Democracy Spraffa

Item 11 - Appendix 1

West Dunbartonshire Council · 9 November 2022
Back to Audit Committee — 9 November 2022 and its agenda

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Page 1

Self Appraisal Checklist
Part A
for those charged with Governance Yes/No/Partly Is action Required? Who and By When
Leadership Commitment and Communication
1    Are we aware of emerging fraud risks and taken
appropriate preventative and detective action?
Yes
Yes - regular updates are received through
NAFN and CIFAS which are circulated to
relevant services within the Council.
The Internal Audit Annual Audit Plan for
2020/21 includes an allocation of resource to
undertake relevant fraud activity including
investigation of national fraud initiative
exercise and other investigations.
N/A
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
The responsibility for overseeing the NFI lies
with Internal Audit.  Internal Audit will review
all aspects of NFI for the coming 2022/2023
exercise.  A report will be presented to the
Audit Committee outlining how the Council is
engaging with the 2022/2023 exercise.
Shared Service Manager -
Audit & Fraud
February 2023
3. Is the NFI an integral part of our corporate policies and
strategies for preventing and detecting fraud and error ? Yes
The NFI is included within our Anti-Fraud and
Corruption Policy. N/A
4. Have we considered using the point of application data
matching service offered by the NFI team, to enhance
assurances over internal controls and improve our
approach to risk management?
Partly
This is not something that is actively used by
services.  This will be considered as part of
the 2022/23 NFI exercise.
Shared Service Manager -
Audit & Fraud
March 2023
5. Are the NFI progress and outcomes reported regularly
to senior management and elected/board members (eg,
the
audit committee or equivalent)?
Yes
A high level summary is provided to Audit
Committee on NFI progress and the annual
report provides more detail on areas
investigated and outcomes.
N/A
6. 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?
N/A
All required data sets are submitted.
N/A
7. Does internal audit, or equivalent, monitor our approach
to NFI and our main outcomes, ensuring that any
weaknesses
are addressed in relevant cases?
Yes
The responsibility for overseeing the NFI lies
with Internal Audit.  Internal Audit will review
all aspects of NFI for the coming 2022/2023
exercise.  A report will be presented to the
Audit Committee outlining how the Council is
engaging with the 2022/2023 exercise.
Outcomes of the NFI exercise are used to
inform potential audit areas for future annual
audit plans.
Shared Service Manager -
Audit & Fraud
February 2023
8. Do we review how frauds and errors arose and use
this information to improve our internal controls?
Yes
Outcomes of the NFI exercise are used to
inform potential audit areas for future annual
audit plans.
As part of the 2022/23 Annual Internal Audit
Plan we will carry out a review of waiting lists
to review the adequacy and effectiveness of
processes that are in place in relation to
waiting lists.
Shared Service Manager -
Audit & Fraud
March 2023
9. Do we publish, as a deterrent, internally and externally
the achievements of our fraud investigators (eg, successful
prosecutions)?
Yes
Published on website and during fraud
awareness training internally. N/A
Part B
For the NFI Key contacts and users
Planning and Preparation
1.Are aware of emerging fraud risks, eg due to Covid-19,
and taken appropriate preventative and detective action? Yes
Yes - regular updates are received through
NAFN and CIFAS which are circulated by the
Corporate Fraud team to relevant services
within the Council.
Shared Service Manager -
Audit & Fraud
Ongoing
2. Are we investing sufficient resources in the NFI
exercise? Partly
As part of the 2022/23 exercise the Corporate
Fraud team will carry out a review of dataset
owners across the Council to ensure sufficient
resources are in place.
Shared Service Manager -
Audit & Fraud
February 2023
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.
Yes
Quality checks on data are carried out
regularly. N/A
Appendix 1

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4. Is our NFI Key Contact (KC) the appropriate officer for
that role and do they oversee the exercise properly?
Yes
The responsibility for overseeing the NFI lies
with Internal Audit.  Internal Audit will review
all aspects of NFI for the coming 2022/2023
exercise. 
A report will be presented to the Audit
Committee outlining how the Council is
engaging with the 2020/2023 exercise.
Shared Service Manager -
Audit & Fraud
February 2023
5. Do KCs have the time to devote to the exercise and
sufficient authority to seek action across the organisation?
Yes
Sufficient allocation of resource for the NFI
work is included within the Internal Audit
Annual Audit Plans.  Progress reports are
submitted to Audit Committee on a regular
basis.
Shared Service Manager -
Audit & Fraud
Ongoing
6. 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
This is recognised in terms of the matches
received.  Resources for the Corporate Fraud
team's workplan are reviewed in light of the
matches received and the level of outcomes
for earlier exercises.
Shared Service Manager -
Audit & Fraud
Ongoing
7. Do we confirm promptly (using the online facility on the
secure website) that we have met the fair processing
notice requirements? Yes
This exercise has been confirmed using the
online facility in September 2022.
Shared Service Manager -
Audit & Fraud
30 September 2022
8. Do we plan to provide all NFI data on time using the
secure data file upload facility properly? Yes
Internal Audit co-ordinates the NFI exercise
and a timetable is in place to meet timescales
for data upload for the 2022-2023 exercise.
Shared Service Manager -
Audit & Fraud
November 2022
9. Have we considered using the the point of application
data matching service offered by the NFI team to enhance
assurances over internal controls and improve our
approach to risk management? Yes
This is not something that is currently used
within the Council as it attracts additional
costs and the functionality requires to be
reviewed for any enhancements offered.  This
will be considered as part of the 2022/23 NFI
exercise.
Shared Service Manager -
Audit & Fraud
March 2023
Effective Follow up Matches
10   Do all departments involved in NFI start the follow-up
of matches promptly after they become available?
Yes
Progress is monitored and followed up by the
Corporate Fraud Team. Shared Service Manager -
Audit & Fraud
Ongoing
11. 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
A full review of protocols for all services has
been carried out by Internal Audit to ensure
compliance.  High risk matches have been
fully discussed with all services and they are
aware to prioritise these.  This will be
monitored by the Corporate Fraud Team.
Shared Service Manager -
Audit & Fraud
Ongoing
12  Are we investigating the circumstances of matches
adequately before reaching a ‘no issue’ outcome, in
particular? Yes
A full review by Corporate Fraud team has
been conducted to ensure all services are
investigating adequately.  We are satisfied
that all services are full investigating matches
before reaching a "no issue" outcome.
N/A
13. (In health bodies) are we drawing appropriately on the
help and expertise available from NHS Scotland Counter-
Fraud Services?
N/A
14. 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
Appropriate reports to PF, disciplinary action
are taken, debt recovery procedures in place. N/A
15. Do we avoid deploying excessive resources on match
reports where early work (eg, on high-risk matches) has
not found any fraud or error? Yes
Reviews of results undertaken and resources
based on the outcomes achieved will be
deployed to other recommended or high risk
matches.  The Corporate Fraud team will
review all services to ensure compliance.
Shared Service Manager -
Audit & Fraud
Ongoing
16. 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
The Corporate Fraud team have reviewed
each service to ensure they consider the "All
Matches" report.  All services are aware of the
"all matches" report.
N/A
17. Overall, are we deploying appropriate resources on
managing the NFI exercise? Yes
The Corporate Fraud team review resources
to ensure appropriate resources are being
deployed.
N/A
Recording and Reporting
18. Are we recording outcomes properly in the secure
website and keeping it up to date? Yes
The Corporate Fraud team have carried out a
full review of this area to ensure compliance.  N/A
19. Do staff use the online training modules and guidance
on the secure website, and do they consult the NFI team if
they are unsure about how to record outcomes (to be
encouraged)? Yes
Offices have found the online training helpful
and if required they have been informed to
consulted with Internal Audit for further
training/assistance.  Internal Audit have also
raised awareness of the online training
modules with all services.
N/A
20. If, out of preference, we record some or all outcomes
outside the secure website, have we made arrangements
to inform the NFI team about these outcomes? N/A
All outcomes are reported in secure website.
N/A