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West Dunbartonshire Council · 3 May 2023
Back to Audit Committee — 3 May 2023 and its agenda

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Agenda
Audit Committee
Date: Wednesday, 3 May 2023
Time: 14:00
Venue: Civic Space, 16 Church Street, Dumbarton, G82 1QL
Contact: Ashley MacIntyre, Committee Officer
ashley.macintyre@west-dunbarton.gov.uk
Dear Member
Please attend a meeting of the Audit Committee as detailed above.
The business is shown on the attached agenda.
Yours faithfully
PETER HESSETT
Chief Executive
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Distribution: 
Councillor Karen Conaghan (Chair)
Councillor Ian Dickson
Councillor Jonathan McColl (Vice Chair)
Councillor James McElhill
Councillor Michelle McGinty
Councillor John Millar
Councillor Martin Rooney 
Councillor Hazel Sorrell
Mr C Johnstone 
All other Councillors for information 
Chief Executive
Chief Officers 
Date of issue: 19 April 2023
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AUDIT COMMITTEE 
WEDNESDAY, 3 MAY 2023 
AGENDA 
1 APOLOGIES 
2 DECLARATIONS OF INTEREST 
Members are invited to declare if they have an interest in any of the items of
business on the agenda and the reasons for such declarations. 
3 MINUTES OF PREVIOUS MEETING 5 - 7 
Submit for approval as a correct record, the Minutes of Meeting of the Audit
Committee held on 15 February 2023. 
4 OPEN FORUM 
The Committee is asked to note that no open forum questions have been
submitted by members of the public. 
5 INTERNAL AUDIT PLANS 2022/23 – PROGRESS TO   9 - 28 
31 MARCH 2023 
Submit report by the Chief Officer – Resources advising of progress at 31
March 2023 against the Internal Audit Plans for 2022/23. 
6 2023/24 INTERNAL AUDIT ANNUAL STRATEGY AND PLAN 29 - 37 
Submit report by the Chief Officer – Resources advising of the planned
programme of work for the Internal Audit Section for the year 2023/24. 
7 NATIONAL FRAUD INITIATIVE 2022/23     39 - 43 
Submit report by the Chief Officer – Resources providing an update on the
current position with regard to the National Fraud Initiative in Scotland
2022/2023 Exercise. 
8/ 
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8 REVIEW OF INTERNAL AUDIT CHARTER    45 - 51 
Submit report by the Chief Officer – Resources advising that a review of the
Internal Audit Charter has been undertaken and the Charter updated to more
closely reflect the requirements of Standard 1000 of the Public Sector Internal
Audit Standards (PSIAS). 
9 SCOTTISH PUBLIC SERVICES OMBUDSMAN COMPLAINTS 53 - 61 
REPORT 2021-22 
Submit report by the Chief Officer – Citizen, Culture and Facilities presenting
the Scottish Public Services Ombudsman (SPSO) report on complaints
handling by West Dunbartonshire Council for the year 1 April 2021 – 31
March 2022. 
10 MAZARS 2022/23 EXTERNAL AUDIT ANNUAL PLAN           To Follow 
Submit report by the Chief Officer – Resources providing the Mazars 2022/23
External Audit Annual Plan. 
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AUDIT COMMITTEE
At a Meeting of the Audit Committee held in the Civic Space, 16 Church Street on
Wednesday, 15 February 2023 at 10.00 a.m.
Present: Councillors Karen Conaghan, Ian Dickson, James McElhill,
Michelle McGinty and Martin Rooney and Lay Member Mr
Christopher Johnstone.
Attending: Peter Hessett, Chief Executive; Laurence Slavin, Chief Officer –
Resources; Angela Wilson, Chief Officer – Supply, Distribution
and Property; Victoria Rogers, Chief Officer – People and
Technology; Laura Mason, Chief Officer – Education, Learning
and Attainment; Julie Slavin, Chief Finance Officer, HSCP; Andi
Priestman, Shared Service Manager – Audit and Fraud; Fiona
Taylor, Head of Health and Community Care, HSCP and Ashley
MacIntyre, Committee Officer.
Also attending: Tom Reid, Audit Director, Mazars.
Apologies: Councillors Jonathan McColl, John Millar and Hazel Sorrell.
Councillor Karen Conaghan in the Chair
DECLARATIONS OF INTEREST
It was noted that there were no declarations of interest in any of the items of
business on the agenda.
MINUTES OF PREVIOUS MEETING
The Minutes of Meeting of the Audit Committee held on 9 November 2022 were
submitted and approved as a correct record.
OPEN FORUM
The Committee noted that no open forum questions had been submitted by
members of the public.
ITEM 3
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INTERNAL AUDIT PLANS 2021/22 AND 2022/23 – PROGRESS TO 18 JANUARY
2023
A report was submitted by the Chief Officer – Resources advising of progress at 18
January against the Internal Audit Plans for 2021/22 and 2022/23.
After discussion and having heard the Shared Service Manager – Audit and Fraud in
further explanation of the report and in answer to Members’ questions, the
Committee agreed:-
(1) to note the recently issued Internal Audit reports and action plans; and
(2) to note the status of implementation progress relating to action plans from the
previously issued Internal Audit reports.
PUBLIC INTEREST DISCLOSURES AND OTHER INTERNAL AUDIT
INVESTIGATIONS 16 JULY 2022 TO 18 JANUARY 2023
A report was submitted by the Chief Officer – Resources advising of the outcome of
investigations into allegations and disclosures, in line with public interest disclosure
and business irregularities policies received by Internal Audit between 16 July 2022
and 18 January 2023.
After discussion and having heard the Shared Service Manager – Audit and Fraud in
further explanation of the report and in answer to Members’ questions, the
Committee agreed to note the contents of the report.
CIPFA GUIDANCE FOR AUDIT COMMITTEES
A report was submitted by the Chief Officer – Resources advising of the updated
CIPFA guidance on Audit Committees within Local Authorities.
After discussion and having heard the Shared Service Manager – Audit and Fraud in
further explanation of the report and in answer to Members’ questions, the
Committee agreed:-
(1) to note the updated guidance for Audit Committees;
(2) that the Chair of the Audit Committee would review the updated guidance with
support from the Chief Officer – Resources and the Shared Service Manager
– Audit and Fraud; and
(3) that an update on the Council’s current arrangements to the Audit Committee
and any required improvement actions would be brought to a future meeting
of the Committee for consideration and approval.
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STRATEGIC RISKS 2022-2027
A report was submitted by the Chief Officer – People and Technology providing an
update on the strategic risks for 2022-27.
After discussion and having heard the Chief Officer – People and Technology and
the Chief Officer – Education, Learning and Attainment in further explanation of the
report and in answer to Members’ questions, the Committee agreed to note the
contents of the report.
AUDIT UPDATE – WEST DUNBARTONSHIRE COUNCIL
A report was submitted by the Audit Director, Mazars providing an update for year
ending 31 March 2023.
After discussion and having heard the Audit Director in further explanation of the
report and in answer to Members’ questions, the Committee agreed:-
(1) to note that Tom Reid, Audit Director, Mazars would be the Engagement Lead
for West Dunbartonshire Council; and
(2) to note the contents of the report.
The meeting closed at 10.45 a.m.
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WEST DUNBARTONSHIRE COUNCIL
Report by Chief Officer – Resources
Audit Committee: 3 May 2023
Subject: Internal Audit Plans 2022/23 – Progress to 31 March 2023
1. Purpose
1.1 The purpose of this report is to advise Members of progress at 31 March 2023
against the Internal Audit Plans for 2022/23.
1.2 The report also advises Members of:
• Recently issued Internal Audit reports and action plans; and
• Status of implementation progress relating to action plans from previously
issued Internal Audit reports.
2. Recommendations
2.1 It is recommended that Members note the contents of this report.
3. Background
3.1 The annual audit plan for 2022/23 was approved by the Audit Committee on 15
June 2022.  This report provides information on the progress in implementing
the plan.
3.2  When audit reports are issued by Internal Audit, an action plan is agreed with
management in relation to issues highlighted by the audit report.  Progress on
implementing the actions is monitored by Internal Audit on a monthly basis and
regularly reported to the Audit Committee.
4. Main Issues
4.1. The annual audit plan sets out the audit coverage for the year utilising available
staff resources to enable the Shared Service Manager – Audit & Fraud to provide
the annual internal audit opinion regarding the adequacy and effectiveness of
internal control within the Council.
4.2 In accordance with the risk-based audit methodology, for each audit, one of four
audit opinions is expressed:
Strong In our opinion there is a sound system of internal
controls designed to ensure that the organisation is
able to achieve its objectives.  
Satisfactory In our opinion isolated areas of control weakness
were identified which, whilst not systemic, put
some organisation objectives at risk.  
ITEM 5
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Requires Improvement In our opinion systemic and/or material control
weaknesses were identified such that some
organisation objectives are put at significant risk.
Unsatisfactory In our opinion the control environment was
considered inadequate to ensure that the
organisation is able to achieve its objectives.
4.3 Detailed findings and recommendations reported to management are graded using
the following criteria:   
Red In our opinion the control environment is insufficient to address the
risk and this could impact the Council as a whole. 
Corrective action must be taken and should start immediately. 
Overseen to completion by Corporate Management Team.
Amber In our opinion there are areas of control weakness which we consider
to be individually significant but which are unlikely to affect the
Council as a whole.
Corrective action must be taken (some exceptions may be agreed
with Internal Audit) within reasonable timeframe.
Overseen to completion by Chief Officer/Head of Service.
Green In our opinion the risk area is well controlled or our audit highlighted
areas for minor control improvement and/or areas of minor control
weakness. 
Process improvements/efficiencies may be actioned at management
discretion in consultation with Internal Audit.
Managed by service owner. 
Not reported in Audit Committee papers.
4.4 Two audit reviews have been finalised since the Audit Committee meeting in
February 2023 as follows:
• ParentPay
• Corporate Procurement – Supplier Management
ParentPay
4.5 ParentPay is an online payment solution used in all Primary Schools, Secondary
Schools and Early Learning & Childcare Centres. The secure web based
application provides a facility for parents and carers to pay online at a time that is
convenient, for trips, meals, breakfast clubs etc. and enables the removal of all
cash and cheques from establishments. Parents and carers who wish to continue to
use cash are able to take advantage of PayPoint facilities in local shops.  
4.6 Establishments benefit from using ParentPay in a number of ways including
reduced cash handling and banking, and reducing the risks around money being
held on establishment premises. The system also allows for improved
communication with parents and carers concerning payments and an accurate
record is held of all payments made. 
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4.7 The objective of this audit was to provide management and the Audit Committee
with an assessment of the adequacy and effectiveness of the governance, risk
management and controls over the key risks faced by the Council in relation to the
ParentPay system.
4.8 The review focussed on the high level processes and procedures in relation to the
ParentPay system tasks and the management of credit and debit balances.
4.9 The overall control environment opinion for this audit review was Satisfactory.
There were two AMBER issues identified as follows:
Lack of Formalised Debt Recovery Guidance (Amber)
There is currently no guidance in place for the recovery of debt and establishments
are expected to apply their own procedures and self-manage debt recovery which
has resulted in inconsistent practices across the establishments.
Where there is no guidance in place, there is a risk that accrued debt may not be
recovered by the Council.
Management of Debt (Amber)
An aged analysis of debtors was undertaken which identified that there is a total
debt balance currently of £65,328.28 for pupils and £977.66 for staff relating to
school meals. This debt has built up since the system was introduced in 2018.  For
some cases, pupils have transitioned from primary into secondary school and
received a new account on entering secondary school but the debt remains
outstanding at the primary school.  
From a sample of schools contacted, it was identified that there is no guidance
available to staff who are required to deal with staff debt and establishments are
expected to self-manage this process. In addition, reports are not produced for
Heads of Establishments or Education Management which would identify staff debt
that requires action.
Where there is no formal process in place and debt is not pursued in a timely
manner, there is a risk that accrued debt may not be recovered by the Council.
4.10 There were 3 issues identified, two of which we consider to be individually
significant and an action plan is in place to address all issues by 30 June 2023.
Corporate Procurement – Supplier Management
4.11 Specific Guidance is in place to ensure that supplier management of the Council’s
contracts for the procurement of goods and services is undertaken in accordance
with the Council’s Financial Regulations and Standing Orders.  
4.12 The preferred Supplier Management method is to use Scorecards within the Public
Contracts Scotland – Tender (PCS-T) system for measuring Key Performance
Indicators. Where this method is not used, Contract Owners are expected to ensure
effective and adequate arrangement are in place for Supplier Management
throughout the term of a contract.
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4.13 The objective of this audit is to provide management and the Audit Committee with
an assessment of the adequacy and effectiveness of the governance, risk
management and controls surrounding the key risks in relation to Supplier
Management.
4.14 The overall control environment opinion was Satisfactory.  There was one AMBER
issue identified as follows:
HSCP Formal Contract & Supplier Management (Amber)
Through discussions with the HSCP Heads of Service it was identified that other
than general monitoring of the financial costs of contracts, there is currently no
formal contract and supplier management practiced in line with Council Guidance.
Where formal contract and supplier management is not undertaken there is a risk
that HSCP management are unable to demonstrate that high quality services are
being delivered.
4.15 The audit identified 3 issues, 1 of which we consider to be individually significant
and an action plan is in place to address all issues by 31 December 2023.
4.16 The fieldwork for the 2022/23 Annual Audit Plan is nearing completion and is on
track to be completed by end of May.  The status of the 2022/23 audit plan is
attached at Appendix 1.
4.17 In relation to audit work for the Integration Joint Board, the agreed audit plan is
being progressed with regular reporting to the Integration Joint Board Audit &
Performance Committee.
4.18 In relation to the Valuation Joint Board, planning for the 2022/23 audit plan is
complete and fieldwork is underway.
4.19 In relation to the Leisure Trust, planning for the 2022/23 audit plan is complete and
fieldwork is underway.
4.20 Internal and External Audit Action Plans
In relation to audit action plans, these are monitored by Internal Audit on a monthly
basis.  There were 12 actions due for completion by the end of March, 2 of which
have been reported as completed my management and action dates in relation to
10 actions have been missed.  Revised dates have been set for 8 actions and
require to be set for 2 actions. The status report at 31 March 2023 is provided at
Appendix 2.
Ongoing Corporate Fraud Team Work
4.21 From 1 April to 31 March 2023, the Corporate Fraud team’s day to day work has
resulted in actual recoveries, charges and re-billings as detailed below, against an
annual target of £250,000.  
Description Amount (£)
Council Tax Reduction 39,085
Council Tax Single Person Discount 20,699
National Fraud Initiative (Housing Benefit) 58,665
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National Fraud Initiative (Council Tax/Council Tax
Reduction)
39,543
National Fraud Initiative (Small Business Bonus Scheme) 0
Joint Working Housing Benefit/Council Tax Reduction 0
Non Department for Work and Pensions Housing Benefit 77,551
Non Department for Work and Pensions Council Tax
Reduction
0
Department for Work and Pensions Housing Benefit Error 8,676
Covid 19 Business Grants 5,250
Scottish Welfare Fund Community Care Grant 6,095
Administrative Penalty 0
Total £255,564
4.22 The Internal Audit Team and the Corporate Fraud Team continue to work together
as appropriate in order to ensure a joined-up approach to fraud investigation and
detection.
National Fraud Initiative
4.23 The National Fraud Initiative is a series of biennial exercises run by the Cabinet
Office and Audit Scotland to identify or prevent fraud and error by matching
electronic data held by public bodies. Participating bodies are required to
investigate data discrepancies within a timescale and report back on any savings.
4.24 The 2022 biennial exercise is now underway and datasets have been submitted to
the Cabinet Office.  Matches were released in January and February 2023.
Benchmarking
4.25 In accordance with the Council’s Strategic Improvement Framework, services
should undertake benchmarking activity with the equivalent function in other
Councils.  Therefore, the Council’s Internal Audit service has entered into a
benchmarking group which involves seven other Councils, these being:
• Argyll and Bute;
• Clackmannanshire;
• East Dunbartonshire;
• Falkirk;
• West Lothian;
• Inverclyde; and
• Stirling.
4.26 Meetings will continue to take place during 2023 to review performance against
agreed performance indicators and identify other areas for sharing of best
practice.    
5. People Implications
5.1 There are no people implications.
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6. Financial and Procurement Implications
6.1 As a result of Corporate Fraud Team activity, actual recoveries, charges and re-
billings of £255,564 from 1 April to 31 March 2023 have been identified against
an annual target of £250,000.
6.2 There are no procurement implications arising from this report.
7. Risk Analysis
7.1 There is a risk that failure to deliver the Internal Audit Plan would result in an
inability to provide a reasonable level of assurance over the Council’s system of
internal financial control to those charged with governance.  The main basis for
providing assurance is coverage of the planned risk-based audits.  Every
endeavour is made to ensure that no material slippage occurs in risk-based
audits by concentrating resources on these audits.
8. Equalities Impact Assessment (EIA)
8.1 There are no direct equalities impacts arising from the report however where an
agreed action results in a change in process this will be considered for equalities
impact by the relevant service.
9. Consultation
9.1 This report has been subject to consultation with appropriate Chief Officers.
10. Strategic Assessment
10.1 This report relates to strong corporate governance.
....................................
Laurence Slavin
Chief Officer - Resources
Date: 31 March 2023
Person to Contact: Andi Priestman, Shared Service Manager – Audit & Fraud
E-mail: andi.priestman@west-dunbarton.gov.uk
Appendices: 2022/23 Annual Audit Plan – Progress to 31 March 2023
(Appendix 1)
Status of Internal Audit Action Plans at 31 March 2023
(Appendix 2)
Background Papers: Audit Committee – 15 June 2022: Internal Audit Annual
Plan 2022/23
Audit Committee – 21 March 2018: Counter Fraud and
Corruption Strategy
Internal Audit Reports - Copies available on request
Wards Affected: All wards
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2022-2023 Internal Audit Annual Audit Plans – Progress to 31 March 2023
2022-23 Plan
Audit/Status
Not
Started
Planning Fieldwork Fieldwork
Complete
Draft
Report
Final
Report
Date Reported to
Audit Committee
Risk-Based Reviews
Learning Disabilities Services – Financial
Monitoring of Contracts
Deferred to 2023/24 Audit Plan.  There is currently a redesign planned for LDS financial
monitoring processes.  Audit resource will be provided to the project and terms of reference
will be agreed.
Fleet Management ✓ ✓ ✓ ✓ June 2023
Occupational Therapy Waiting Times ✓ ✓ ✓ ✓ June 2023
Financial Assessment Process ✓ ✓ ✓ ✓ ✓ February 2023
Housing Repairs and Maintenance ✓ June 2023
Corporate Procurement – Supplier Management
(c/f)
✓ ✓ ✓ ✓ ✓ May 2023
Vehicle Maintenance ✓ ✓ June 2023
Void Management ✓ June 2023
Housing Waiting Lists ✓ ✓ ✓ ✓ ✓ February 2023
Parent Pay ✓ ✓ ✓ ✓ ✓ May 2023
Off Payroll Working ✓ ✓ ✓ ✓ June 2023
Corporate Purchase Cards ✓ ✓ ✓ ✓ ✓ February 2023
Limited Scope Financial System Reviews
Non-Domestic Rates ✓ ✓ June 2023
Creditors ✓ ✓ ✓ ✓ June 2023
Compliance Reviews
Health and Wellbeing Policy Deferred to 2023/24 Audit Plan.
Other Work
Integration Joint Board – Internal Audit Service The internal audit annual plan for 2022/23 is nearing completion.  Progress updates will be
provided to the HSCP Board Audit & Performance Committee.
Valuation Joint Board – Internal Audit Service The internal audit annual plan for 2022/23 is nearing completion.
Leisure Trust – Internal Audit Service The internal audit annual plan for 2022/23 is nearing completion.
National Fraud Initiative Matches for the 2022/23 Exercise have been received and investigations are underway.
2021/2022 Audit Plan Completion Four audits were finalised during 2022/23 –Debtors, Project Management Arrangements;
Vehicle Tracking System and Overtime.
Appendix 1
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLANS
AT 31 MARCH 2023
Summary: Section 1 Summary of Management Actions due for
completion by 31/03/2023
There were 12 actions due for completion by 31 March
2023, 2 of which have been reported as completed by
management and 10 actions have missed the deadline set
by management.  A revised date requires to be set for 2
actions.
Section 2 Summary of Current Management Actions Plans at
31/03/2023
At 31 March 2023 there were no audit reports delayed due
to management not finalising the action plan within
agreed timescales.
Section 3 Current Management Actions at 31/03/2023
At 31 March 2023 there were 18 current audit action
points.  
Section 4 Analysis of Missed Deadlines
At 31 March 2023 there were 14 audit action points where
the agreed deadline had been missed.
Section 5 Summary of Action Plan Points by Audit Year
Appendix 2
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLAN POINTS 
SUMMARY OF ACTION PLANS DUE FOR COMPLETION BY 31.03.2023
SECTION 1
Strategic Area
No. of
Actions
Due
No. of
Actions
Completed
Deadline
missed
Revised date
set*
Deadline
missed
Revised date
to be set*
Housing and Employability 1 1
Supply, Distribution and
Property
3 1 2
Roads and Neighbourhood 6 6
HSCP – Health and
Community Care
2 2
Total 12 2 8 2
* These actions are included in the Analysis of Missed Deadlines – Section 4
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLAN POINTS 
SUMMARY OF CURRENT ACTION PLANS AT 31.03.2023
SECTION 2
CURRENT ACTIONS BY STRATEGIC AREA
Housing and Employability
Due for completion April 2023 2
Total Actions 2
Supply, Distribution and Property
Due for completion April 2023 1
Due for completion December 2023 1
Total Actions 2
Roads and Neighbourhood
Due for completion June 2023 6
Total Actions 6
HSCP - Health and Community Care
Due for completion December 2023 1
Completion date to be advised 5
Total Actions 6
Education Learning and Attainment
Due for completion June 2023 2
Total Actions 2
Total current actions: 18
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLAN POINTS
CURRENT ACTION PLANS AT 31.03.2023
SECTION 3
Status Key
On track
Overdue – revised date
required
Current Internal Audit Action Plans
IHMS Stores and Stock Management (Report issued January 2022)
Code Agreed Action Status Original Due
Date Due Date Assigned To Managed By
IAAP/104
Lack of Stock Control Process for Direct Purchases of UPVC Units (Rating reduced to
Amber)
An inventory of sizes/ types/hands/styles of uPVC windows and doors will be developed for inactive
orders. A plan will be put in place to install all units where feasible. Any unusable units will be dealt
within in line with the Council’s management of obsolete stock procedures.
31-Mar-2023 31-Dec-2023*
Building
Services
Manager
Chief Officer –
Supply,
Distribution and
Property
Employee Expenses (Report issued May 2022)
Code Agreed Action Status Original Due
Date Due Date Assigned To Managed By
IAAP/111
Lack of Co-ordination and Management of Pool Vehicles (Amber)
A working group has been established to review pool car procedures which is being chaired by the
Chief Officer Shared Services Roads & Neighbourhood.
The CAS team will be responsible for maintaining pool vehicle records. A review is currently being
carried out of procedures to make this process more efficient.
Cost Savings Analysis will be carried out on an annual basis and reported as appropriate.
01-Oct-2022 30-Jun-2023*
Shared Fleet and
Waste Services
Manager
Chief Officer –
Roads and
Neighbourhood
IAAP/113
Identification of High Levels of Claims by Teams & Individuals for Recommendation of
Pool Car Use (Amber)
A working group has been established to review pool car procedures which is being chaired by the
Chief Officer Shared Services Roads & Neighbourhood.
A list of high mileage claimants has been collated and the working group will assess the users in
relation to allocation of pool cars and identify if additional vehicles are required.
01-Oct-2022 30-Jun-2023*
Shared Fleet and
Waste Services
Manager
Chief Officer –
Roads and
Neighbourhood
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLAN POINTS
CURRENT ACTION PLANS AT 31.03.2023
SECTION 3
Status Key
On track
Overdue – revised date
required
Management of Capital Projects (Report Issued July 2022)
Code Agreed Action Status Original Due
Date Due Date Assigned To Managed By
IAAP/135
c
Lack of Capital Project Post Implementation Reviews (Amber)
Agree timeline for outstanding PPR’s and commence in priority order. 31-Jan-2023 30-Apr-2023* Corporate Asset
Manager
Chief Officer –
Supply, Distribution
and Property
Housing Waiting Lists (Report Issued January 2023)
Code Agreed Action Status Original Due
Date Due Date Assigned To Managed By
IAAP/152
b
Timely review and investigation of National Fraud Initiative Matches (Amber)
Training will be organised for additional users on the system. 28-Feb-2023 30-Apr-2023*
Housing
Operations Co-
ordinator/
Housing
Operations
Team Leader
Chief Officer
Housing and
Employability
IAAP/152
c
Timely review and investigation of National Fraud Initiative Matches (Amber)
Error report will be requested from IHMS. 30-Apr-2023 30-Apr-2023
Housing
Operations Co-
ordinator/
Housing
Operations
Team Leader
Chief Officer
Housing and
Employability
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLAN POINTS
CURRENT ACTION PLANS AT 31.03.2023
SECTION 3
Status Key
On track
Overdue – revised date
required
Vehicle Tracking System (Report Issued January 2023)
Code Agreed Action Status Original Due
Date Due Date Assigned To Managed By
IAAP/147
Lack of Formal Process for authorising Users Access to Vehicle Tracking System (Amber)
Users will be contacted and each service’s identified administrator will be given access to review and
confirm access rights are correct.
31-Mar-2023 30-Jun-2023*
Shared Fleet and
Waste Services
Manager
Chief Officer –
Roads and
Neighbourhood
IAAP/148
Lack of tracking units in hired vehicles (Amber)
Management will commence a review to assess practical application of tracking devices to Long term
hires.
31-Mar-2023 30-Jun-2023*
Shared Fleet and
Waste Services
Manager
Chief Officer –
Roads and
Neighbourhood
IAAP/149
a
Under Utilisation of Vehicle Tracking System (Amber)
All Services operating vehicles with tracking units installed will be contacted and provided with
updated Tracking System Procedures and training if required.
31-Mar-2023 30-Jun-2023*
Shared Fleet and
Waste Services
Manager
Chief Officer –
Roads and
Neighbourhood
IAAP/149
b
Under Utilisation of Vehicle Tracking System (Amber)
All Service managers that utilise Council owned or hired vehicles should ensure they are aware and
are trained on the operational functionality of the Vehicle Tracking System.
31-Mar-2023 30-Jun-2023* Service
Managers Chief Officers
Financial Assessments Process H&CC (Report Issued January 2023)
Code Agreed Action Status Original Due
Date Due Date Assigned To Managed By
IAAP/142
a
No Independent review of the Financial Assessment calculation (Amber)
Review of financial assessment processes to ensure that Senior Social Workers are aware of their
responsibilities and expectations in relation to checking FA calculations.
28-Feb-2023 To be
advised*
Integrated
Operations
Manager
Head of Health and
Community Care
IAAP/142
b
No Independent review of the Financial Assessment calculation (Amber)
Review of systems currently available within care contracts to consider ability to replicate for non-
residential charges within ACT/COPT.
28-Feb-2023 To be
advised*
Integrated
Operations
Manager
Head of Health and
Community Care
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLAN POINTS
CURRENT ACTION PLANS AT 31.03.2023
SECTION 3
Status Key
On track
Overdue – revised date
required
Code Agreed Action Status Original Due
Date Due Date Assigned To Managed By
IAAP/142
c
No Independent review of the Financial Assessment calculation (Amber)
The Head of Health and Community Care will consider meeting with other Heads of Services to
discuss the feasibility, and financial and resourcing implications of setting up a centralised team to
carry out Financial Assessment Process and calculations for the non-residential services teams.
31-Mar-2023 To be
advised*
Head of Health
and Community
Care
Chief Officer HSCP
IAAP/143
a
Annual Review of Financial Assessment calculation (Amber)
Management will carry out a review of financial assessment yearly review processes with senior
social workers to consider how current systems can be improved to ensure consistent completion of
the reviews within appropriate timescales.
28-Feb-2023 To be
advised*
Integrated
Operations
Manager
Head of Health and
Community Care
IAAP/143
b
Annual Review of Financial Assessment calculation (Amber)
The annual review process will be monitored by Head of Service. 31-Mar-2023 To be
advised*
Head of Health
and Community
Care
Chief Officer HSCP
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLAN POINTS
CURRENT ACTION PLANS AT 31.03.2023
SECTION 3
Status Key
On track
Overdue – revised date
required
ParentPay (Report Issued February 2023)
Code Agreed Action Status Original Due
Date Due Date Assigned To Managed By
IAAP/155
Lack of formal debt recovery procedures (Amber)
Guidance will be developed which will provide clear procedures and a standard approach, for all staff
dealing with debt recovery in schools. The guidance will:
• Identify the level of debt for the commencement of debt recovery procedures within schools;
• Identify a de minimis level for passing to the Corporate Debt Team for recovery.
30-Jun-2023 30-Jun-2023
Senior Education
Officer
Policy,
Performance and
Resource
Chief Officer
Education, Learning
and Attainment
IAAP/156
Management of debt within establishments (Amber)
Currently debt management procedures are being finalised and these will be implemented once
approved by the Education Committee.
Heads of Establishments will instruct all staff who require to pay for meals through ParentPay that
this must be done in a timely manner, and that debt will not be built up at any time. This will be
managed and monitored by Heads of Establishments on a regular basis.
30-Jun-2023 30-Jun-2023
Senior Education
Officer
Policy,
Performance and
Resource
Chief Officer
Education, Learning
and Attainment
Supplier Management (Report Issued March 2023)
Code Agreed Action Status Original Due
Date Due Date Assigned To Managed By
IAAP/158
HSCP Formal Contract and Supplier Management
Development of a Contracts Register to be stored centrally and controlled by the CCQ Team.  By the
due date it will have been developed to include a risk register in RAG format to cover contract start
date, end date, extension date, CI scores, spend status, Quality monitoring information. Risk
register will also be used to programme in more to review services well ahead of contract end date.
31-Dec-2023 31-Dec-2023
HSCP Head of
Strategy and
Transformation
Chief Officer HSCP
Board
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLANS
ANALYSIS OF MISSED DEADLINES SECTION 4
Report Agreed Action Original Due
Date
Revised Date Management Comments
Employee Expenses
(May 2022)
Lack of Co-ordination and Management of
Pool Vehicles (Amber)
A working group has been established to review
pool car procedures which is being chaired by the
Chief Officer Shared Services Roads &
Neighbourhood.
The CAS team will be responsible for maintaining
pool vehicle records. A review is currently being
carried out of procedures to make this process
more efficient.
Cost Savings Analysis will be carried out on an
annual basis and reported as appropriate.
31-Oct-2023
31-Mar-2023
30-Jun-2023 Fleet Management Service has now met with services who have pool
car users.
An update will be provided to the  Pool Car Working Group Meeting
on 22nd March.
A high level cost savings analysis has been undertaken and a report
will be presented to PMRG.
Employee Expenses
(May 2022)
Identification of High Levels of Claims by
Teams & Individuals for Recommendation of
Pool Car Use (Amber)
A working group has been established to review
pool car procedures which is being chaired by the
Chief Officer Shared Services Roads &
Neighbourhood.
A list of high mileage claimants has been collated
and the working group will assess the users in
relation to allocation of pool cars and identify if
additional vehicles are required.
31-Oct-2022
31-Mar-2023
30-Jun-2023 Fleet Management Service has now met with services who have pool
car users.
An update will be provided to the  Pool Car Working Group Meeting
on 22nd March.
A high level cost savings analysis has been undertaken and a report
will be presented to PMRG.
Financial Assessments
Process H&CC
(January 2023)
No Independent review of the Financial
Assessment calculation (Amber)
Review of financial assessment processes to
ensure that Senior Social Workers are aware of
their responsibilities and expectations in relation
to checking FA calculations.
28-Feb-2023 To be advised The feasibility of creating a new 'transactional team' to
complete financial assessments/annual review across adult services is
being considered.  A report is going to SMT in April 2023.
Relevant action will then be taken.
Financial Assessments
Process H&CC
(January 2023)
No Independent review of the Financial
Assessment calculation (Amber)
Review of systems currently available within care
contracts to consider ability to replicate for non-
residential charges within ACT/COPT.
28-Feb-2023 To be advised The feasibility of creating a new 'transactional team' to
complete financial assessments/annual review across adult services is
being considered.  A report is going to SMT in April 2023.
Relevant action will then be taken.
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLANS
ANALYSIS OF MISSED DEADLINES SECTION 4
Report Agreed Action Original Due
Date
Revised Date Management Comments
Financial Assessments
Process H&CC
(January 2023)
Annual Review of Financial Assessment
calculation (Amber)
Management will carry out a review of financial
assessment yearly review processes with senior
social workers to consider how current systems
can be improved to ensure consistent completion
of the reviews within appropriate timescales.
28-Feb-2023 To be advised Interim process in place to ensure annual review of financial
assessments. To ensure consistency and application of an annual
financial reviews the feasibility of creating a new 'transactional team'
to complete financial assessments/annual review across adult
services is being considered.
Housing Waiting Lists
(January 2023)
Timely review and investigation of National
Fraud Initiative Matches (Amber)
Training will be organised for additional users on
the system.
28-Feb-2023 30-Apr-2023 The new users have been added to the NFI system and have been
provided an overview of the system, however in-depth training
proved difficult without a review due to be carried out.  The next
review is due to be received from NFI in April and we are therefore
planning further training then.
Vehicle Tracking System
(Report issued January
2023)
Lack of Formal Process for authorising Users
Access to Vehicle Tracking System (Amber)
Users will be contacted and each service’s
identified administrator will be given access to
review and confirm access rights are correct.
31-Mar-2023 30-Jun-2023 Service users will be contacted,  a meeting to be held to agree levels
of access, training requirements and agree designated service
contacts.
Vehicle Tracking System
(Report issued January
2023)
Lack of tracking units in hired vehicles
(Amber)
Management will commence a review to assess
practical application of tracking devices to Long
term hires.
31-Mar-2023 30-Jun-2023 To be included in discussions with hire companies, additional costs
and benefits to be factored in.
Vehicle Tracking System
(Report issued January
2023)
Under Utilisation of Vehicle Tracking System
(Amber)
All Services operating vehicles with tracking units
installed will be contacted and provided with
updated Tracking System Procedures and training
if required.
31-Mar-2023 30-Jun-2023 Meetings are being held with transport and fleet to develop
procedures and links to action IAAP/147.
Vehicle Tracking System
(Report issued January
2023)
Under Utilisation of Vehicle Tracking System
(Amber)
All Service managers that utilise Council owned
or hired vehicles should ensure they are aware
and are trained on the operational functionality of
the Vehicle Tracking System.
31-Mar-2023 30-Jun-2023 Links to above action.
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLANS
ANALYSIS OF MISSED DEADLINES SECTION 4
Report Agreed Action Original Due
Date
Revised Date Management Comments
Financial Assessments
Process H&CC
(January 2023)
No Independent review of the Financial
Assessment calculation (Amber)
The Head of Health and Community Care will
consider meeting with other Heads of Services to
discuss the feasibility, and financial and
resourcing implications of setting up a centralised
team to carry out Financial Assessment Process
and calculations for the non-residential services
teams.
31-Mar-2023 To be advised The feasibility of creating a new 'transactional team' to
complete financial assessments/annual review across adult services is
being considered.  A report is going to SMT in April 2023.
Relevant action will then be taken.
Financial Assessments
Process H&CC
(January 2023)
Annual Review of Financial Assessment
calculation (Amber)
The annual review process will be monitored by
Head of Service.
31-Mar-2023 To be advised Interim process in place to ensure annual review of financial
assessments. To ensure consistency and application of an annual
financial reviews the feasibility of creating a new 'transactional team'
to complete financial assessments/annual review across adult
services is being considered.  A report is going to SMT in April 2023.
Relevant action will then be taken.
Management of Capital
Projects (July 2022)
Lack of Capital Project Post Implementation
Reviews (Amber)
Agree timeline for outstanding PPR’s and
commence in priority order.
31-Mar-2023 30-Apr-2023 This action is being progressed but capacity issues within the team
have delayed the completion of this action.
IHMS Stocks and Stores
Management (January
2023)
Lack of Stock Control Process for Direct
Purchases of UPVC Units (Rating reduced to
Amber)
An inventory of sizes/ types/hands/styles of uPVC
windows and doors will be developed for inactive
orders. A plan will be put in place to install all
units where feasible. Any unusable units will be
dealt within in line with the Council’s
management of obsolete stock procedures.
31-Mar-2023 31-Dec-2023 The units have now been moved to a secure storage location.
Programme of installation is ongoing.  Management have also been in
touch with relevant contractor who have so far failed to uplift their
mismeasures.  A formal letter will be issued to contractors stating
that the units will be disposed of by a certain date to allow them an
opportunity to uplift these units.
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLANS
SUMMARY OF ACTIONS BY AUDIT YEAR SECTION 5
Status at 31 March 2023
Audit Year No of Agreed
Actions
No of actions
complete
Current actions by Grade
Red Amber Green*
2020/2021 25 22 0 1 2
2021/2022 51 44 0 3 4
2022/2023 38 16 0 14 8
Total 114 82 0 18 14
* Green actions are within the Council’s risk appetite and are therefore not included in
Audit Committee reports.
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WEST DUNBARTONSHIRE COUNCIL
Report by Chief Officer - Resources
Audit Committee: 3 May 2023
___________________________________________________________________
Subject:  2023/24 Internal Audit Annual Strategy and Plan
1. Purpose
1.1 The purpose of this report is to advise members of the planned programme of
work for the Internal Audit Section for the year 2023/24.
2. Recommendations
2.1 It is recommended that the Committee approve the 2023/24 Audit Plan.
3. Background
3.1 The Public Sector Internal Audit Standards include the requirement for the
Chief Internal Auditor to prepare a risk-based plan to determine the priorities
of the internal audit activity, consistent with the organisation’s goals.
4. Main Issues
4.1 The audit universe contains all areas that have been identified for review and
an assessment has been undertaken of the risk relating to each area based
on a number of criteria.  Account has also been taken of the risks identified in
the Council’s risk registers and risks identified by external scrutiny bodies
through local scrutiny arrangements.
4.2 It is intended that audit work will be focused on areas of greatest risk taking
into account management’s own view of risk and meetings have been held
with Chief Officers as appropriate.  Each area has been assessed against a
broad range of risk criteria and a risk score has been generated based on
probability factors such as current control environment, results of last audit
and time since last audit.
4.3 The audit plan also includes the carry forward of the completion of fieldwork
for some audits from 2022/23.
4.4 The Audit Plan also includes the activity of the Corporate Fraud Team and
includes an allocation of days to provide the Internal Audit Service to the WD
Integration Joint Board, the WD Leisure Trust and the Valuation Joint Board.
4.5 Internal Audit monitors delivery of the plan continuously during the year using
a number of performance indicators. Progress is reported to members on a
regular basis.
ITEM 6
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4.6 Outlined below are the current risk factors influencing our proposed audit
coverage for 2023/24:
• Learning Disabilities Services provide a range of support services to adults
with learning disabilities.  A service review is being undertaken and
Internal Audit will provide audit advice and support to the project to ensure
risks are adequately and effectively managed.
• Local authorities across Scotland have a target to allocate 1% of annual
budgets by participatory budgeting processes. In West Dunbartonshire
local people already engage in a variety of different ways to influence and
direct resources.  Internal Audit will review the Council’s approach to
participatory budgeting to ensure arrangements in place to monitor and
report on performance are adequate and effective.
• The Council operates an Attendance Management Policy which is
designed to provide support for employees who are ill and to improve
attendance levels across the council. Internal Audit will review the
adequacy and effectiveness of the attendance management arrangements
across the Council.
• Internal Audit will review the process to ensure commercial waste is being
collected promptly and efficiently by the council and that all income from
commercial waste collection and disposal is properly collected and
accounted for.
• Internal Audit will review the adequacy and effectiveness of stock control
processes in operation within Facilities Management Cleaning and
Catering services
• As part of the annual audit planning process, corporate procurement is a
key risk area that is reviewed each year.  For 2023/24 Internal Audit will
agree the risk areas with Corporate Procurement and carry out an audit to
ensure compliance with relevant policies and procedures.
• The UK Government launched the UK Shared Prosperity Fund in April
2022 and West Dunbartonshire Council has been allocated funding over a
3 year period.  An assurance framework is being developed for external
reporting and Internal Audit will provide advice and support on the relevant
governance, risk management and internal control procedures being
developed in relation to the assurance framework.
• A project is being undertaken by Roads and Neighbourhood to review the
routes used for waste collection. Internal Audit will provide advice and
support to the project to ensure routes are optimised for future service
delivery.
4.7 The draft 2023/24 Internal Audit Strategy and Plan is included at Appendix 1.
There are no significant threats to the independence of the internal audit
activity, such as inappropriate scope or resource limitations.  The Plan
contains contingency provision that will be utilised during the year in response
to unforeseen work demands that may arise e.g. special investigations and
provision of ad hoc advice.  The plan also includes a balance of days required
to complete audit work from the 2022/23 audit plan.
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4.8 The risk scoring system is maintained on a real-time basis and is altered as
circumstances change.  Regular reviews of the risk scores allow Internal Audit
to address the changing risk exposure of the organisation more effectively and
ensure audit effort is focused on those areas identified as higher risk.
5. Personnel Implications
5.1 There are no personnel issues with this report.
6. Financial and Procurement Implications
6.1 There are neither financial nor procurement implications arising directly
from this report.
7. Risk Analysis
7.1 The Plan has been constructed taking cognisance of the risks associated with
major systems. Consultation with relevant Chief Officers has been carried out
to ensure that risks associated with delivering the Council’s objectives have
been considered.
8. Equalities Impact Assessment (EIA)
8.1 There are no issues.
9. Consultation
9.1 This report has been subject to consultation with appropriate Chief Officers.
10. Strategic Assessment
10.1 This report relates to all five of the Council’s Strategic Priorities.
Laurence Slavin
Chief Officer - Resources
Date: 31 March 2023
Person to contact Andi Priestman, Shared Service Manager – Audit & Fraud
Telephone:  01389-737436
Email:  andi.priestman@west-dunbarton.gov.uk
Appendix 1: Draft 2023/24 Internal Audit Strategy and Plan
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Background Papers: None
Wards Affected: All wards
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2023/24 INTERNAL AUDIT ANNUAL STRATEGY AND PLAN
1. Introduction
1.1 The Public Sector Internal Audit Standards (PSIAS) set out the requirement for the
Shared Service Manager – Audit & Fraud to prepare a risk-based audit plan to determine
the priorities of the internal audit activity, consistent with the organisation’s goals.
1.2 The Shared Service Manager – Audit & Fraud must review and adjust the plan as
necessary in response to changes in the organisation’s business, risks, operations and
priorities.
1.3 The audit plan must incorporate or be linked to a strategic or high-level statement of how
the Internal Audit Service will be delivered and developed in accordance with the Internal
Audit Charter and how it links to the organisational objectives and priorities.
1.4 The strategy shall be reviewed on an annual basis as part of the audit planning process.
2. Internal Audit Objectives
2.1 The definition of internal auditing is contained within the PSIAS as follows:
“Internal auditing is an independent, objective assurance and consulting activity designed
to add value and improve an organisation’s operations.  It helps an organisation
accomplish its objectives by bringing a systematic, disciplined approach to evaluate and
improve the effectiveness of risk management, control and governance processes.”
2.2 The primary aim of the internal audit service is to provide assurance services which
requires the Chief Internal Auditor to provide an annual internal audit opinion based on an
objective assessment of the framework of governance, risk management and control.
2.3 The internal audit service also provides advisory services, generally at the request of the
organisation, with the aim of improving governance, risk management and control and
contributing to the overall opinion.
2.4 The internal audit service supports the Chief Officer Resources in his role as West
Dunbartonshire Council’s (the Council) Section 95 Officer.
3. Risk Assessment and Audit Planning
3.1 The internal audit approach to annual audit planning is risk-based and all areas which
may be subject to audit review are contained within an Audit Universe which is subject to
formal review, at least annually.
3.2 The risk scoring system is maintained on a real-time basis and is altered as
circumstances change.  Regular reviews of the risk scores allow Internal Audit to address
the changing risk exposure of the organisation more effectively and ensure audit effort is
focused on those areas identified as higher risk.
Appendix 1
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2023/24 INTERNAL AUDIT ANNUAL STRATEGY AND PLAN
3.3 The Audit Universe is risk assessed each year to determine the Annual Audit Plan and
ensure that suitable audit time and resources are devoted to reviewing the more
significant areas of risk.   Each area within the Audit Universe is assessed for impact
against a number of broad risk categories as follows:
Strategy Risks associated with the setting and achievement of strategic
objectives.
Economy Risks associated with the economy in which the Council
operates.
Reputation Risks associated with threats to the Council’s name and
standing in the sector.
Customer Risks associated with customer relationships.
Legal/Regulatory Risks associated with the requirement to comply with a wide
range of statute.
Financial Risks associated with financial loss or inefficiency.
Technology Risks associated with application systems, their integrity,
security and development.
Management
Information
Risks associated with the provision of information for decision-
making purposes.
Human Resources Risks associated with people, e.g. recruitment, succession,
development, motivation and morale etc.
Operations Risks associated with the business operating process.
Business
Continuity/Resilience
Risks associated with disaster scenarios which would threaten
the continuing operation of the Council.
Security Risks associated with security over customer and the Council’s
assets.
Stakeholder Risks associated with management of stakeholder expectations
(e.g. Government or local communities)
Fraud Risks associated with asset misappropriation, corruption and
financial statement fraud.
3.4 Account has also been taken of the risks identified in the Council’s Risk Registers and
risks identified by external scrutiny bodies through local scrutiny arrangements.
3.5 There will be regular ongoing discussion with External Audit to ensure respective audit
plans are reviewed as circumstances change in order to minimise duplication of effort
and maximise audit coverage for the Council.  
4 Service Delivery
4.1 The provision of the internal audit service is through a directly employed in-house team. 
The Shared Service Manager – Audit & Fraud is provided through a shared service
arrangement with Inverclyde Council.
4.2 In relation to the total staff days allocated to the 2023/2024 plan, a resource allocation
spreadsheet is completed for each member of staff which is split between annual leave,
public holidays, training days, general administration and operational plan days.  
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2023/24 INTERNAL AUDIT ANNUAL STRATEGY AND PLAN
The combined operational plan is 800 days which will be resourced as follows:
Team Member Plan Days
Lead Auditor (0.5 FTE) 70
Auditor 50
Auditor (0.5 FTE) 90
Auditor (0.5 FTE) 90
Audit Assistant 108
Section Lead – Corporate Fraud 32
Corporate Fraud Officer 180
Corporate Fraud Officer 180
Total Plan Days 800
The Shared Service Manager – Audit & Fraud does not directly carry out the assignments
included in the annual audit plan but provides the quality review and delivery oversight of
the overall plan.  As such, no direct time is included within the plan.  The Section Lead –
Corporate Fraud does not directly carry out NFI and other investigations but provides
quality review and oversight of the work of the fraud officers and investigates any
whistleblowing enquiries that may arise.  As such, a small allocation of time is allocated
to the plan.  Where there are any resource issues which may impact on delivery of the
plan, this will be reported to Audit Committee at the earliest opportunity.  
4.3 Given the range and complexity of areas to be reviewed it is important that suitable,
qualified, experienced and trained individuals are appointed to internal audit positions.
The PSIAS requires that the Chief Internal Auditor must hold a professional qualification
such as CMIIA (Chartered Internal Auditor), CCAB or equivalent and be suitably
experienced.  The internal auditor posts must also be CMIIA/CCAB or equivalent with
previous audit experience.
4.4 Internal audit staff members identify training needs as part of an appraisal process and
are encouraged to undertake appropriate training, including in-house courses and
external seminars as relevant to support their development.  All training undertaken is
recorded in a personal training record for CPD purposes. 
4.5 Internal audit staff members require to conform to the Code of Ethics of the professional
body of which they are members and to the Code of Ethics included within the PSIAS.
An annual declaration is undertaken by staff in relation to specific aspects of the Code.
4.6 Following each review, audit reports are issued in draft format to agree the accuracy of
findings and agree risk mitigations.  Copies of final audit reports are issued to the
relevant Chief Officer and Service Manager responsible for implementing the agreed
action plan.  A copy of each final audit report is also provided to External Audit.
4.7 The overall opinion of each audit report feeds into the Internal Audit Annual Report and
Assurance Statement which is presented to the Audit Committee and is used by the s95
Officer in the preparation of the Annual Governance Statement.
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2023/24 INTERNAL AUDIT ANNUAL STRATEGY AND PLAN
5 Proposed Audit Coverage 2023-2024
5.1 The proposed audit coverage is set out in the table below.  This includes a range of risk
based reviews, limited scope financial reviews and regularity audits.
5.2 The Plan contains a contingency provision that will be utilised during the year in
response to unforeseen work demands that arise e.g. special investigations and
provision of ad hoc advice.
Audit Area Strategic Area Risk
Score
Staff
Days
Risk-Based Reviews
Corporate Complaints Corporate 6344 30
Participatory Budgeting Corporate 5124 30
Attendance Management Corporate 4392 20
Commercial Waste Roads and Neighbourhood 4209 25
FM Cleaning – Stock Control CCF 4026 15
FM Catering – Stock Control CCF 4026 15
Corporate Procurement Corporate 4575 25
Total 160
Limited Scope Financial System Reviews
Debt Recovery Resources 4600 20
Total 20
Project Assurance Reviews
Learning Disability Services Review HSCP 7320 10
Total 10
Regularity Audits
Education Control Self-Assessment Education N/A 15
High Earners – Quarterly check Corporate N/A 12
HSCP – Imprest HSCP N/A 14
Total 41
Advisory Reviews
UK Shared Prosperity Fund Corporate 6222 20
Roads – Route Optimisation Roads and Neighbourhood 4392 10
Finance/HR Establishment Controls Corporate 3660 10
Total 40
Corporate Governance Reviews
Annual Governance Statement (2022/23) Corporate - 5
Total 5
Corporate Fraud Activity
National Fraud Initiative Corporate - 100
Fraud Referrals including Joint Working - - 250
Whistleblowing and Other Investigations - - 22
Liaison with DWP - - 10
Fraud Awareness Training Corporate - 10
Total 392
Other Work
Audit follow up Corporate - 12
IJB – Internal Audit Service - - 20
VJB – Internal Audit Service - - 15
Leisure Trust – Internal Audit Service - - 15
Contingency - - 20
Completion of  2022-2023 Audit Plan - - 50
Total 132
Total Staff Days for 2023/24 800
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2023/24 INTERNAL AUDIT ANNUAL STRATEGY AND PLAN
6 Quality and Performance
6.1 The PSIAS require each internal audit service to maintain an ongoing quality assurance
and improvement programme based on an annual self-assessment against the
Standards, supplemented at least every five years by a full independent external
assessment. 
6.2 In addition, the performance of Internal Audit continues to be measured against key
service targets focussing on quality, efficiency and effectiveness.  For 2023/2024 these
have been set as follows:
Measure Description Target
1. Draft Report Percentage of draft reports issued
within 3 weeks of completion of
fieldwork.
90%
2. Final Report Percentage of final reports issued
within 2 weeks of issue of draft report.
90%
3. Audit Plan Delivery Percentage of audits completed v
planned.
85%
4. Audit Budget Percentage of audits completed within
budgeted days.
80%
5. Audit Recommendations Percentage of audit recommendations
agreed.
90%
6. Action Plan Follow Up Percentage of action plans followed
up – Internal and External Audit.
100%
7. Customer Feedback Percentage of respondents who rated
the overall quality of internal audit as
satisfactory or above.
100%
8. NFI recommended matches Percentage of National Fraud Initiative
high risk matches investigated within
timescales.
100%
9. DWP liaison Percentage of cases referred to/
actioned for DWP within DWP
timescales. 
100%
10. Staff compliance with CPD Number of training hours undertaken
to support CPD
80
11. Management engagement Number of meetings with CMT and
senior management as appropriate
1 per
quarter
6.3 Actual performance against targets will be included in the 2023/24 Internal Audit Annual
Assurance Report.
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WEST DUNBARTONSHIRE COUNCIL
Report by Chief Officer - Resources
Audit Committee: 3 May 2023
___________________________________________________________________
Subject:  National Fraud Initiative 2022/23
1. Purpose
1.1 The purpose of this report is to update Members on the current position with
regard to the National Fraud Initiative in Scotland 2022/2023 Exercise.
2. Recommendations
2.1 It is recommended that the Audit Committee notes the contents of this report
and agrees that further updates are provided to Audit Committee as part of
the Internal Audit Progress report outlining the Council’s progress with the
2022-2023 exercise.
3. Background
3.1 The NFI in Scotland is now well established with this being the 9th biennial
exercise since 2006/07. The NFI enables public bodies to take advantage of
computer data matching techniques to detect fraud and error. The NFI
remains the largest national fraud detection and prevention scheme that can
provide data matches within and between public bodies. Its key features are
that it:
• acts as a deterrent to potential fraudsters.
• identifies errors and fraud thus enabling appropriate action to recover
money and/or press criminal charges.
• can provide assurances, similar to a regular health check, that systems are
operating well and can also identify where improvements are required.
• operates across boundaries between public bodies in different sectors and
countries.
• represents value for money in terms of the efficiencies deliverable through
centralised data processing and identifying targeted high priority matches.
3.2 The NFI works by using data matching to compare a range of information held
on bodies’ systems to identify potential inconsistencies or circumstances that
could indicate fraud or error which are called ‘matches’. A match does not
automatically mean that there is a fraud or error and investigations are
required to enable the correct conclusion to be drawn for each match. Bodies
investigate these and record on a secure web application appropriate
outcomes based on their investigations.
3.3 Public bodies spend billions of pounds of taxpayers’ money for the benefit of
the Scottish population, providing services and financial assistance to all
ITEM 7
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citizens including those that need them the most. Systems underpinning public
spending can be complex and errors can happen. Unfortunately, there are
also some individuals who seek to exploit the systems and fraudulently obtain
services and benefits to which they are not entitled.
3.4 Data sharing enables bodies to match data internally and externally.
Technology provides an efficient way to connect discrete data sets and can
therefore limit the gaps available for fraudsters to manipulate and can help
identify those that have. It also supports bodies to identify and implement
process and control improvements that should reduce future errors and the
costs of correcting these errors.
3.5 Audit Scotland, working closely with public bodies, external auditors and the
Cabinet Office, has completed another major data sharing and matching
exercise. The National Fraud Initiative (NFI) exercises make a significant
contribution to the security and transparency of public sector finances by
confirming that services are provided to the correct people and by reducing
fraud and error.
4. Main Issues
4.1 For 2022/23, a number of data matches were released during January and
February 2023.  West Dunbartonshire Council has received 5,087 matches
which are set out in Appendix 1.
4.2 The 2022/23 NFI exercise will be monitored by Audit & Fraud as part of the
2023/24 Annual Audit Plan.  Training and support will be provided to Services
responsible for investigating the matches and an update on progress will be
provided on a regular basis to Audit Committee.
5. Personnel Implications
5.1 There are no personnel issues with this report.
6. Financial and Procurement Implications
6.1 There are neither financial nor procurement implications arising directly
from this report.
7. Risk Analysis
7.1 The NFI enables public bodies to take advantage of computer data matching
techniques to detect fraud and error.  This can lead to process risks being
identified during the investigation of matches and internal controls being
strengthened to reduce the risk of fraud and error recurring in the future and
improve the Council’s control environment.
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8. Equalities Impact Assessment (EIA)
8.1 There are no issues.
9. Consultation
9.1 This report has been subject to consultation with appropriate Chief Officers.
10. Strategic Assessment
10.1 This report relates to all five of the Council’s Strategic Priorities.
Laurence Slavin
Chief Officer - Resources
Date: 31 March 2023
Person to contact Andi Priestman, Shared Service Manager – Audit &
Fraud
Telephone:  01389-737436
Email:  andi.priestman@west-dunbarton.gov.uk
Appendix 1: NFI 2022/23 Exercise - Matches
Background Papers: None
Wards Affected: All wards
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National Fraud Initiative 2022/23
Total Matches Received at 31 March 2023
Area Number of
Matches
Received
Number of
Matches
Processed
Outcome Value of
Fraud
or Error No issue Fraud Error
Housing Benefit to Student
Loans
7
Housing Benefit to Housing
Benefit
2
Housing Benefit to Housing
Tenants
54
Housing Benefit to Taxi Drivers 4
Housing Benefit to DWP
Deceased
23
Payroll to Payroll 71
Payroll to Pensions 10
Housing Benefit to Waiting Lists 13
Housing Tenants to Housing
Tenants
396 3 3
Housing Tenants to Housing
Benefit Claimants
21
Housing Tenants to DWP
Deceased
182
Blue Badge 241
Waiting List to Housing Tenants 133 8 8
Waiting List to Housing Benefit
Claimants
65
Waiting List to Waiting List 68
Waiting List to DWP Deceased 20
Council Tax Reduction Scheme
to Payroll
101
Council Tax Reduction Scheme
to Pensions
154
Council Tax Reduction Scheme
to Council Tax Reduction
Scheme
14
Council Tax Reduction Scheme
to Housing Tenants
114
Council Tax Reduction Scheme
to Taxi Drivers
15
Housing Tenants to Council Tax
Reduction Scheme
16
Council Tax Reduction Scheme
to Housing Benefit Claimants
22
Council Tax Reduction Scheme
to DWP Deceased
44
Duplicate Creditors 3222
Procurement - Payroll to
Companies House
51
Housing Tenants to State
Benefits
24
Total 5087 11 11 0 0 0
Appendix 1
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WEST DUNBARTONSHIRE COUNCIL
Report by Chief Officer - Resources
Audit Committee: 3 May 2023
Subject:  Review of Internal Audit Charter
1. Purpose
1.1 The purpose of this report is to advise Members that a review of the
Internal Audit Charter has been undertaken and the Charter updated to
more closely reflect the requirements of Standard 1000 of the Public
Sector Internal Audit Standards (PSIAS).
2. Recommendations
2.1 It is recommended that Members approve the Internal Audit Charter.
3. Background
3.1 The PSIAS are based on the mandatory elements of the International
Professional Practices Framework (IPPF) of the Global Institute of
Internal Auditors (IIA) and are intended to promote further improvement
in the professionalism, quality, consistency and effectiveness of
internal audit across the public sector. The Standards were revised on
1 April 2017 to reflect the latest changes in the IPPF.
3.2 Standard 1000 of the PSIAS sets out the requirement for an Internal
Audit Charter which is a formal document that defines the Internal Audit
activity’s purpose, authority and responsibility and establishes the
Internal Audit activity’s position within the organisation. Final approval
of the Internal Audit Charter resides with the Audit Committee.
3.3 The Internal Audit Charter requires to be subject to a formal review
every 5 years.
4. Main Issues
4.1 The Internal Audit Charter was last approved by the Audit Committee in
June 2018.  This report fulfils the requirement for a formal review of the
Charter every 5 years.
4.2 Although there were no substantive changes required,  the Internal
Audit Charter has been updated to more closely reflect the
requirements of Standard 1000 and the updated Internal Audit Charter
is set out at Appendix 1.
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4.3 In relation to the quality assurance and improvement programme, a
self-assessment is undertaken on an annual basis by the Shared
Service Manager – Audit & Fraud to ensure compliance with the Public
Sector Internal Audit Standards.
4.4 In relation to the formal external assessment, West Dunbartonshire
Council participates in a validated self-assessment peer review
process through the Scottish Local Authorities Chief Internal Auditors
Group. The peer review process was scheduled for West
Dunbartonshire Council in 2022 however this has not yet taken place.
There was a delay to the external assessment programme across all
Scottish Local Authorities as a result of COVID. This has been
escalated through the Chief Internal Auditors Group and revised dates
are being scheduled for all external assessments which have been
delayed.
5. People Implications
5.1 There are no personnel issues.
6. Financial and Procurement Implications
6.1 There are no financial implications.
7. Risk Analysis
7.1 The Charter clarifies the purpose of the Internal Audit function and
details its principal roles and responsibilities. The document largely
codifies existing practice and does not alter the existing role of Internal
Audit or signify any change in how Internal Audit will discharge its role.
Accordingly, there are no significant new developments or issues
arising from the review of the Internal Audit Charter which require to be
highlighted.
8. Equalities Impact Assessment (EIA)
8.1 There are no issues.
9. Consultation
9.1 This report has been subject to consultation with appropriate Chief
Officers.
10. Strategic Assessment
10.1 This report relates to strong corporate governance.
.........................................
Laurence Slavin
Chief Officer - Resources
Date: 31 March 2023
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_________________________________________________
Person to Contact:  Andi Priestman, Shared Service Manager – Audit &
Fraud
Email: andi.priestman@west-dunbarton.gov.uk
Appendices: Appendix 1 – Internal Audit Charter
Background Papers: Report to Audit and Performance Review
Committee on 13 June 2018 (Internal Audit
Charter Update)
Public Sector Internal Audit Standards
Wards Affected: All Wards
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Internal Audit Charter
Purpose
The Public Internal Audit Standards (PSIAS) require that the Internal Audit Charter defines the terms
‘board’ and, ‘senior management’ in relation to the work of Internal Audit. For the purposes of Internal
Audit work:
• Board - refers to the Council’s Audit Committee which has delegated responsibility for overseeing
the work of Internal Audit
• Senior management - is defined as the Chief Executive and members of the Council’s Corporate
Management Team (CMT)
The purpose of West Dunbartonshire Council’s Internal Audit activity is to provide independent,
objective assurance and advisory services designed to add value and improve the Council’s
operations.  The mission of Internal Audit is to enhance and protect organisational value by providing
risk-based and objective assurance, advice and insight.  The Internal Audit activity helps West
Dunbartonshire Council accomplish its objectives by bringing a systematic, disciplined approach to
evaluate and improve the effectiveness of governance, risk management and control processes.
Professional Standards
The Internal Audit team operates in accordance with the PSIAS and will additionally adhere to the
Code of Ethics as contained within the PSIAS.  The Chief Internal Auditor will report periodically to
senior management and Audit Committee regarding the Internal Audit team’s conformance to the
Code of Ethics and the PSIAS.
Authority
The Shared Service Manager – Audit & Fraud reports functionally to the Council’s Chief Officer –
Resources (s95 Officer).  The Shared Service Manager – Audit & Fraud has a right of access and
freedom to report in her own name to all officers and members and particularly those charged with
governance.  This reporting structure protects the independence of the Shared Service Manager –
Audit & Fraud and promotes an appropriate profile for the Internal Audit team throughout the
organisation.
To establish, maintain and assure the Council’s Internal Audit team has sufficient authority to fulfil its
duties, the Audit Committee will:
• Approve the Internal Audit activity’s charter.
• Approve the risk-based Internal Audit plan.
• Receive regular reports from the Shared Service Manager – Audit & Fraud on the Internal Audit
team’s performance relative to its plan and other matters.
The Shared Service Manager – Audit & Fraud or an authorised representative shall have authority to:
• Enter at all reasonable times any of the Council’s premises or land.
• Have access to all records, documents and correspondence relating to the Council, wherever they
are held.
• Require and receive such explanations as are necessary concerning any matter under
examination.
• Require any employee of the Council to produce any of the Council’s property, including property
held by the Council as security or on the behalf of others, under that employee’s control.
In carrying out their duties, Internal Auditors will have full and unrestricted access to all Council
functions, records, property and personnel necessary for their work.  
Independence and Objectivity
The Shared Service Manager – Audit & Fraud will ensure that the Internal Audit team remains free
from all conditions that threaten the ability of internal auditors to carry out their responsibilities in an
unbiased manner, including matters of audit selection, scope, procedures, frequency, timing and
report content.
Appendix 1
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Internal Audit Charter  Appendix 1
The Internal Audit team will maintain an unbiased mental attitude that allows them to perform
engagements objectively.  Internal Audit will make a balanced assessment of all the relevant
circumstances and not be unduly influenced by their own interests or by others in forming
judgements.
The Internal Audit team will have no direct operational responsibility or authority over any of the
activities audited.  Accordingly, they will not implement internal controls, develop procedures, install
systems, prepare records or engage in any other activity that may impair their judgement.
The CIA has additional responsibilities for counter fraud arrangements. The CIA will declare an
interest for audit assignments in this area with the next most senior internal audit team member taking
additional reporting responsibilities if a conflict arises. A further option, if required, is for the CIA of
another local authority to provide oversight of an audit where there is a possible conflict of interest.
The Shared Service Manager – Audit & Fraud will confirm to the Audit Committee at least annually
the organisational independence of the Internal Audit team.
Scope of Internal Audit Activities
The scope of the Internal Audit activity encompasses:
• Strategic development of the Internal Audit function to best meet the Council’s needs.
• The continuous professional examination and evaluation of the overall adequacy and
effectiveness of the Council’s system of internal control ensuring risk inherent in the business is
adequately identified, evaluated and managed and providing advice on control implementation.
• Agreeing with management improvements to the control environment where considered desirable
or necessary and monitoring and reporting on the implementation of these remedial actions by
management.
• Reviewing the reliability, integrity and timeliness of financial and operational information supplied
to management and to the members, and the means used to identify, measure, classify and report
such information.
• Reviewing the systems and controls established to ensure compliance with those policies, plans,
procedures, laws and regulations which have specific impact on the Council.
• Reviewing the means used to safeguard assets and, as appropriate, the existence of such assets.
• Assisting the s95 Officer in the discharge of statutory responsibilities as “proper officer” for
ensuring the proper administration of the Council’s financial affairs.
• Managing the risk of fraud and corruption is the responsibility of the CMT. Management is also
responsible for developing, implementing and maintaining systems of internal control to guard
against fraud or irregularity and ensure probity in systems and operations. Internal Audit will assist
management by reviewing the controls and procedures in place.
• Undertaking National Fraud Initiative and other investigations of suspected frauds and
irregularities and contributing to the promotion of an anti-fraud culture within the Council.
• Supporting management in respect of disseminating control best practice and promoting risk
awareness throughout the Council, including during key business change initiatives.
• Working closely with the external auditors to ensure the maximum benefit is achieved for the
Council from their respective roles and that any duplication of effort is eliminated.
Internal Audit Plan
At least annually, the Shared Service Manager – Audit & Fraud will submit to senior management and
the Audit Committee a risk-based Internal Audit plan for review and approval.  The Internal Audit plan
will consist of a work schedule as well as budget and resource requirements for the next financial
year.  The Shared Service Manager – Audit & Fraud will communicate the impact of any resource
limitations and significant interim changes to senior management and the Audit Committee.
The Internal Audit plan will be developed based on a prioritisation of the audit universe using a risk-
based methodology, including input from senior management and the Audit Committee.  The Shared
Service Manager – Audit & Fraud will review and adjust the plan as necessary in response to any
changes in the Council’s operations, risks, programmes, systems and controls.  Any significant
deviation from the approved Internal Audit plan will be communicated to senior management and the
Audit Committee through periodic activity reports.
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Internal Audit Charter  Appendix 1
Reporting and Monitoring
A written report will be prepared and issued by the Shared Service Manager – Audit & Fraud or
designated officer following the conclusion of each Internal Audit engagement and will be distributed
as appropriate.  
The Internal Audit Report will include management’s agreed actions taken or to be taken in regard to
specific findings identified together with a timetable for implementation.  The Internal Audit team will
be responsible for appropriate follow-up of agreed actions.  Progress on action plan implementation
will be communicated to senior management and the Audit Committee through periodic Internal Audit
activity reports.
Quality Assurance
The Internal Audit activity will maintain a quality assurance and improvement programme that covers
all aspects of the Internal Audit activity.
The Chief Internal Auditor will communicate to senior management and the Audit Committee on the
Internal Audit activity’s quality assurance and improvement programme including results of ongoing
internal assessments and external assessments conducted at least every 5 years.
31 March 2023
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WEST DUNBARTONSHIRE COUNCIL
Report by Chief Officer- Citizen, Culture & Facilities
Audit Committee: 3 May 2023
___________________________________________________________________
Subject: Scottish Public Services Ombudsman Complaints Report 2021-22
1. Purpose
1.1 The purpose of this report is to present the Scottish Public Services
Ombudsman (SPSO) report on complaints handling by West Dunbartonshire
Council for the year 1 April 2021 – 31 March 2022. 
2. Recommendations
2.1 It is recommended that Committee:
• Notes the contents of the report and the ongoing commitment at a service
and strategic level to monitor complaints and ensure compliance with
Scottish Public Services Ombudsman (SPSO) timelines
3. Background
3.1 West Dunbartonshire Council adopted the SPSO complaint handling model
operating in line with all other Local Authorities on 1 April 2013.  Complaints
continue to be managed centrally by the Customer Relations team for all
Council services. Complaints regarding West Dunbartonshire Health and
Social Care Partnership (HSCP) are managed independently by the
partnership.  
Statutory appeals and reviews, such as planning decision appeals, continue to
be directed to the relevant decision making body, and are not processed
through the SPSO office.
3.2 The Complaints Handling Process is well established and understood by both
customers and staff. Centralised complaints handling ensures an open and
transparent process. Complaints are valued because they provide an insight
into services, and how the Council is performing. The feedback offers
valuable information helping to inform service planning, improve how services
are delivered and ensure customer’s voices are heard and views considered. 
Customers who remain dissatisfied with the final outcome of their complaint
are openly directed to the SPSO to have their case considered for review.
3.3 West Dunbartonshire Council acts as factor for the buildings where we retain
an interest with tenanted properties.  Anyone who remains dissatisfied with
the outcome of their complaint may be also signposted to the First-tier
Tribunal for Scotland (Housing and Property Chamber). The Tribunal is an
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independent and impartial judicial body whose function is to review complaints
from homeowners who consider their property factor has failed to perform its
factoring duties or failed to comply with the Property Factors’ Code of
Conduct.  
3.4      As a member of the Local Authority Complaints Handlers Network, the
Council continues to fully engage in sharing of good practice, and developing
consistent approaches to complaints handling and reporting. Network
meetings are held regularly, with SPSO in attendance at each meeting.  
4. Main Issues
4.1 The SPSO delivers an annual report to each Local Authority detailing the
number of complaints reported to its office.  Appendix 1 provides a
breakdown of enquiries handled by SPSO relating to West Dunbartonshire
Council for 2021-22 together with comparison data for 2020-21.  Appendix 2
is a summary breakdown of complaints received by the Council in 2021-22. 
Appendix 3 shows Social Work complaints handled by the HSCP for the
same period.  
4.2 In the year 2021-22, SPSO received 15 complaints regarding the Council, a
decrease of 17 from 2020-21. The highest proportion of complaints made by
West Dunbartonshire customers related to housing matters. 
4.3 Of the 15 complaints to SPSO, 3 were deemed as premature, which is
terminology used by the SPSO when the complainant has not exhausted the
Council’s complaints process. A further 2 were closed by SPSO as unable to
proceed.  SPSO considered 5 of the complaints demonstrated good complaint
handling and further investigation was not needed.  Of the complaints
considered 2 were closed by SPSO as insufficient benefit would be achieved
by investigation.  A further 2 complaints were referred back to West
Dunbartonshire Council.   
4.4 An investigation was carried out on one complaint raised against West
Dunbartonshire Council. Following investigation the complaint was deemed
not upheld.  This is positive and reflects on the high level of effective
complaints handling within West Dunbartonshire Council.
4.5 As outlined in Appendix 2, the Council handled 891 complaints internally in
2021-22.  Of these, 627 were closed within 2021-22.  The difference in
complaints handled and closed is due to complaints being received during the
reporting period, but still being worked on.  The remaining 264 were closed in
2022-23 and will be included in appropriate reporting periods.  When
registering a complaint, residents preferred method is by telephone which
accounted for 37% of all complaints received.  The online complaints form is
the next preferred method accounting for 34%.    
4.6 As noted above, the number of complaints received in 2021-22 was 891. This
represents an increase of 12% when compared to complaints received in
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2020-21.  It is important to continue to encourage capturing expressions of
dissatisfaction.  Complaints data provides services with valuable information
to inform service improvement and understand the expectations of
Customers. 
4.7 Of the 627 complaints closed, 64% were resolved within SPSO timescales,
including with extension where applicable, representing a decrease of 5%
from 2019-20. Customer Relations maintain a focus on right first time and is
committed to ensuring the quality of responses remains high whilst seeking to
improve response times again in 2022-23.   
4.8 In line with this, the service continue to work to encourage a culture of
welcoming complaints and ensuring services across the Council use the data
provided to identify and progress improvement activity.   
5. People Implications 
5.1 There are no people implications arising from this report. 
6. Financial and Procurement Implications 
6.1 There are no financial implications arising from this report. 
7. Risk Analysis 
7.1 There is a reputational risk in not responding to complaints in defined time
periods within the two stage process.  Complaints data is closely monitored,
including response times and quality of response from services.  Customer
Relations continue to work to support services to improve response
timescales and maintain quality of complaints management.   
7.2 There is a risk that services do not learn from the complaints received and do
not adapt processes or policies to stop it happening again. To reduce this risk
complaints data is reported quarterly to Performance & Monitoring Group. 
Complaints data is also shared with Chief Officers and included within service
Delivery Plans to ensure visibility and to assist in informing service
improvements. 
8. Equalities Impact Assessment (EIA) 
8.1 The two stage process has been equality impact assessed at a National level.
Locally, all aspects have been considered and assistance to navigate the
complaints process is available for all customers. 
9. Consultation 
9.1 Not applicable to this report. 
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10. Strategic Assessment 
10.1 Effective complaints handling contributes to delivery of all four of the Council’s
strategic priorities. 
Chief Officer: Amanda Graham 
Date:  3 April 2023 
___________________________________________________________________ 
Person to Contact: Stephen Daly  
Citizen & Library Manager  
Citizen, Culture and Facilities 
Council Offices, 16 Church Street, Dumbarton  
01389 737263     
Appendices: Appendix 1 – SPSO Complaints Data  
Appendix 2 - Summary of Council Complaints 2021-22  
Appendix 3 -  Summary of HSCP Complaints 2021-22 
Background Papers: None 
Wards Affected: All Wards
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West Dunbartonshire Council complaints closed 2021-22
STAGE OUTCOME GROUP
West
Dunbartonshire
Council
Advice Member of the public test not met (s 5 (6)) 0
Premature 3
Unable to proceed 2
Total 5
Early
Resolution
Cause and impact test not met (s 5 (3)) 0
Discretion –  Insufficient benefit would be
achieved by investigation
2
Discretion – alternative action proposed 0
Discretion – Alternative route used or available 0
Discretion - Good complaint handling 5
Discretion – referred back 2
Discretion - Resolved - both parties satisfied with
proposed outcome
0
Member of the public test not met (s 5 (6)) 0
Organisation not in jurisdiction 0
Premature 0
Right of appeal to court/tribunal/Scottish ministers
(s 7 (8))
0
Subject matter not in jurisdiction 0
Time limit (s 10) 0
Unable to proceed 0
Total 9
Investigation Fully upheld 0
Not upheld 1
Outcome not achievable 0
Resolved 0
Some upheld 0
Total 1
TOTAL COMPLAINTS 15
Appendix 1
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West Dunbartonshire Council complaints closed 2020-21 
Stage Outcome Group
West
Dunbartonshire
Council
Advice Discretion – alternative action proposed 0
Organisation not in jurisdiction 0
Premature 10
Subject matter not in jurisdiction  0
Unable to proceed 4
Total 14
Early
Resolution
Cause and impact test not met (s 5 (3)) 0
Discretion –   alternative route used or
available
1
Discretion –  Insufficient benefit would be
achieved by investigation 
1
Discretion – alternative action proposed 2
Discretion - Good complaint handling 10
Discretion – referred back 0
Member of the public test not met (s 5
(6))
0
Premature 1
Right of appeal to court/tribunal/Scottish
ministers (s 7 (8))
0
Subject matter not in jurisdiction  0
Time limit (s 10) 0
Unable to proceed 1
Total 16
Investigation Fully upheld 0
Not upheld 1
Some upheld 1
Total 2
Total Complaints 32 
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Year 2021-22 Outcome
Performance & Monitoring
Total
Complaints
Received
Complaints
Received
Stage 1
Complaints
Received
Stage 2
Total
complaints
closed
Closed at
Stage 1
Closed
within  5
Working
Days
Extension
Stage 1
Exceeded S1
deadline after
extension ie
+10days
Total working
days to close
Stage 1
complaints
Average
working days
to close S1
Closed at
Stage 2
Closed
within 20
working
days
Extension
Stage 2
Exceeded S2
deadline
after
extention ie
+25
Total working
days to close
Stage 2
complaints
Average
working days
to close S2
Escalated
from Stage 1
to 2
Upheld
Stage 1
Not
Upheld
Stage 1
Upheld
Stage 2
Not upheld
Stage 2
Withdrawn
People & Technology 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
Regulatory 18 15 3 9 7 4 2 1 55 8 2 1 0 1 55 28 1 3 4 1 1 0
Resources 84 73 11 57 49 26 14 9 408 8 8 5 1 2 112 61 5 26 23 3 5 0
Communications, Culture, Communities & Facilities 31 30 1 25 24 19 4 1 100 4 1 1 0 0 20 20 0 11 13 0 1 0
Education, Learning & Attainment 107 96 11 80 71 60 6 5 424 6 9 8 0 1 95 29 6 36 35 2 7 0
Roads & Neighbourhood 216 205 11 161 153 114 20 19 877 6 8 1 2 5 223 74 4 96 57 5 3 0
Housing & Employability 80 67 13 56 43 33 6 4 199 5 13 8 1 4 281 64 7 16 27 4 9 1
Regeneration 249 227 22 189 162 86 30 46 2010 12 27 5 4 18 1145 150 7 115 47 20 7 0
Totals 785 713 72 577 509 342 82 85 4073 8 68 29 8 31 1931 28 30 303 206 35 33 1
80%
0 8
517 28
122 60%
6 51%
1
8 Channel Received
0 272 0
64 372
56 10
9 10
0 121
2 0
Social Media 0
785 785Total 303 35 TOTAL
Contractor 0 0 Face to Face
Failure to deliver service 3 0 In Writing
Service standards not declared 0 0 By telephone
Error in Service Delivery 21 0 Internal Complaints form
Council policy – level of service provision 0 0
Employee behaviour 19 1 Online Complaints form
Equalities
Delay in service delivery 0 0 E-mail Equality concern raised
Council policy – charges 0 0 % of Stage 2 complaints upheld
Council policy – does not meet criteria 0 0
Citizen expectation not met – timescales 66 7 % of Stage 1 complaints upheld
Below declared service standard 0 0 average working days to close Stage 1 complaints
Citizen expectation not met - quality of service 194 27 average working days to close Stage 2 complaints
Complaints Received Complaints Closed
Complaint Category Upheld per category
Stage 1
Upheld per
category Stage 2
Performance
% of complaints closed within SPSO timescales
Appendix 2
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WDHSCP – Social Work Complaints Data
Period: 1st April 2021 - 31st March 2022
Social Work Services Total
Children’s Health, Care & Criminal Justice 31
Community Health and Care Services 18
Mental Health, Learning Disability & Addictions 11
Total
Subject
Communication 5
Failure to fulfil statutory responsibilities 3
Failure to provide service 2
Failure to Achieve Standards 8
Quality of Service 8
Data Breach 0
Bias or unfair discrimination 0
Employee Attitude 0
Other 3
Response
Acknowledged within 3 days  60
Response within 28 days 6
Outcomes
Upheld 0
Unsubstantiated 0
Partially Upheld 8
Not Upheld 9
Ongoing* 3
*Will be responded to in Quarter 1 2022/23
Appendix 3
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