coming years will be shared with the External Auditors as required. Long term projection work completed to date has already modelled a range of potential demand scenarios for the primary sector and identified an expected peak of demand in 2033/34. Options that can be considered for deployment in future years to manage upper demand scenarios that would exceed the planned capacity being delivered for primary sector education within Dargavel village, have already been identified and reported through the Education and Children’s Services Policy Board in November 2023 and shared with community representatives. Should the monitoring arrangements over the coming years highlight projection of sustained demand trending towards the upper demand scenarios, an appraisal will be required to assess which of the options is most appropriate for consideration to be deployed to meet the scale and nature of the additional future demand. This process will include early community engagement with school communities and will require timely assessment and associated decision making to allow planned delivery of any additional intervention well ahead of the developing need. In relation to the secondary sector, the impact of higher demand scenarios will take longer to emerge (mid to late 2030s) and similarly it has been well trailed in Council reports and with Page 137 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 the community that long term monitoring and projection modelling may identify the need to consider options at an appropriate future point in time in respect to any further intervention and or decisions in relation to secondary sector provision across West Renfrewshire. Similarly, the long‐term monitoring arrangements will facilitate early identification of such risks and will support early engagement with the appropriate primary and secondary schools that may be impacted by any future school estate changes. Annual update in relation to all modelling projections has been reported to the Education and Children’s Services PB in October 2024 as part of a report covering the whole school estate – this action is now complete and will form part of the business as usual Schools Estate Strategy work. Delivery of New School Facilities It has been recognised by the Council that as a result of the very late identification of the significant under‐capacity problems within both the primary and secondary sectors serving Dargavel, the Council has since late 2023 been operating within a highly compressed non‐typical timeline to undertake all the associated capacity planning, land assembly, community engagement, statutory consultation, space planning, procurement arrangements before moving into project delivery in order to achieve operational delivery of the new facilities by August 2027. In broad terms, the Council is seeking to achieve all that is associated with the long‐term strategic planning, engagement, consultation and operational delivery of a new school and major extension of a secondary school in a 4 ½ year period, when such an end‐to‐end process would normally run over a much longer period – a timeline of around 6‐8 year would not be an untypical Page 138 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 period of timeframe. Consequently, the Council is parallel running several activities that would in most circumstances be delivered in a broadly consecutive manner. The Council has established governance, programming, and resource arrangements in place to support the delivery of the new primary school and secondary school extension over the remaining 3 ½ year period through to the operational target date of August 2027. To date the external auditors have not undertaken any detailed scrutiny of the delivery programme or the arrangements in place. To provide assurance officers will provide a full overview of the current arrangements for the external auditors for their review and will support whatever audit work is required to allow them to assess the Council’s current approach. Impact on Service Provision We note that the council has assessed that currently there has been no detriment to either teaching delivery or pupil education in the Dargavel and Bishopton areas from the interim measures introduced. We consider it critical that the council reports the results of these assessments publicly, regularly and in an accessible way, to maintain and rebuild community confidence. Ongoing as part of the Service’s Quality Assurance Framework Ongoing and will be incorporated into parent and school Director of Children’s Services Head of Marketing and Communications Renfrewshire Council has a robust Quality Assurance framework involving regular meetings with Education Managers and school staff and planned school visits which focus in on the national quality assurance indicators (reviews). DPS had a visit in January as part of this process where key strengths under the national Quality Assurance indicators from How Good is Our School were evaluated, self‐improvement and self‐evaluation and Learning, Teaching and Assessment and a report was produced. In addition, Bishopton Primary School and Park Mains High School were both recently inspected by HMI, receiving very positive reports. Page 139 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 newsletters at appropriate points. Further, every school submits a school improvement plan and a school improvement report (published on website) and their evaluations under the 4 key Quality Indicators (QIs) of their performance, based on data gathered through self‐evaluation, HMI visits, internal visits and stakeholder input is submitted to Children’s Services in April. These are shared with the parent councils and will also be published on the school website as part of the self‐evaluation process. This is in line with Education Scotland guidelines, the National Improvement Framework and statutory requirements. This communication with parents will be an ongoing process. The Commission is also concerned at the possible wider impacts of the council’s failings regarding the estimation of pupil numbers and whether this has had any impact on services provided by the council in the Dargavel area. We request that the Controller seeks further information on these issues so that we can understand the work that the council has done to understand these impacts. In line with requests emerging from defined audit programme to be set by Azets Chief Executive Full details of all the additional areas of potential service impact (noted below) considered by the Council have been shared and discussed in detail with the External Auditor to support the Controller of Audit’s follow‐up report to the Accounts Commission. Support to Schools Early Learning & Childcare Provision Children’s social Care support NHS Service Provision & facilities Community Leisure & Recreation within wider Masterplan Transport & Active Travel Infrastructure Provision Public Bus Transport Provision Page 140 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 Financial Management and Consequences The financial impact of these failings on the council is significant. The council capped the risk and contributions from BAE Systems under the Section 75 agreement, and as a direct result faces estimated net additional capital costs of £60 million, to be met by borrowing. This is a substantial sum of public money. The council needs to clarify the opportunity costs of this in terms of its overall capital programme. The council projects that it will have a revenue budget deficit of up to £50 million by 2026/27 and will need to make difficult decisions on prioritising its spending, compounded by the financial consequences of this issue The council has recently negotiated a transfer of land from BAE for the construction of a new primary school. The Controller’s report indicates that this was in exchange for amendments to the extent and composition of the housing units for which planning permission has been granted. Given the reported determination of BAE to fully protect their commercial interests in the development, and the absence of alternative solutions for the council, it will be important to ensure and demonstrate that this exchange represents Best Value for the public purse. Ongoing March 2024 Director of Finance and Resources Head of Economy and Development The Council will be required to manage the financial impact of the unplanned delivery of a new primary school and larger extension at PMHS through the delivery of its wider financial strategy and any opportunity costs articulated as part of developing and delivering that strategy. Regular reports with regards the Council’s financial position and outlook are provided to Council, which include the financial consequences of the Dargavel failings. The next report to Council updating the financial outlook will be in September 2024. The financial and wider factors considered by officers as part of the negotiation process with BAE systems to secure the associated land agreement and adjustments to the S.75 agreement have been shared with the external auditors. Council Leadership, Governance, and Culture The council’s action plan will be hugely important in further embedding improvements in this area. In particular, the following elements must be progressed urgently and transparently: February 2024 and ongoing in relation to the outcomes Director of Finance and Resources This report and combined action plan provides the Audit, Risk & Scrutiny Board with an overarching view of all progress associated with the Dargavel issue, subsequent investigations, reviews and agreed actions. Page 141 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 the council’s review of its scrutiny arrangements against CIPFA good practice guidelines the council’s review of its approach to risk management the council’s leadership development programme for officers. To be satisfied of progress in these areas, the Commission requires the Controller to request further information from the council on the scope and timing of these actions, and report back to the Commission in the update requested for June 2024, or earlier if she thinks necessary. We also expect these issues to be covered in the accelerated Best Value report. associated with each action. The Commission is also concerned about the culture of the council and whether it has truly learned the lessons it needs to. We expect organisational culture to be an area of focus in the accelerated Best Value report. In particular, we request an update on whether the culture of the organisation is appropriately open and transparent, encourages continuous improvement, December 2024 (ie the confirmed timescale for BV audit work to conclude) Chief Executive The Council’s auditors concluded that the Council has appropriate governance arrangements in place with improvements over the years in member and officer relationships and effective leadership overall and were satisfied through their detailed audit work that the Council had demonstrated that the governance failings identified by the Bowles report were limited to the historic handling of Dargavel. The auditors did not highlight any concerns over the wider organisational culture in the Council or in its approach to managing major capital programmes but did identify that the role of the Audit, Risk and Scrutiny Board in ensuring effective scrutiny is not sufficiently clear. The Council has recognised this and has completed a review of the Audit, Risk and Scrutiny Board governance and operating arrangements, with recommended changes being agreed by the Board and subsequently by full Council. Page 142 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 effective joint working between officers and members, effective scrutiny and challenge (especially by elected members), and engagement and discussion with stakeholders. In addition, we request an assessment of whether it has the right skills in the right places to deliver on its responsibilities, and whether issues are escalated to the right level. Despite the finding of the Council’s auditors, the Commission has expressed concern in relation to the Council’s culture and have sought further assurances in relation to a wide range of organisational issues. It has been confirmed that consideration and assessment of such issues will form part of the planned Best Value Audit process and subject to confirmation of the planned detailed best value audit programme. Council officers will provide all the necessary support, assistance, and information to allow the audit team to appropriately assess all key areas of interest and are actively progressing an internal self‐assessment and evidence process to support this element of the audit engagement in due course over the anticipated 2024/25 audit programme. Finally, the Commission notes that the auditor has concluded that the council has obtained appropriate external legal advice and determined there is no potential for any form of action against former senior employees involved in the Dargavel School decision‐making. In addition, no disciplinary action has been taken against any senior officer involved in decision‐making relevant to the Section 75 approval process for the Dargavel Village development. The Commission accepts that these are management issues. March 2024 Head of Corporate Governance No senior officers involved in the Dargavel S.75 decision making process and identified in the Bowles Report remain employed by the Council or remained employed at the time of the Bowles report publication. In this context no senior officer could be subject to any form of internal Council disciplinary investigation or action. Full details of the process of consideration and legal advice that was sought regard to any other form of external legal action has been shared with the local external audit team as requested by the Commission. Page 143 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 However, we request that the Controller asks the council for further information on the process followed and factors taken into account by the council in considering disciplinary action against staff involved. In addition, and looking forward, the Commission asks for information on the council’s approach to performance management and March 2024 Head of HR & OD A full package of information in relation to current HR policies and procedures and future planned revisions has been provided to the external auditor. In June 2024, the Council in consultation with key stakeholders and trade unions revised both its people, performance and talent policy and discipline policy. Additional guidance and training is currently being developed for managers and employees, with an expected role out in the Autumn 2024. its current policy on disciplinary action, so we can be assured that appropriate arrangements are in place to ensure that staff have the necessary skills and that senior officers are properly accountable for their areas of responsibility. Page 144 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 CROSS PARTY WORKING GROUP AGREED ACTIONS Refresher training for management teams across all of the Council’s directorates on the operation of delegated authority should be implemented. April 2024 Head of Corporate Governance and Chief Auditor Training was delivered to all directorates by the Head of Corporate Governance and the Council’s Chief Auditor in January 2024 to Chief Officers and tier 3 managers. A further “catch up” session was held on 23 April 2024. Refresher training for management teams across all of the Council’s directorates on the operation of the Protocol for Relationships between Political Groups, Elected Members and Officers should be implemented. That the Bulletin be issued with the minutes of each Council and board meeting for the meetings of Full Council. May 2024 Head of Corporate Governance The Bulletin is now issued with the minutes pack at each Full Council Meeting commencing with the meeting of 9 May 2024. All major projects and programmes will report to the appropriate board at least twice a year. Any such reports will include a note of all project groups involved. May 2024 Chief Executive Update reports on City Deal Projects and cultural Infrastructure programmes have gone to boards in December and February respectively as part of twice yearly reporting cycles. Housing investment programme update provided as part of update report at each cycle with an additional full update provided in august of each year. The content of the Protocol for Relationships between Political Groups, Elected Members and Officers be refreshed. February 2024 Head of Corporate Governance The Revised Protocol was approved at the Council Meeting of 29 February 2024 A health check of all major projects will be completed and reported through the Audit, Risk and Scrutiny Board March 2024 Chief Executive This has separately been reported to the ARS Board as part of the independent review action plan A structure chart for all Council directorates should be prepared and circulated to all Elected Members. This should be regularly updated and recirculated as necessary. March 2024 Chief Executive The structure chart was circulated to all Elected Members, and the first updated version was issued in March That a Chief Planning Officer report brought to the Planning and Climate Change Policy Board at least twice a year advising on the position in respect of s75 Agreements. Planning applications, or where officers cannot not reach agreement May 2024 Head of Economy and Development Arrangements have been put in place by officers for this bi‐ annual reporting Page 145 of 146
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APPENDIX Action Plan Response Monitoring (Completed Items) – November 2024 on substantive matters in a specific s75 Agreement negotiation will also be brought back to the Board for further consideration. The outcome of the management training programme will be reported to the Audit, Risk and Scrutiny Board Sept 2024 Director of Finance and Resources and Head of HR & OD The evaluation of Cohort 1 (Chief Officers) has been completed and feedback presented to the Council’s Corporate Management Team. Generally, the feedback from this cohort indicated a high level of satisfaction with the programme overall. Collaboration with other colleagues during the programme featured strongly with learning through shared experiences. There was positive feedback around learning from colleagues, strengthening networks across services and shared experiences, which will create consistent approaches around best practice. Some feedback was received around the content being more ‘Renfrewshire’ specific, including organisational challenges and use of case studies. Cohorts 2&3 have recently completed their training and are in the process of being evaluated. Page 146 of 146