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Item 5 - Internal Audit Plan 2023-2024 - Progress to 24 January 2024

West Dunbartonshire Council · 21 February 2024
Back to Audit Committee — 21 February 2024 and its agenda

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WEST DUNBARTONSHIRE COUNCIL
Report by Chief Officer – Resources
Audit Committee: 21 February 2024
Subject: Internal Audit Plan 2023/24 – Progress to 24 January 2024
1. Purpose
1.1 The purpose of this report is to advise Members of progress at 24 January 2024
against the Internal Audit Plan for 2023/24.
1.2 The report also advises Members of:
• recently issued Internal Audit reports and action plans
• the 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 2023/24 was approved by the Audit Committee on 8
May 2023.  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
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 There were two audit reviews finalised since the last Audit Committee in December
2023:  
Complaints Handling
4.5 By definition local councils are elected bodies that provide frontline services to local
residents and external organisations that represent the interests of their local
communities. Service users may complain whenever failures in service occur,
including perceived failures. Therefore the Council must have effective processes
and controls in place for managing complaints.
4.6 The objective of this audit was to provide management and the Audit Committee
with an assessment on the adequacy and effectiveness of the governance, risk
management and control procedures in relation to the corporate complaints
process.
4.7 The review focused on the high-level processes and procedures in relation to the
handling of corporate complaints and concentrated on identified areas of perceived
higher risk such as valid complaints not being completely and accurately recorded,
acknowledged and responded to in a timely manner or arrangements not being in
place to improve service delivery by learning lessons from valid complaints.

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4.8  The overall control environment opinion was Requires Improvement.  One RED
and 4 AMBER issues were identified as follows:
Lack of centralised recording of complaints (Red)
Complaints handling should demonstrate structured interactions between
complainants and staff and comply with the Scottish Public Sector Ombudsman
(SPSO) Model Complaints Handling Procedures (MCHP) and it is essential that all
complaints received are recorded and investigated in a timely manner.
The Corporate Complaints team log all complaints received on a central
spreadsheet and send details of the complaint to the relevant service for
investigation. However, the audit identified that where services receive complaints
directly, these are not always recorded, or are recorded locally and are not routinely
sent to the Corporate Complaints team to record on the central spreadsheet. We
were not able to reconcile complaint records held locally against the central
spreadsheet.
This has resulted in some complainants experiencing delays in receiving an
acknowledgment or responses to their complaints which may result in adverse
criticism of the Council’s complaints handling process. There is also a risk that
corporate reporting on complaints is not complete and does not allow for root cause
analysis of complaints and identifying any lessons learned.
Managing complainants who contact Councillors, MSP’s and Chief Officers directly
(Amber)
It is the democratic right of service users to contact any council representative to
lodge a complaint. Some service users wrongly assume that complaints must be
addressed via email directly to Councillors, MSP’s and Chief Officers to facilitate
quick responses. For these situations it is unknown if compliance can be
demonstrated with the MCHP’s, as in most cases there are no formal logs retained.
Complaints received via Democratic Services and the Leadership Support Team
are recorded but there are no internal processes to ensure these are passed on to
be formally logged by the Complaints team.
The WDC Complaints online process requires the complainant to complete a
standard form, which is formally logged and recorded by the corporate complaints
team. This results in Councillors, MSP’S and Chief Officers only becoming involved
at designated and appropriate stages of the complaints process. It is difficult to
effectively manage complaints when complainants and officers are not supported
by clear and adequately communicated internal complaints processes to support
compliance with the MCHP. It is important complainants understand the staged
process of their individual complaint at the outset which will assist them in terms of
expectations and the next steps to take if the resolution to their complaint is not
satisfactory.

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Adequacy of complaints procedures (Amber)
Complainants and staff expect procedures to support them in achieving reasonable
outcomes. During our fieldwork we identified a lack of internal guidance to support
compliance with the SPSO MCHP. We identified the following areas where
guidance would be beneficial:
• the MCHP’s are available on the intranet for services to follow, however there
are no internal processes to support these procedures in relation to specific staff
roles, responsibilities and information flows at each stage of the complaints
process including prescribed timescales and management sign-off;
• there is no step by step guidance for staff to follow for all complaint pathways to
ensure that all complaints are handled in accordance with the MCHP;
• guidance to distinguish between valid complaints as opposed to requests for
service or information could be clearer;
• there is a lack of clarity concerning the recording of complaints which are
resolved quickly. We understand that all complaints are not always recorded or
logged when dealt with successfully by services;
It is essential that all relevant staff have access to and fully understand the
complaints procedures they require to perform their role.
Adequacy of complaints reporting (Amber)
The reporting arrangements for complaints must be linked to the accountability of
services. However the audit identified the following issues in relation to reporting of
complaints:
• oversight of complaints is not fully in place at each level of management across
all council services, as the reports produced and presented quarterly at
Performance & Monitoring Review Group and annually to the Audit Committee
only include those complaints logged and recorded by the Corporate Complaints
team. It is therefore difficult to determine the levels of complaints received and
dealt with directly by services;
• due to the limitations in some services in relation to recording complaints the
frequency of reporting at each level of management has not been determined;
• lack of centralised system limits the ability to undertake root cause analysis and
identify any lessons learned;
• complaints performance indicators are illustrated on reports produced by the
Corporate complaints team for those complaints they formally log, however it is
unclear whether all services meet the staged complaints performance indicators
set in the MCHP due to the limitations in formally logging.
Without adequate oversight of complaints at each level of management it is difficult
to demonstrate compliance with the MCHP’s. Also, infrequent and inadequate
reporting of complaints may cause some external stakeholders to conclude that the
council does not regard complaints as a priority.

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Training arrangements for staff involved in handling complaints (Amber)
Effective management of complaints involves training staff, especially those on the
frontline and their supervisors. The audit identified some issues with the current
training arrangements, namely:
• the training needs of services on handling complaints should be developed;
• expected mandatory training in handling complaints has not been fully
determined across relevant posts responsible for investigating and responding
to complainants;
• there is no formal complaints training timetable for complaints handling Council
Staff.
Successful implementation of the complaints handling procedures is unlikely to be
achieved without training of staff. If mandatory training and good internal processes
are not introduced to staff responsible for complaints handling it may result in non-
compliance with complaints handling procedures.
4.9 The audit identified five significant control issues and an action plan is in place to
address all issues by 31 March 2024.
FM Catering - Stock Control
4.10 WDC is committed to providing healthy, nutritious, good value meal options to
pupils from early years up to secondary schools. Catering staff prepare around 1
million meals per annum and all catering staff are trained in food hygiene and all
hold an Elementary Food Hygiene Certificate and receive regular refresher training.
All kitchens follow the HACCP guidance and comply with Environmental Health
legislation. All menus which are standardised (rolling menus) comply with the
Scottish Government's Schools (Health Promotion and Nutrition) (Scotland) Act
2007 and with Healthy eating in schools - guidance 2020.
4.11 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 West Dunbartonshire Council
in relation to FM Catering – Stock Control.
4.12 The scope of the review focused on the high-level processes and procedures in
relation to FM Catering Stock Control and concentrated on identified areas of
perceived higher risk such ensuring catering supplies ordered, received and utilised
were valid, checked and recorded, regular stock checks were undertaken and
wastage/disposal of stock was accurately recorded and checked.
4.13 The overall control environment opinion was Satisfactory.  Areas of good practice
were identified including stock areas were found to be in order and stock rotation
was being carried out.

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There were 5 Amber issues identified as follows:
Lack of Documented Procedures (Amber)
The audit identified a lack of documented internal procedures to support staff who
deal with catering stock control. Gaps identified include:
• Incorrect stock sheets/shopping lists were being used at the two high schools
visited;
• Issues with the completion, saving and storage of stock
spreadsheets/templates; and
• No formal guidance on use of premises, equipment and foodstuff for personal
purposes.
Where documented procedures are not in place this may result in errors and
inconsistent approaches.
Insufficient Staffing of Stock Count Processes (Amber)
When counting stock, good practice suggests that there should always be two staff
involved in carrying out this process with one counting and the other checking. It
was identified that from three out of the four schools visited, monthly and annual
stock counts are carried out predominantly by one member of staff with only
occasional assistance from another member of staff.
Where two members of staff are not involved in the stock count process, this could
result in errors or omissions going undetected.
Lack of Independent Check of Stock Check Documentation (Amber)
Audit testing of stock checks carried out at a sample of establishments for periods
5-7 identified some issues as follows:
• The audit identified that there is no independent check undertaken of stock
checks carried out by management to ensure completeness and accuracy of the
process.
• Audit testing identified some issues including:
o The Catering Managers at the two secondary schools visited are not using
the correct spreadsheet to record the monthly stock count information
resulting in some items requiring to be manually added to the spreadsheet.
However these manual entries are not included in the spreadsheet formula
which provides the final stock count figure. In some instances, this resulted in
an incorrect Final Stock Count figure being reported on the management
form;
o Within the stock form spreadsheets, cells containing formula are not
protected.  This includes prices that should only be changed/updated by the
Food & Nutritional Coordinator; and
o Catering Managers lack sufficient knowledge and understanding of working
with spreadsheets.
Where there is no independent check of stock checks there is a risk that errors in
stock control figures arise or inconsistent practices are not being identified.

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Inadequate Process for Approval of Invoices (Amber)
It is the responsibility of the approver of each invoice to review all transactions to
ensure that all financial accounting details, receipts and the correct VAT has been
recorded correctly. However, due to the high volume of invoices received, the
Facilities Officer is unable to carry out detailed checking of invoices for validity. 
Without suitable checks, invoices could be paid for items which are not authorised
or appropriate.
Lack of checking Compliance with the Shopping List (Amber)
Monthly service reviews are carried out by Team Leaders, however stock is not
checked for compliance to the Shopping List as part of the service review.  In
addition, although Food for Life Compliance visits are carried out, details of the
visits are not documented.
Where adequate checks are not undertaken or recorded, management cannot be
confident that stock held is compliant with the approved Shopping List.
4.14 The audit identified nine issues, five of which we consider to be individually
significant and an action plan is in place to address all issues by 30 September
2024.
4.15 The status of the 2023/24 audit plan is attached at Appendix 1.
4.16 In relation to audit work for the Integration Joint Board, the 2023/24 is underway
with regular reporting to the Integration Joint Board Audit & Performance
Committee.
4.17 In relation to the Valuation Joint Board, planning for the 2023/24 audit plan has not
started.
4.18 In relation to the Leisure Trust, the 2023/24 audit plan is underway.
4.19 Internal and External Audit Action Plans
In relation to audit action plans, these are monitored by Internal Audit on a monthly
basis.  There were 8 actions due for completion by the end of December, 6 of which
have been reported as completed by management and the completion date relating
to 2 actions has been revised.  The status report at 31 December 2023 is provided
at Appendix 2.
Ongoing Corporate Fraud Team Work
4.20 The Corporate Fraud team’s day to day work continues to focus on referrals relating
to council tax reduction/single person discounts, joint working with DWP in relation
to housing benefit and council tax reduction, referrals relating to housing tenancies
and investigating relevant national fraud initiative matches.
4.21 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 for example in relation to whistleblowing enquiries.

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National Fraud Initiative
4.22 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 set timescale and report back on any
savings.
4.23 The matches for the 2022 exercise have now been received and investigations are
underway.  To date 690 matches have been investigated with 13 frauds being
detected totalling £20,823 relating to Housing Benefit or Council Tax Reduction
Scheme matches which are being recovered.
Benchmarking
4.24 In accordance with the Council’s Strategic Improvement Framework, the
Council’s Internal Audit service continues to be part of a benchmarking group
which involves seven other Councils.
4.25 Meetings will continue to take place during 2024 to review performance and
identify other areas for sharing of best practice.    
5. People Implications
5.1 There are no people implications.
6. Financial and Procurement Implications
6.1 The Corporate Fraud Team activity can result in actual recoveries, charges and
re-billings.  The total amount of annual recoveries, charges and re-billings
identified will be included in the Internal Audit Annual Report for 2023/24.
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.

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10. Strategic Assessment
10.1 This report relates to strong corporate governance.
....................................
Laurence Slavin
Chief Officer - Resources
Date: 24 January 2024
Person to Contact: Andi Priestman, Shared Service Manager – Audit & Fraud
E-mail: andi.priestman@west-dunbarton.gov.uk
Appendices: 2023/24 Annual Audit Plan – Progress to 24 January 2024
(Appendix 1)
Status of Internal Audit Action Plans at 31 December 2023
(Appendix 2)
Background Papers: Audit Committee – 8 May 2023: Internal Audit Annual Plan
2023/24
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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