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Renfrewshire Council · 13 June 2022
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___________________________________________________________________
To: Audit, Risk and Scrutiny Board
On: 13 June 2022
___________________________________________________________________
Report by: Chief Auditor
___________________________________________________________________
Heading: Internal Audit Annual Report 2021 - 2022
___________________________________________________________________
1. Summary
1.1  The Public Sector Internal Audit Standards require the Chief Auditor to
prepare a report, at least annually, to senior management and the Board on
the internal audit activity’s purpose, authority, and responsibility, as well as
performance relative to its plan. 
1.2  The annual report must also provide an annual audit opinion on the overall
adequacy and effectiveness of the Council’s internal control environment and
include details of any significant risk exposures and control issues, including
fraud risks, governance issues, and other matters that can be used to inform
the governance statement. 
1.3  The Annual Report for 2021-22 is attached and outlines the role of Internal
Audit, the performance of Internal Audit, the strategic and operational issues
which influenced the nature of the work carried out, the key audit findings, and
contains the annual audit assurance statement.
___________________________________________________________________ 
2. Recommendations
2.1 Members are invited to consider and note the contents of the Annual Report. 
___________________________________________________________________

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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 
________________________________________________________________
Author Karen Campbell – 07768354651

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Annual Report 
2021-2022 
Renfrewshire Council
Internal Audit 
May 2022

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Renfrewshire Council 
Internal Audit Annual Report 2021/2022 
Contents 
Page 
1.    Introduction  1-2 
2.    Responsibilities of Management and Internal Audit  2 
3. Internal Audit Activity in 2021/22  2-4 
4.                                                                          Summary of Internal Audit Work    4 
5.  Internal Audit Resources  4 
6.  Review of Internal Audit Activity 
• Table 1 – Analysis by category of audit 
4-6 
7.    Quality Assurance and Improvement Activity 
• Table 2 – Internal Audit Performance 
6
8. Implementation of Audit Recommendations 
• Table 3 – Implementation of Audit Recommendations 
6-7
9. Performance of Non-Audit Activities
• Table 4 – Corporate Counter Fraud Performance
7-8 
10.  Audit Assurance Statement  8-9 
Appendix 1 – Summary of Assurances

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Renfrewshire Council 
Internal Audit Annual Report   
1 April 2021 – 31 March 2022 
1. Introduction 
1.1 Internal Audit is an independent and objective assurance and consulting activity
designed to add value and improve the operations of Renfrewshire Council. It
assists Renfrewshire Council in accomplishing its objectives by bringing a
systematic and disciplined approach to evaluate and improve the effectiveness
of the organisation's risk management, control, and governance processes. 
1.2 The Chief Auditor reports functionally to the Audit, Risk and Scrutiny Board and
administratively (i.e. day to day operations) to the Director of Finance and
Resources. In accordance with the principles of good corporate governance,
regular reports on internal audit work and performance are presented to the
Audit, Risk and Scrutiny Board. 
1.3 The purpose, authority and responsibility of the internal audit activity is defined
in the internal audit charter, approved by the Audit, Risk and Scrutiny Board;
and provides that the Chief Auditor has independent responsibility for the
conduct, format and reporting of all internal audit activity and findings. 
1.4 The service operates in accordance with the Public Sector Internal Audit
Standards (PSIAS). The Standards define the basic principles for carrying out
internal audit. They establish the framework for providing internal audit
services, which add value to the organisation, leading to improved
organisational processes and operations. 
1.5 The Standards require the Chief Auditor to prepare a report, at least annually,
to senior management and the Board on the internal audit activity’s purpose,
authority, and responsibility, as well as performance relative to its plan. The
annual report must also provide an annual audit opinion, on the overall
adequacy and effectiveness of the Council’s internal control environment. It
must include details of any significant risk exposures and control issues,
including fraud risks, governance issues, and other matters that can be used to
inform the governance statement.   
1.6 The aim of this report is to provide an opinion on the overall adequacy and
effectiveness of the council’s framework of governance, risk management and
control and provide a summary of the work undertaken during the year to
support that opinion.  The report also provides details of the performance of the
internal audit service during the past year, and the results of the quality
assurance and improvement programme.
1.7 In addition to the work carried out in relation to council services, we also provide
an internal audit service to the following organisations:

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• OneRen
• Renfrewshire Valuation Joint Board
• Scotland Excel
• Clydeplan
• Renfrewshire Health and Social Care Partnership – Integration Joint
Board 
1.8 The outcome of the audit assignments undertaken for these organisations is
reported separately as part of their annual report which also contains an
assurance statement to their Boards. 
2. Responsibilities of Management and Internal Audit 
2.1 It is the responsibility of the Council’s managers to ensure that the management
of the areas under their control is adequate and effective and that their services
have a sound system of internal control which facilitates the effective exercise
of the organisation’s functions and which includes arrangements for the
management of risk. 
2.2 Internal audit is not a substitute for effective control exercised by management
as part of their responsibilities. Internal audit’s role is to independently assess
the adequacy of the risk management, internal controls and governance
arrangements put in place by management and to undertake sufficient work to
evaluate and conclude on the adequacy of those controls for the period under
review. 
3. Internal Audit Activity during 2021/2022 
3.1 The internal audit plan for 2021/2022 was approved by the Audit, Risk and
Scrutiny Board on 22 March 2021.   The plan was risk-based and took into
account the outcomes of the service and corporate risk evaluation processes,
any significant changes in council operations over the period, and the impact of
developments in national policy and regulation.  The plan also took into account
key external audit reports including their Annual Audit Plan for the council.   
3.2 The continued restrictions arising from the pandemic and the changing risk
profile of the council and the reduction in resource for part of the year due to
unplanned absence necessitated that the audit plan was kept under continuous
review throughout the year.  It should be noted the working environment
throughout this year has led to some audits either requiring additional time from
our contingency budget or taking a bit longer to complete.  The planned review
of administration of medicines in schools was deferred until 2022/23. In
addition, at the request of Service Senior Management three further reviews
were undertaken during the year and have been reported upon:- 
a) Billing, Collection and Accounting of Levies by the Council
b) PVG Checks and Cleanliness in Schools
c) Electronic Payments to Children Services Locations

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3.3 All other planned work as detailed in the 2021/2022 audit plan has been
undertaken or commenced and those assignments not finalised by 31 March
2022 have been prioritised in the first quarter of the current year. 
3.4 Set out below are the significant risks which influenced the content of the plan
and the nature of the work undertaken in recognition of these.   
(1) Financial Sustainability 
The council is continuing to face significant financial pressures in the medium
and long term. Consequently, the financial sustainability risk remains very high
and continues to be subject to significant and regular scrutiny. The council’s 
transformational change programme to deliver service delivery and savings
recommenced during this year. Work undertaken during 2021/22 included:
• Reviews of budgetary controls across all services, council tax
collection procedures and void processes were completed 
• Planned reviews of overtime payments and creditor payment
processing have commenced and will be completed early in the
2022/2023 audit year. 
(2) Economy 
The coronavirus pandemic has resulted in significant challenges for businesses
to remain as going concerns and for individuals to be financially sufficient during
periods of self isolation.The Scottish Government has made funds available,
which have been administered by the Council in the form of business grants
and support payments to individuals. A review of the arrangements for paying
and accounting for those business support grants was completed to ensure the 
controls in place were sufficient.  Corporate Counter Fraud continued to
undertake work in relation to potential and actual fraudulent grant activity and
support payments and are continuing to liaise with the police on those cases
where necessary. 
(3) Organisational Resilience 
Business continuity planning is crucial to our ability to provide services, and
those services are increasingly heavily reliant on digital systems.  A review is
therefore being undertaken to ensure services business continuity plans are
sufficient and realistic in terms of recovery. 
(4) Asset Management 
Physical assets of the Council required to be efficiently managed to avoid
financial, physical and reputational risk for the council.  During this year we
reviewed Council’s Winter Maintenance Procedures and also the safety checks
in place in high rise housing stock. Reviews are currently ongoing on the
controls in place over Streetscene equipment and to ensure that the required
statutory inspections are being undertaken within Council Buildings. 
(5) Brexit

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The Council continue to monitor the impact of Brexit and implement any
required changes to our duties.  As this work is ongoing no specific internal
audit work was undertaken during the year. 
3.5 In line with the council’s procedures, instances of suspected theft, fraud or other
irregularity are reported to internal audit.  Depending on the nature of the
allegations, they are investigated either by the internal audit service or by the
Corporate Counter Fraud service. All referrals were evaluated and investigated
as appropriate.  Both Corporate Counter Fraud and Internal Audit undertook
work in relation to potential and actual fraudulent grant activity and are
continuing to liaise with the police on those cases referred to them. 
3.6  During 2021/22, Internal Audit conducted a number of investigations in relation
to employee conduct and service management has undertaken disciplinary
procedures and strengthened internal controls where necessary. 
3.7 The outcomes of all internal investigation reviews are reported to the Audit, Risk
and Scrutiny Board. 
3.8 The Corporate Counter Fraud team workload during 2021/22, involved mainly  
investigating matches identified by the national fraud initiative. 
4. Summary of Internal Audit Work
4.1 The internal audit team has been working on a hybrid basis, mainly from home.
The team also provided advice and support where necessary to council
services. 
4.2 Appendix 1 details the assurances arising from the internal audit work carried
out in line with the 2021/22 audit plan and from those 2020/21 assignments
which were finalised during this year which supports the annual assurance
statement.  These include the conclusions in relation to the overall system of
internal control, risk management and governance arrangements. 
5. Internal Audit Resources 
5.1     For the year to 31 March 2022, the audit plan was based on an establishment
of 6.00 full time equivalent employees plus 100 days to be provided from other
service providers and a trainee. However, the actual staffing complement was
reduced due to higher than anticipated unplanned absence and as a result of
the Covid19 pandemic. No audit engagements were outsourced as was
planned. 
6. Review of Internal Audit Activity 
6.1     The Audit Plan for 2021/22 set out our risk-based plans across a range of audit
categories, the results of which have been reported quarterly to Audit, Risk and

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Scrutiny Board. Table 1 below compares the actual days spent on each
category of audit work against that planned for the year.   
Table 1 
Type of Audit Planned
Days
Actual
Days
Variance
Days %
Governance 81 52 (29) (35%)
Assurance 428 332 (96) (22%)
Contingency 344 336 (8) (2%)
Audit Planning & Reporting 119 114 (5) (4%)
Total Operational Days 972 834 (138) (14%)
Training  62 33 (29) (47%)
Strategic Management  22 6 (16) (72%)
Team Administration 90 89 (1) (1%)
Development 80 46 (34) (42%)
Total Non-operational Days 254 174 (80) (31%)     
Gross Available Days 1226 1008 (218) (17%)
Operational % 79% 82.9%  
Non-Audit – Including
Management of Risk
Management and Insurance and
Corporate Counter Fraud
including the co-ordination of
NFI
107 110 3 3% 
6.2 Material differences (over 20% and over 20 days) from the plan are explained
below: 
1) Governance                                                                                                              
The planned review of administration of medicines in schools was deferred until
2022/23 due to the planned implementation of a revised policy. 
2) Assurance 
Due to the higher than planned absence levels, no work being outsourced and
the level of contingency work, the completion of some 2021/22 assignments
have been carried forward in 2022/23. 
3) Training 
Planned training activity did not take place due to Covid restrictions and home
working arrangements. These are planned to go forward in 2022/23. 
4) Strategic Management and Development

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As a result of the Covid Restrictions and unplanned absence levels, the external
quality assessment of the internal audit service was delayed until 2022/2023. 
7. Quality Assurance and Improvement Activity 
7.1 Internal audit measures performance against a range of measures set annually
by the Director of Finance and Resources. The Audit, Risk and Scrutiny Board
received quarterly reports on progress and performance during the year. Table
2 shows the actual performance against targeted performance for the year. 
Table 2 
Internal Audit Performance 2021/22 
Performance measure  Target 2021/22 Actual 2021/22
% completion of audit plan for the year* 95% 92.1%
% engagements completed by target
date
95% 98.4%
% engagements completed within time
budget
95% 96.8%
* this measures the completion percentage as at 31 March.  100% of the plan is ultimately delivered through the
finalisation of the outstanding elements in the new financial year.  
7.2 The percentage completion of the audit plan is slightly below the target set for
the year.  This was due to the level of unplanned leave. The actual performance
for the year for the two other indicators, is above the target performance level. 
7.3 The Chief Auditor is required to develop and maintain a quality assurance and
improvement programme that covers all aspects of internal audit including
conformance with the PSIAS. The review did not identify any areas of non-
conformance that require to be addressed. 
7.4 External Audit’s review of the internal audit service concluded that overall the
service operates in accordance with the PSIAS. 
8.  Implementation of Audit Recommendations 
8.1 During 2021/22, 150 recommendations were followed up, with 82% of all
recommendations being completed. The implementation status of the
recommendations across each service area is detailed in Table 3 below. 
Table 3 
Implementation of Audit Recommendations 2021/22
Service No.
Followed up
Complete Partially
Complete
(new date)
Not
Implemented
(new date)
Redundant
Adult Services 8 7 (88%) 1 (12%) 0 0

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Chief Executive’s 21 10 (47%) 9 (43%) 2 (10%) 0
Children’s Services 12 9 (75%) 2 (17%) 1 (8%) 0
Environment &
Infrastructure 38 37 (97%) 0 1 (3%) 0
Finance &
Resources 67 56 (84%) 7 (10%) 2 (3%) 2 (3%)
Communities &
Housing  4 4 (100%) 0 0 0
Total 150 123 (82%) 19 (13%) 6 (4%) 2 (1%) 
9. Performance of Non-Audit Activities 
9.1 Risk Management 
The responsibility for co-ordinating risk management and insurance activity
across the council lies with internal audit.  Risk management performance is
detailed in the risk management annual report. 
9.2 Corporate Counter Fraud 
The Corporate Counter Fraud team report to the Chief Auditor, during 2021/22
the team worked mainly from home.  The aim of the team is to raise awareness
to promote an anti-fraud culture and investigate instances of suspected fraud
against the Council, such as council tax reduction fraud, tenancy fraud and
other corporate fraud.  Our working practices were revised in order to protect
the health of residents and staff during the pandemic, including contacting
individuals, where possible, by telephone or e-mail rather than face to face visits
and this has worked well for cases with a lower monetary value. For cases,
where it is possible that a referral could be made to the Procurator Fiscal,
interviews under caution resumed during the year.   
The joint working arrangements with the DWP in place to investigate potential
high value fraud cases which involve both benefits payments and council tax
reduction, recommenced in the last quarter of the year. 
Table 4 
Corporate Counter Fraud Performance 2021/22
Financial Outcomes 2021/22 (£)
Cash savings directly attributable
to preventative counter fraud
intervention (e.g business grants)
426,600.00 
Cash recoveries in progress
directly attributable to counter
fraud investigations
181,281.59
Notional savings identified through
counter fraud investigation, (e.g.
housing tenancy and future
council tax)
434,708.04

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Housing Benefit Savings identified
through other counter fraud work
or through joint working with the
DWP
40,310.52
Non-Financial Outcomes 2021/22 
Housing properties recovered 4
Housing applications
amended/cancelled
10
Blue badge misuse warning letters
issued
13 
9.3 The National Fraud Initiative 
The National Fraud Initiative (NFI) in Scotland is a counter-fraud exercise led
by Audit Scotland and overseen by the Cabinet Office for the UK. It uses
computerised techniques to compare information about individuals held by
different public bodies, and on different financial systems that might suggest
the existence of fraud or error. 
Internal audit is responsible for the co-ordination of the exercise which is
undertaken every second year. The Council’s data, as required by the NFI, was
submitted in October 2020, the resulting matches were received in January
2021 and investigation of those matches was progressed throughout this year
by Corporate Fraud and Council Services. The final outcomes arising from the
exercise will be subject to a separate report to the Audit, Risk and Scrutiny
Board during 2022/23. 
10. Audit Assurance Statement 
10.1 Internal audit has performed its work in accordance with the role defined in
paragraph 1.4.  The audit work performed has been reported to senior
managers and where areas for improvement in internal control have been
identified appropriate recommendations have been made and accepted for
action by management.   
10.2 In view of the continued challenges common to all local authorities, the Council
recognises the need to exercise very close scrutiny over financial management
and compliance with overarching governance arrangements and will continue
to take appropriate action to further strengthen control in these areas.  
10.3 Internal audit contributes to the promotion of sound corporate governance in
the Council. The scrutiny function within the council performed by the Audit
Panel and the Audit, Scrutiny and Petitions Board further demonstrates strong
commitment in this area. 
10.4 It is not feasible for the system of internal control in the Council to be without
any weakness.  It is important to balance the risks involved in accepting
systems limitations with the consequences if a problem emerges. Internal audit
recognises this and assesses this in its reporting mechanism.

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10.5 The audit plan is always intended to be flexible and contingency time was
utilised to undertake additional work on areas of emerging risk.   Additionally,
the gross operational days were reduced by 14% due to unplanned absence 
and no audit engagements were outsourced as was planned due to the
pandemic . In this context, it is considered that reasonable assurance can be
placed upon the adequacy and effectiveness of the Council’s internal control,
risk management and governance arrangements, as evidenced by:-  
(i) the results of the planned audit work in 2021/22;
(ii) the results of investigative work in 2021/22;
(iii) management self assessment of internal control, risk management and
governance arrangements;
(iv) management action to respond to audit recommendations to mitigate the
risks areas highlighted in this report;
(v) the regular review of the Local Code of Corporate Governance.   
Signed         
Assistant Chief Auditor 
Date          13 June 2022

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Appendix 1
1
Audit Engagement Risk Area Assurance Level Conclusion
Payments to Care
Homes
Assurance Reasonable • The audit has identified that financial assessments and
payments to care homes were calculated correctly.
However, it identified that signed payment schedules
are not always being returned timeously by care homes
and also that there was outstanding information which
was delaying the completion of financial assessments.  
Events Management Assurance Reasonable • The events programme is adequately supported by
appropriate event manuals which are based upon
regulation and official published guidance.
• Additionally, based on the information provided and the
analysis of hours worked to ensure that events are
delivered safely and successfully, it is clear that
employees have been working excessive extra paid and
unpaid hours to fulfil the events programme and this
required to be addressed.  
Document Solution
Centre
Assurance Reasonable • The audit has identified that stock is held in a secure
location and that DSC staff promoted use of their
services to a number of specific service areas
Consideration should be given to wider promotion of
DSC services to all areas of the Council. 
• Some recommendations for improving the charging
process and in relation to the procedure for apportioning
the year end under/overspend were made.
Management of ICT
Systems
Governance Reasonable • The audit review highlighted that there is an adequate
system in place in relation to the centralisation of
software applications backed by individual Support
Models. Some annual reviews had not taken place
timeously, however action has been taken to address
this issue and a recommendation has been made to
make the process more robust. 
Business Support
Grants
Assurance Substantial • Business grant payments were made in line with
documented procedures. Roles and responsibilities for
decision making, escalation and dispute resolution were

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Appendix 1
2
clear. Grant costs were monitored and appropriately
reported.
Memorial Safety Assurance Limited • Procedures have been prepared for the inspection of
memorials to ensure that unsafe memorials identified
are properly dealt with to prevent accidents 
• It was a major concern that at the time of the audit
review only around 4% of Renfrewshire memorials had
been inspected in cemeteries. In addition, there were
only 2 members of staff who were currently undertaking
these inspections. Whilst it is acknowledged that
memorial inspection work was interrupted by events as
a result of the COVID 19 pandemic, it is vital that plans
and resources were put in place to complete this
exercise as soon as possible and management agreed
to do this
Payroll Assurance Reasonable • Although there is a Salary Adjustment Policy in place,
recovery action does not always strictly comply with
the policy and recommendations were made to
strengthen controls in this area.  
• There are satisfactory arrangements in place to ensure
that employees and managers are aware of their
responsibilities in relation to payroll processing and
salary overpayments. 
• The introduction of monthly overpayment reports to
services to inform them of employee overpayments
has enabled services to address any issues that may
lead to further overpayments. A dedicated team has
been established to concentrate on overpayment
recoveries.  
Capital Expenditure Assurance Reasonable • Contracts were awarded only where there was sufficient
capital funding available and the financial implications of
the contracts awarded were fully detailed on Board
reports. It was recommended that standardised
business case templates should be used for all capital
projects and Finance Business Partners should be more

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Appendix 1
3
involved in reviewing and challenging assumptions
during capital projects
Levy Processes Contingency Reasonable • The audit has identified that generally satisfactory
arrangements are in place for the billing, collection and
recording of the levy transactions. We have made
recommendations mainly in respect of the refund
process. 
Supporting
Attendance
Assurance Reasonable • The audit review identified that, the level of sickness
absence monitoring in place was found to be adequate
and that management are provided with adequate
information to ensure that the supporting attendance
policy is being followed. 
•  One recommendation was made in relation to training.
Use of Purchase
Cards
Assurance Limited • Whilst there were adequate procedures in place
covering the purchase of goods with Pcards, issues
were identified regarding compliance with areas of
these procedures such as the purchase of ICT goods
without prior ICT approval, large value invoices being
paid over multiple transactions and many card holders
having individual transaction limits of more than £2,000.
• The audit also identified many transactions that were
not approved timeously which resulted in committed
spend not being recorded in the financial ledger.
•  It was noted that the audit covered the period when
working practices were affected by covid, however it is
still expected that procedures in place should be
adhered to and any exemptions to this are approved by
Management and evidenced in backup paperwork.  
Childrens Houses
Cash Payments
Assurance Reasonable • The audit highlighted that there is a risk associated with
petty cash expenditure authorisation and the manner in
which the petty cash vouchers are completed.  In
addition, the auditor noted minor issues in relation to
types of cash expenditure and cash levels held.

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Appendix 1
4
Children’s Services
Electronic Payments
Contingency Reasonable • The process to facilitate electronic payments within
Children’s Services was introduced quickly because of
the Covid pandemic. The audit review identified some
issues in relation to processes, controls and recording
of payment information.
Budgetary Controls Assurance Substantial • The audit identified that there were clear budgetary
control roles and responsibilities for accounting staff and
budget holders. Budget holders get the information they
need from accounting staff.
• The main findings from the review were in relation to
having formal procedures i.e. an updated Budget
Holders Manual and council specific budget monitoring
procedures for accountants.
Non-Domestic Rates Assurance Reasonable • The audit identified that satisfactory controls are in place
for the billing and collection of NDR. However, the
pandemic workload had led to delays in reinstating
reviews of reliefs and the controls over refunds required
to be strengthened. 
Void Properties Assurance Reasonable • The audit identified that there are timely processes in
place to minimise turnaround of void properties and that
general repairs are instructed, performed promptly and
post inspected prior to properties being available for
reoccupation. 
• Delays were identified in the time taken to relet
properties.  While we acknowledged that this was
significantly impacted by the covid pandemic we have
recommended processes should be reviewed to
determine if the time taken allocate a property to a new
tenant can be reduced
School Cleaning and
PVG Checks
Assurance Reasonable • It is evident that during the period in question, facilities
management were under severe pressure to provide an
enhanced cleaning regime in order to enable schools to
remain open when they had significant staff shortages
due to vacancies and unplanned absence.  The new
staffing model also had to be implemented during this

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Appendix 1
5
time.  All available options were utilised to increase
capacity within the service as soon as possible to try and
alleviate the pressures and this led to the PVG
clearance oversight for a group of contract staff who
normally would not come into contact with children.
• With regards to the standards of cleanliness in schools,
the new staffing model at the time of the review was still
being embedded in and we have made some
recommendations to further enhance the management
controls in operation to ensure the standards of
cleanliness are maintained at a satisfactory level.
Housing Assurance
Statement
Assurance Substantial • Based on sample check of the evidence used to
demonstrate compliance, we would confirm that the
Council complies with the Housing Regulator
requirements of the Housing Assurance Statement.
LEADER Programme Assurance Substantial • The audit identified that satisfactory arrangements are
in place for issuing, monitoring and managing the
External Funding Applications through the LEADER
grant funding programme. 
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. 
• 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.