Democracy Spraffa

Internal and External Audit Report Follow Up 2025-26

Argyll and Bute Council · 16 December 2025
Back to Audit and Scrutiny Committee — 16 December 2025 and its agenda

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Page 1

ARGYLL AND BUTE COUNCIL  AUDIT AND SCRUTINY COMMITTEE                                                            
FINANCIAL SERVICES  16 December 2025 
INTERNAL AND EXTERNAL AUDIT REPORT FOLLOW UP 2025-26 
1.0 INTRODUCTION 
1.1 Internal and external audit reports include an action plan with a
management response establishing the agreed action, timescale and
responsible officer. Internal Audit record these in a database and, on a
quarterly basis, follow them up to ensure they are being progressed. 
1.2 This report updates the committee on all open actions as at 30
September 2025 including information on actions where the agreed
implementation date has been rescheduled or evidence is required to
confirm completion.   
2.0 RECOMMENDATIONS 
2.1 To endorse the contents of the report. 
3.0 DETAIL 
3.1 The two tables below provide a numerical summary of open audit actions
with a split between actions due by and due after 30 September 2025. 
3.2 Appendix 1 provides a visual representation of progress in addressing
agreed actions. 
3.3 Appendix 2 provides further detail on actions that have been delayed and
rescheduled or where evidence is required to confirm completion.

Page 2

Table 1 – Actions due by 30 September 2025
Service
Complete
Delayed/
Rescheduled
Evidence
Required
Total
Internal Audit
DH – Commercial Services  1  1
DH – Education Wellbeing, Inclusion & Achievement 1   1
DH – Legal & Regulatory Support 1   1
KF – Development & Economic Growth 1 2  3
KF – Roads & Infrastructure Services 3 1  4
H&SCP (SW) – Adult Services (Mental Health Learning Disability,
Addictions & Lifelong Conditions) 
2  2
H&SCP (SW) – Adult Services (Older Adults & Community
Hospitals)
1   1
H&SCP (SW) – Finance/Transformation  1  1
H&SCP (SW) – Strategic Planning & Performance 1 1  2
H&SCP (IJB) – Adult Services (Older Adults & Community Hospitals)  1  1
H&SCP (IJB) – Finance/Transformation  2  2
H&SCP (IJB) – Strategic Planning & Performance  6  6
LiveArgyll   1 1
External Audit
Nil    
TOTAL 8 17 1 26 
Table 2 – Actions due after 30 September 2025
Service
Complete
On Course
Delayed/
Rescheduled 
Total
Internal Audit
DH – Commercial Services  1  1
DH – Education Performance & Improvement  4  4
DH – Education Wellbeing, Inclusion & Achievement  5  5
DH – Legal & Regulatory Support  6  6
KF – Development & Economic Growth   1 1
KF – Financial Services 1 2 1 4
KF – Roads & Infrastructure Services 1 7  8
H&SCP (SW) – Children & Families and Criminal Justice  7 1 8
H&SCP (IJB) – Strategic Planning & Performance  7  7
External Audit
Nil    
TOTAL 2 39 3 44

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4.0 CONCLUSION 
4.1 Satisfactory progress continues to be made implementing audit actions. 
5.0 IMPLICATIONS 
5.1 Policy – None
5.2 Financial – None
5.3 Legal – None
5.4 HR – None
5.5 Customer Service – None
5.6 Risk – None
5.7 Climate Change – None
5.8 Fairer Scotland Duty – None
5.9 Equalities – protected characteristics – None
5.10 Consumer Duty – None 
5.11 Island Communities – None
5.12 Children’s Rights and Wellbeing – None 
Paul MacAskill
Chief Internal Auditor
16 December 2025                                                  
For further information contact: Paul MacAskill, 01546 604108
Paul.macaskill@argyll-bute.gov.uk 
APPENDICES
Appendix 1 – Visual representation of progress in addressing agreed actions 
Appendix 2 – Action Plan Points Delayed & Rescheduled or Evidence Required

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Appendix 1 – Visual representation of progress in addressing agreed actions as at 30 September 2025

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Appendix 2 – Action Plan Points - Delayed and Rescheduled or Evidence Required 
Action Plan Points due by 30th September 2025 
Service, Report, Plan no. & Finding Agreed Action Original and
Revised Dates
Comment Responsible Officer
LOW
COMMERCIAL SERVICES
Asbestos Management 
7.  Site Responsible Person Records
Services should advise Property Services of any
changes of staff nominated as SRP but in practice
this does not happen consistently meaning that
these records are not up to date. 
Property Services have in the past issued emails to
Heads of Services asking for staffing updates, but
due to a lack of response this practice was
stopped. Consideration should be given to
whether this could be reinstated and where there
is no response if this should be escalated to
DMT/SMT.
Property Services will issue
emails to Heads of Services
asking for staffing updates then
enter details into Concerto.
30/09/2025
31 Dec 2025
Extension required to 31
December 2025 to
accommodate statutory
requirements of Martyn's Law.
While the actions that will be
taken remain mostly the same,
the processes are being
updated to reflect the statutory
requirements within Martyn’s
Law. This will include increased
frequency of checking, with
Heads of Service, for changes in
site responsible persons from
annually to 6 monthly. Updated
Facility Responsible Person
Records are completed and
input on concerto.  Email to be
issued to all Heads of Service in
November 2025 with response
due by end November. 
Delayed and Rescheduled
Commercial Services
Admin Officer 
MEDIUM
DEVELOPMENT & ECONOMIC GROWTH
PLANNING 
1.  Staff Training Planning do not currently have in
place a training schedule for 2023/24 for planning
officers.
Once the incorporation of the
IDOX project is completed a 
training schedule will be
introduced covering both the 
new system and other relevant
areas such as the National
planning for framework 4.
31/03/2024
31/12/2024
31/03/2025
30/06/2025
30/09/2025
31 Mar 2026
Planning staff have access to a
full programme of training
during the year held internally,
or externally, as appropriate.  In
2025/26 a programme of
training is currently being
collated.  A formalised training
schedule has still to be
completed however action has
already been taken forward to
Process and
Productivity
Improvement Officer

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Service, Report, Plan no. & Finding Agreed Action Original and
Revised Dates
Comment Responsible Officer
deliver on several training
themes identified by staff.  This
has included an event on
considering the implications of
the grid enhancement (April
2025), and sessions during Feb
and March 2025 relating to
Trees and EIA development.  It
is confirmed that the most
pressing training needs have
been identified and are being
delivered/progressed whilst a
training plan that addresses
wider requirements remains
under production.
In addition, staff can access a
range of digital courses
specialising in Planning topics
and there is also a range of
internal courses available on
back-office systems, corporate
priorities, and other topics such
as cyber security and the use of
AI and digital tools such as
copilot etc. Creating a training
schedule is however still
complicated by a lack of
available external courses.  That
said, when staff do attend
these, they are also asked to
cascade learning to other
colleagues through notes
taken.  Lastly, the council is also
undertaking a transformational
process, and planners attend an
increasing number of

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Service, Report, Plan no. & Finding Agreed Action Original and
Revised Dates
Comment Responsible Officer
workshops and seminars that
often involve a place-based
approach working with other
council services and external
partners.  The Scottish
Government have also set up a
Planning Hub to help share
expertise with Planning
Authorities.  This approach is
likely to increase in the future. 
Delayed and Rescheduled
HIGH
DEVELOPMENT & ECONOMIC GROWTH
SHORT TERM LETS 
1.  Procedures  
Whilst policies and procedures that are in place
are comprehensive, there are some elements of
the policies which require to be completed in
parts. This includes  policies/procedures around
Enforcement and Renewals  that still require to be
brought together and circulated.  Other
developments are noted for progression on
Oracle.
1. Develop a Short-term Let
Enforcement policy  
2. Develop procedures for the
renewal of Short-term let 
Licences 
3. Secure changes to the Oracle
STL system, including a 
searchable public register, a
template licence revocation 
letter, with this status being
added to oracle and tracking
these 
4. Develop a template for
provisional licence, including
cover letter 
5. Include a new Licence type -
“Transfer Licence” and new 
application status entitled
“transferred”.
30/09/2025
31 Dec 2025
Good progress is being made to
deliver these actions. 
1. STL Enforcement - not
progressed yet. 
2. Renewal procedure
developed and in place. Revised
STL Policy approved by Council
on 26 June 2025, together with
fees. 
3. IT system being updated and
developed to accept on-line
applications and payments.
System testing ongoing but
currently cannot accept on-line
renewal applications.
Alternative arrangements in
place. 
4. IT is working on new public
register. Revocation form part
of enforcement policy and
procedures (see 1 above). 
5. IT development to process
transfers is complete.
Regulatory Services
and Building Standards
Manager

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Service, Report, Plan no. & Finding Agreed Action Original and
Revised Dates
Comment Responsible Officer 
Delayed and Rescheduled
LOW
ROADS & INFRASTRUCTURE SERVICES
Burial Records 
6.  Historical Register Information  
Finding; The Burial and Cremation (Scotland) Act
2016 (The Act) requires information to be
retained electronically although this is not
currently in force it will be at a future date.  The
BACAS system has been partially updated with
historical information recorded in burial registers;
it has not been possible to update with all
information due to the volume of work involved.  
Recommendation;  Source temporary additional
resource to update historical burial records on
BACAS.
The service will source
temporary assistance to update
records during Summer 2024.
30/06/2024
31/12/2024
30/06/2025
30/09/2025
31 Dec 2027
The input of historical records is
progressing within the existing
Roads and Amenity
administrative support team as
it has not been possible to
obtain additional resource.  This
project is significantly more
onerous than initially
considered and is creating
pressure on the team to
complete a piece of work that is
not currently legislative.  A
more realistic timeframe has
therefore been established to
complete this work and allow
the admin team to prioritise
business as usual and progress
with this recommendation
when resources permit. 
Delayed and Rescheduled 
Operations Manager,
Roads and
Infrastructure Services
LOW
ADULT SERVICES (OLDER ADULTS & COMMUNITY
HOSPITALS) 
Adult Services - Adult Support & Protection
1.  Progress  
Whilst significant progress has been made to
address the key areas identified within the report
there remains challenges in terms of ensuring
attendance by all relevant partners at case
conferences, ensuring that chronologies and risk
assessments are completed and ensuring that the
‘three-point test’ is undertaken.
Adult services will facilitate an
ASP audit on a six monthly basis 
to determine practice and
compliance with ASP legislation
and KPIs.
30/09/2024
31/12/2024
31/08/2025
31 Dec 2025
Audit complete and report
recently shared with Senior
Leadership Team.  Due to go to
Adult Protection Committee
and Social Work governance
(Chaired by Chief Social Work
Officer).  Will also go to Chief
officer Group for Public
Protection.  Action plan in
development, evidence will be
provided once progressed
through low-level governance.
Head of Adult Services
(Mental Health, Acute
and Complex Care)

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Service, Report, Plan no. & Finding Agreed Action Original and
Revised Dates
Comment Responsible Officer 
Delayed and Rescheduled 
MEDIUM
FINANCE/TRANSFORMATION
INFORMATION GOVERNANCE 
1.  Documentation Review
Reviews are outstanding in regard to; ·
Records Management Plan ·
Information Governance policy framework
A review of all relevant
documents will be carried out.
RMP will be reviewed and
submitted to Keeper around
February 2025.  IG policy to be
reviewed.
31/03/2025
30/09/2025
31 Dec 2025
The new date for submission of
the RMP to the Keeper is 31
December 2025. 
Delayed and Rescheduled
Governance, Risk &
Safety Manager
MEDIUM
FINANCE/TRANSFORMATION
INFORMATION GOVERNANCE 
2.  Improvement Plan
A number of improvement recommendations
made by the Keeper of Scotland were identified in
the following areas: · Business Classification ·
Retention Schedule · Destruction Arrangements ·
Archiving and Transfer · Business Continuity and
Vital Records · Audit Trail An action Plan to
address these areas should be implemented
Develop and implement an
action plan to address the
Keeper of  Scotland's
improvement
recommendations, ensuring
that all aspects of records
management are up-to-date,
compliant, and  effectively
managed. Will be reviewed as
part of RMP submission to
Keeper.
31/03/2025
30/09/2025
31 Dec 2025
The new date for submission of
the RMP to the Keeper is 31
December 2025. 
Delayed and Rescheduled
Governance, Risk &
Safety Manager
MEDIUM
STRATEGIC PLANNING AND PERFORMANCE
HSCP CULTURE 
1.  Surveys 
Recent surveys undertaken by each organisation
do not focus specifically on the HSCP in terms of
culture (how are the services working together,
communicating with each other, sharing
information), instead focussing on staff
experiences in each organisation.
HR leads within ABC and NHSH
to review survey landscape and
explore joint survey option over
and above existing employer
only surveys.  To report to SLT
and JPF.
31/03/2025
30/09/2025
31 Mar 2026 
Discussion between both
employers and Chief Officer
with conclusion that the iMatter
annual survey is for all
employees in the HSCP
regardless of employer and
therefore further survey at this
stage is not required, however,
any disbandment of the Culture
Group would need to be put to
Audit & Risk. Staff issues have
delayed this action further. 
Delayed and Rescheduled
Depute Director of
People, NHS Highland
MEDI
UM STRATEGIC PLANNING AND PERFORMANCE
HSCP CULTURE 
Refresh and review of the remit
and purpose of the Culture
31/03/2025
30/09/2025
Agreement between staffside
lead for Argyll and Bute, Chief
Depute Director of
People, NHS Highland

Page 10

Service, Report, Plan no. & Finding Agreed Action Original and
Revised Dates
Comment Responsible Officer 
2.  Work Plan 
The work plan outlines priorities, outcomes,
responsible person and timeframes. However,
these are not specific, targeted or in some
instances easily measurable with target dates for
completion marked as ‘ongoing’.
Group.  The work plan will be
included as part of the review
to focus on  meaningful action
and timescales.
31 Mar 2026  Officer and both HR leads that
the Culture Group was no
longer required.  The JPF ToR,
standard agenda and workplan
were reviewed to include the
areas and items that had
previously been part of the
culture group remit, however,
any disbandment of the Culture
Group would need to be put to
Audit & Risk. Staff issues have
delayed this action further. 
Delayed and Rescheduled
MEDIUM
STRATEGIC PLANNING AND PERFORMANCE
HSCP CULTURE 
3.  Monitoring Progress 
There does not seem to be progress notes
assigned to the work plan therefore difficult to
assess, without reading every meeting note what
progress has made. In addition, as noted above a
number of targets dates are simply noted as
‘ongoing’.
Refresh and review of the remit
and purpose of the Culture
Group to include timescales and
progress reporting as
appropriate.
31/03/2025
30/09/2025
31 Mar 2026 
Agreement between staff side
lead for Argyll & Bute, Chief
Officer and both HR leads that
the Culture group was no longer
required.  The JPF ToR, standard
agenda and workplan were
reviewed to include the areas
and items that had previously
been part of the culture group
remit, however, any
disbandment of the Culture
Group would need to be put to
Audit & Risk. Staff issues have
delayed this action further. 
Delayed and Rescheduled
Depute Director of
People, NHS Highland
MEDIUM
STRATEGIC PLANNING AND PERFORMANCE
HSCP CULTURE 
4.  Survey Participation 
Chief Officer to communicate
commencement of surveys to
all staff via CO comms.
31/03/2025
30/09/2025
31 Mar 2026 
Agreed that the National
iMatter survey would be the
tool used. Staff issues have
delayed this action further. 
Delayed and Rescheduled 
Chief Officer

Page 11

Service, Report, Plan no. & Finding Agreed Action Original and
Revised Dates
Comment Responsible Officer
The results of surveys have demonstrated
engagement and participation by HSCP staff could
be improved.
MEDIUM
STRATEGIC PLANNING AND PERFORMANCE
HSCP CULTURE 
5.  Culture and Wellbeing Group 
Whilst the Culture Group is open to all staff across
the HSCP, there is a greater proportion of
representation of NHS staff.
As per refresh and review of
Culture Group, review
membership as a result of
revised remit and purpose.
31/03/2025
30/09/2025
31 Mar 2026  
Agreement between staff side
lead for Argyll & Bute, Chief
Officer and both HR leads that
the Culture group was no longer
required.  The JPF ToR, standard
agenda and workplan were
reviewed to include the areas
and items that had previously
been part of the culture group
remit, however, any
disbandment of the Culture
Group would need to be put to
Audit & Risk. Staff issues have
delayed this action further. 
Delayed and Rescheduled
Depute Director of
People, NHS Highland
LOW
STRATEGIC PLANNING AND PERFORMANCE
Risk Management 
3.  Training
It is noted that there is an outstanding audit
action since June 2021 covering; · Training for new
members of IJB and Audit Committee · training for
Risk leads · maintenance of training records
Recommendation accepted. A
training programme based
upon  the use of the Smartsheet
system is being developed.
31/12/2023
30/06/2024
31/12/2024
30/09/2025
31 Dec 2025
Note the agreed action is
changed, as Smartsheet will be
replaced by in Phase, which has
been delayed.  A TURAS module
in risk is available to all staff, at
present, however, uptake has
not been high.  Audit
Committee training identified
and pending funding approval. 
Delayed and Rescheduled
Business Improvement
Manager
MEDIUM
ADULT SERVICES (MENTAL HEALTH LEARNING
DISABILITY, ADDICTIONS & LIFELONG
CONDITIONS/CSWO)
CLIENT FUNDS PROGRESS REVIEW 
2.  Meeting service users' financial needs
The HSCP will work with
Procurement  Commercial and
Contract Management Team
(PCCMT) to identify appropriate
options within each area. This
issue, which is not within the
30/12/2024
31/03/2025
30/06/2025
30/09/2025
31 Dec 2025
PCCMT has provided options
which need to be reviewed and
considered. 
Delayed and Rescheduled
SW Admin Manager

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Service, Report, Plan no. & Finding Agreed Action Original and
Revised Dates
Comment Responsible Officer
This is a restricted report, please contact Internal
Audit directly if you are responsible for updating
this action.
control of the HSCP, is likely to
recur, generating significant
additional work.
MEDIUM
ADULT SERVICES (MENTAL HEALTH LEARNING
DISABILITY, ADDICTIONS & LIFELONG
CONDITIONS/CSWO) 
Learning & Physical Disability Care Packages
3.  Case Notes
Case notes are maintained on Eclipse, the
replacement  client database for Carefirst. It was
noted that case notes  were not always
maintained and up to date.
Record keeping session (s) to be
delivered by professional lead   ·
Senior Managers to implement
case note audit within their 
respective services – this should
be linked to individual
practitioner  supervision
30/06/2024
31/12/2024
31/03/2025
30/09/2025
31 Jan 2026
Reassigned to another
Professional Team Lead, who
will revisit the case file audit
process, and peer audit case
files per team/service, per
month.  This will be tailored to
meet the requirements of
Eclipse. For record keeping
sessions, this will need time to
plan this and deliver it.
Audit practice notes for LD will
be addressed through
supervision. In addition, audit
tools to be applied to AHP, and
completed by OT and
SALT. Nurses have a different
tool, and looking to also
complete, as well as for
Psychology. 
Delayed and Rescheduled
Senior Managers
(Adult Services)
MEDIUM
FINANCE/TRANSFORMATION
Payroll Procedure for HSCP Care at Home 
1.  Processes
Payroll processes for Care at Home staff are
manually intensive involving a 3-stage process
transferring information at each stage of the
process. This increases risks of error, although
risks are mitigated through authorisation
processes and checking of information efficiencies
could be made by considering a more automated
approach.
The process for payroll will be
reviewed and any
recommendations
implemented. 
If following consultation with
the Finance Manager, it is
determined that no
improvements can be made this
action will be closed pending
purchase of a new automated
system or further development
of the iTrent system.
30/09/2025
31 May 2026
The Council are in the process
of developing a new app, Pay
Time, which, if implemented,
will address this issue.  The
Council are suggesting that
testing will begin in November
2025.  It will be rolled out to the
HSCP if the testing is
successful.  A precise
implementation date is not
within the control of the
HSCP.  It is suggested that this
SW Admin Manager

Page 13

Service, Report, Plan no. & Finding Agreed Action Original and
Revised Dates
Comment Responsible Officer
recommendation is next
reviewed in 6 months, at which
stage there should be a clear
implementation date from the
Council.   
Delayed and Rescheduled
MEDIUM
STRATEGIC PLANNING AND PERFORMANCE
Learning & Physical Disability Care Packages 
7.  Unmet Need  
Unmet need for Older People Care at Home is
collated by the resources team on a weekly basis,
this is then submitted to Performance and
Improvement Team and is reported to Scottish
Government. The data for Learning  Disability is
not currently recorded formally and not  included
in the above.
Include the data re unmet need
for those under 65 in the
weekly  reporting format
already in place for Older
People.
30/06/2024
30/09/2024
31/08/2025
31 Dec 2025
Unmet need for Homecare for
under 65's should be included in
the regular locality returns,
however, there is a variable
response in respect of persons
with MH or LD with most
localities maintaining that they
don't record this.  No separate
record is currently maintained,
and this was to be reviewed and
included in the ongoing
"Resources Services" and
commissioning practice that is
being developed. 
Delayed and Rescheduled
Head of Strategic
Planning, Performance
and Technology &
Head of Adult Services
(Health & Community
Care)
LOW
LIVEARGYLL
Disclosure Checks – PVG 
2.  Policies, Procedures & Guidance
Finding:  The Manager’s Guide to Recruitment
lacks version control to help users ensure they are
using the most current and up-to-date version and
the Safeguarding Policy requires amendment to
correct/remove errors.
Recommendation:  When updating
documentation to incorporate new legislation,
Management should ensure that version control is
applied and all errors corrected/removed.
Document control protocols in
relation to legislative updates
will be reviewed and the
process updated where needed.
31/07/2025  Version control has been added
to the Managers Guide to
Recruitment, the Safeguarding
Policy has been updated but an
error appears to remain, update
to follow. 
Evidence Required
Services and Support
Manager

Page 14

Action Plan Points due after 30th September 2025 
Service, Report, Plan no. & Finding Agreed Action Original and
Revised Dates
Comment Responsible Officer
LOW
DEVELOPMENT & ECONOMIC GROWTH
Private Sector Housing Grants & Adaptions 
3.  Procedure Notes and Shared Documents  
While the vast majority of requirements are
included there would be benefit to updating these
to reflect current working practices, which have
evolved due to hybrid working arrangements and
the digitalisation of records.  Consideration should
be given to creating a checklist to  ensure
consistent application of processes.
Procedures and documents will
be reviewed and updated.
Checklists to be drawn up and
introduced when updating the 
procedures.
31/12/2022
30/06/2023
31/03/2024
30/09/2024
30/12/2024
30/06/2025
31/10/2025 
31 Jan 2026
Long term sickness absence
since April 2025 has prevented
any progress.  Phased return
planned for October.  Revised
timetable will need to be
agreed.
The Scheme of Assistance was
only approved by Council at its
meeting in April this year as the
February meeting agenda was
full. As a result, work on revising
the processes, procedures, and
any checklists could not be
taken forward until this point  
Delayed and Rescheduled
Team Lead - Housing
Operations
LOW
FINANCIAL SERVICES
Preparedness for IFRS16 
1.  Database Maintenance
Continuing to meet the requirements of IFRS 16 will
rely on good communication with departments and
a clear understanding of the processes involved for
updating Financial Services with new lease
arrangements or changes to existing lease
arrangements. 
Policy document and training
will be developed to provide a
framework for ongoing
compliance with IFRS16 Leases
and will be reviewed and
updated as appropriate.
31/12/2025
31 Jan 2026
Pushing back one month to
allow for competing priorities. 
Delayed and Rescheduled
Finance Manager

Page 15

Service, Report, Plan no. & Finding Agreed Action Original and
Revised Dates
Comment Responsible Officer
LOW
CHILDREN AND FAMILIES AND CRIMINAL JUSTICE
Payroll Procedure for HSCP Care at Home 
2.  iTrent
The final stage of the payroll process involves
inputting information into iTrent which is
completed by Administration staff. There is
currently no authorisation process in place to
confirm the accuracy of information input into the
system. The iTrent Project Team are currently
looking at how the processing of timesheet data for
staff can be improved to ensure accurate and
timely information for payroll processing and more
detailed information on when and why staff are
working, particularly casual staff, for HR and service
management.
Provided by key officer for
iTrent system to enable
authorisation on system.
31/03/2026
31 May 2026
The Council are in the process
of developing a new app, Pay
Time, which, if implemented,
will address this issue.  The
Council are suggesting that
testing will begin in November
2025.  It will be rolled out to the
HSCP if the testing is
successful.  A precise
implementation date is not
within the control of the HSCP.
It is suggested that this
recommendation is next
reviewed in 6 months, at which
stage there should be a clear
implementation date from the
Council.   
Delayed and Rescheduled
iTrent Project Team