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2025_26_InternalAudit_SchoolResidentialTrips_ReportFinal

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

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Argyll and Bute Council
Internal Audit Report
November 2025
FINAL
High Medium Low VFM
Number of
Findings
4 2 0 0
Process for School
Residential Trips
Audit Opinion: Limited

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Argyll and Bute Council – Internal Audit Report –Process for School Residential Trips November 2025 
Contents
1. Executive Summary ........................................................................................................................ 3
Introduction ............................................................................................................................................ 3
Background ............................................................................................................................................. 3
Scope ....................................................................................................................................................... 3
Key Dates ................................................................................................................................................ 4
Risks ........................................................................................................................................................ 4
Audit Opinion ......................................................................................................................................... 4
Recommendations ................................................................................................................................. 4
2. Objectives and Summary Assessment ........................................................................................... 5
3. Detailed Findings ............................................................................................................................ 8
Appendix 1 – Action Plan ..................................................................................................................... 15
Appendix 2 – Audit Opinion ................................................................................................................. 18
Contact Details
Internal Auditor: Annemarie McLean
Telephone: 01700 501354
e-mail: annemarie.mclean@argyll-bute.gov.uk
www.argyll-bute.gov.uk

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Argyll and Bute Council – Internal Audit Report –Process for School Residential Trips November 2025 
1. Executive Summary
Introduction
1. As part of the 2025/26 internal audit plan, approved by the Audit & Scrutiny Committee in
March 2025, we have undertaken an audit of Argyll and Bute Council’s (the Council) system of
internal control and governance in relation to the process for school residential visits.
2. The audit was conducted in accordance with the Global Internal Audit Standards (GIAS) with our
conclusions based on discussions with council officers and the information available at the time
the fieldwork was performed. The findings outlined in this report are only those which have
come to our attention during the course of our normal audit work and are not necessarily all the
issues which may exist. Appendix 1 to this report includes agreed actions to strengthen internal
control however it is the responsibility of management to determine the extent of the internal
control system appropriate to the Council.
3. The contents of this report have been agreed with the appropriate council officers to confirm
factual accuracy, and appreciation is due for the cooperation and assistance received from all
officers over the course of the audit.
Background
4. Scotland’s outdoor environment offers motivating, exciting, varied, relevant and easily
accessible activities from pre-school years through to college and beyond. Through Curriculum
for Excellence, and Learning for Sustainability, the Scottish Government endorses the value of
children and young people enjoying positive learning and play experiences in a wide variety of
settings from galleries and museums to woodlands, parks and wild natural spaces, as well as
planned adventure and residential experiences.
5. An enjoyable, creative, challenging learning journey helps children and young people learn by
experience and grow as confident and responsible citizens who value and appreciate their local
area and the wider environment of Scotland, which includes spectacular landscapes, rich natural
heritage and a diverse built environment including landmarks of international significance, as
well as further afield.
6. Excursions and educational visits are an important and valuable part of our educational system.
Getting more children and young people out of the traditional classroom and into the real world,
by giving access to cultural experiences and outdoor learning and play opportunities provides
invaluable life experiences.
7. A residential experience can be an extremely valuable learning opportunity and may be part of
the progressive outdoor learning or cultural experiences provided for young people. Residential
visits include any form of overnight stay regardless of the type of accommodation.
Scope
8. The scope of the audit was to determine if the current processes are embedded prior to the
expansion of residential trips which will be available to all children, as outlined in the Terms of
Reference agreed with the Head of Education: Performance and Improvement on 03 July 2025.
9. It was agreed that the purpose of the audit was to identify areas for process improvement, its
applicability to be applied consistently across the Council’s school estate rather than highlighting

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Argyll and Bute Council – Internal Audit Report –Process for School Residential Trips November 2025 
specific issues at an individual school level. A detailed list of issues arising will be provide to the
Service and the recommendations for improvement contained within it, reflects this agreed
focus on aiding the Council’s preparations for the expansion of residential trips. 
10. The Legislation regarding this expansion is still being considered and the timescales agreed for
completing the recommendations takes cognisance of this.
Key Dates
11. The Terms of Reference provided provisional timescales for the review to take place, the actual
dates are noted below.
Exhibit 1 – Key Dates
Stage Actual Date
Terms of Reference agreed 03 July 2025
Fieldwork Commencement 12 August 2025
Draft Report issued 10 November 2025
Management Comments received 18 November 2025
Final Report issued 18 November 2025
Audit and Scrutiny Committee 16 December 2025
Risks
12.  The risks considered throughout the audit were:
• Audit Risk 1: Processes and procedures for school residential trips are not effective.
• Audit Risk 2: Monitoring arrangements do not provide sufficient oversight of school
residential trips.
• Audit Risk 3: Staff have not been provided with appropriate information, instruction and
training regarding their responsibilities related to school residential trips.
Audit Opinion
13. We provide an overall audit opinion for all the audits we conduct. This is based on our
judgement on the level of assurance which we can take over the established internal controls,
governance and management of risk as evidenced by our audit work.  Full details of the five
possible categories of audit opinion is provided in Appendix 2 to this report.
14. Our overall audit opinion for this audit is that we can take a limited level of assurance.  This
means that internal control, governance and the management of risk are displaying a general
trend of unacceptable residual risk and placing system objectives are at risk. Weakness must be
addressed with a reasonable timescale with management allocating appropriate resources to
the issues raised.
Recommendations
15. We have highlighted four high priority recommendations and two medium priority
recommendations where we believe there is scope to strengthen the control and governance
environment. These are summarised below:

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Argyll and Bute Council – Internal Audit Report –Process for School Residential Trips November 2025 
• Education Management Circular 3.25 and its appendices, should be reviewed, clarified
and updated to contain a flow chart and checklist section on key tasks which can be used
to document and evidence compliance with relevant legislation. 
• Education Management Circular 3.14 and its appendix should be reviewed and updated
with the assistance of Legal Services.
• Education Management Circular 1.26 and its appendices, should be reviewed, clarified
and updated to ensure it takes cognizance of best practice contained in the “Going Out
There” Framework.
• Appropriate corporate monitoring arrangements should be established and
implemented.
• Consideration should be given to the Procurement and Commercial Contract
Management Team (PCCMT) being consulted prior to making bookings/ entering into an
agreement with external providers for school residential trips.
• A training needs analysis should be undertaken, and suitable training provided, for Head
Teachers and staff, including clerical, involved in the processes of planning and
undertaking of school residential trips. 
16. Full details of the audit findings, recommendations and management responses can be found in
Section 3 of this report and in the action plan at Appendix 1.
2. Objectives and Summary Assessment
17. Exhibit 1 sets out the control objectives identified during the planning phase of the audit and our
assessment against each objective.  
Exhibit 1 – Summary Assessment of Control Objectives
Control Objective Link to Risk Assessment Summary Conclusion
1 Procedures for
school residential
trips are in place, up
to date and take
cognisance of best
practice.
Audit Risk 1 Reasonable • The Council has procedures in
place for school residential trips.
These are not all up to date and
the Council has not yet adopted
the Scottish Government best
practice “Going Out There”
framework.  
• There are five Education
Management Circulars (EMCs) that
provide guidance and instruction
relating to the procedures for
planning and undertaking of school
residential trips. 
• The Service is aware that the EMCs
require updating and has
established a working group to
facilitate the Council’s adoption of
the “Going Out There” best
practice framework.
• Three of the EMCs need updating
to reflect current working practices
and identified gaps in the

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Argyll and Bute Council – Internal Audit Report –Process for School Residential Trips November 2025 
procedures. The roles and
responsibilities of all staff involved
in the process are not stated and
linkages between the circulars
could be clearer. 
• There are no record retention
periods stated for key documents
which has led to inconsistent
record keeping. 
• When enquiring with schools about
the trips that they have
undertaken, some have used
external companies to help with
the provision and planning of the
trips. Consideration should be
given to PCCMT being consulted
prior to making bookings and/or
entering into an agreement with
external providers for school
residential trips.
• Procedures are not easily
accessible to staff as the end-to-
end process for planning school
residential trips are not contained
in one document. When updating
the circulars there would be
benefit to considering including a
flow chart providing a visual
overview and a checklist as these
could help streamline and
standardise the processes, whilst
aiding better overall understanding
and improving consistency of
approach.  
2 There are
appropriate
oversight and
monitoring
arrangements in
place for schools
undertaking
residential trips.
Audit Risk 2 Limited • The EMCs provide information and
instruction to schools to assist staff
in planning and approval processes
for school residential trips, there is
no mention of monitoring
arrangements in contained in these
documents. Testing and overview
have established that out with
schools, there is insufficient or
limited monitoring arrangements
in place for schools undertaking
residential trips.
• In schools, Head Teachers, or their
nominated deputies, as Head of
the establishment, are responsible
for checking and approving
arrangements for school residential

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Argyll and Bute Council – Internal Audit Report –Process for School Residential Trips November 2025 
trips and are expected to ensure
staff are supported in organising
school trips.
• Clerical staff in School Support
Teams, record details of trips and
carry out limited checks, so that
the information is available on
request, but nothing else is done
with this information. We would
expect that, for example, this is
used to inform, monitoring,
feedback and training. 
3 Staff involved in
school residential
trips have been
provided with
appropriate
information,
instruction and
training regarding
their
responsibilities.
Audit Risk 3 Limited • The EMCs provide information and
instruction but as noted above,
these require updating. 
• The Council’s Corporate Health and
Safety policy states that a training
needs analysis should be
undertaken, and suitable training
be provided. This has not been
undertaken for school residential
trip processes; No corporate
practical training is made available
to staff regarding their
responsibilities and staff are not
directed to the LEON Risk
Assessment module. 
• Other basic training suggested is
First Aid training. Testing identified
a first aid trained member of staff
was not present on some school
residential trips. In some instances,
this is covered by the facility being
visited, however, this should not be
relied upon.
4 Adults participating
in school trips have
received the
required child
protection
information/basic
training and
evidence of this is
retained.  
Audit Risk 2 Reasonable  • The Council has well established
processes and arrangements in
place to ensure that all school staff
receive the required child
protection information and training
with records kept to evidence this. 
• Legislation regarding the Disclosure
Checks - Protecting Vulnerable
Groups (PVG) scheme changed in
April 2025. 
• The Council carried out an
organisation wide check of
regulated roles and took steps to
ensure that the individuals in those
roles undertook the required level

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Argyll and Bute Council – Internal Audit Report –Process for School Residential Trips November 2025 
of Disclosure Checks and
appropriate evidence retained.
• Testing identified that during home
stay trips PVG checks were not
undertaken in line with Council
procedures. 
• The revised PVG scheme
requirements should be considered
both, when updating the EMCs and
when developing monitoring
arrangements.
18. Further details of our conclusions against each control objective can be found in Section 3 of this
report.
3. Detailed Findings
Procedures for school residential trips are in place, up to date and take cognisance of best
Practice.
19. The Scottish Government developed the “Going Out There” Framework which relates to outdoor
experiences and off-site visits in a wide variety of settings from galleries and museums to
woodlands, parks and wild natural spaces, as well as planned adventure and residential
experiences. It is expected that ‘Going Out There’ should be adopted as a common framework
across Scotland by all those managing or organising visits or providing activities and venues. 
20. The aims include to increase confidence and co-operation and that by adoption of the good
practice exemplified in the framework allows Employers to fulfil their responsibilities under the
Health and Safety at Work Act 1974 for outdoor experiences and off-site visits for all
participants.
21. The Scottish Advisory Panel for Outdoor Education (SAPOE) is the forum where Scotland’s
outdoor learning community collaborates to develop best practice in the design and safe
delivery of outdoor learning for all children and young people in Scotland. It is member led, and
representatives include Local Authorities. One of its key aims is: “promote and develop
consistent good practice across Scotland for off-site visits through the implementation of the
framework Going Out There”.
22. Not all Councils have chosen to adopt the “Going Out There” best practice yet. The Service has
made the decision to adopt the best practice guidance and has established a working group to
undertake this. The group comprises one Education Manager, two Headteachers (one being the
SAPOE representative) and a representative from school support team.
23. This group has already identified the school trips and outdoor learning management circulars
requiring updating as they need to reflect the decision to adopt the national guidance.
24. The Council’s Education Service have a suite of Education Management Circulars (EMCs) which
collectively form the current policies and procedures issued to schools. There are five EMCs that
provide guidance and instruction relating to the procedures for planning and undertaking of
school residential trips, these are:

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Argyll and Bute Council – Internal Audit Report –Process for School Residential Trips November 2025 
• EMC 3.25 School Trips -is the main circular, containing most of the procedures, it directs
staff read EMC 3.14, EMC 1.26 and EMC 3.23 and was last reviewed in 2017.
• EMC 3.14 Insurance – provides details of the three insurance policies available to cover
school trips and procedures for notifying and liaising with Insurance Services and was
also last reviewed in 2017.
• EMC 1.26 Outdoor Education - gives overarching guidance for individual activities, last
reviewed 2023 – although this appears to be incomplete.
• EMC 3.23 Child Protection and Safeguarding - is a core Council policy document which is
supported by annual training provided to all school staff, it was updated in July 2023.
• EMC 1.10 School Funds – provides guidance and instructions relating to the financial
aspects of school residential trips, this was updated in May 2025, in response to internal
audit recommendations.
25. The circulars reviewed in detail as part of this audit were, School Trips, Insurance and Outdoor
Education. The information in these was used to test procedures in nine schools which included,
one joint campus, two 2-18 schools and six primary schools.  
26. The School Trips circular is the main source of guidance and instruction for staff involved in the
planning and undertaking of school trips, including residential trips and contains three
appendices.
27. The School Trips circular has not been updated since 2017 and does not reflect current working
practices and contained gaps which we have identified including:
• No record retention period for any of the documents, which has led to inconsistent
record keeping among the different schools.
• There is no formal or consistent process for P7 transition trips. These require co-
ordination between multiple schools with staff in different schools carrying out tasks.
Lack of guidance has resulted in school support not been notified by all schools involved
in the trips. 
• There is no tailored approval form for home stay trips.
• There are missing links to documents and contact details.
• Post trip reports are now verbal and are mostly lessons learned. It is unclear whether
this is the current way of working or if reports no longer required.
28. The circular sets out the roles and responsibilities for four key roles involved but not all roles and
responsibilities are included.
• Head Teacher/Campus principles /nominated delegate – as Head of the Establishment
has overall responsibility for all trips and approval.
• Leaders In Charge – the teacher (s) planning and leading the school residential trip.
• Supervising staff – accompanying the trip.
• School liaison officer – the in-school contact for those on the trip.
29. Clerical staff in the schools have an active role, performing tasks related to the administration
for school trips but this is not detailed in the circular and has led to differing practices and
inconsistency within schools. In some small primary schools, clerical staff organise the trips while
in other larger schools, teachers undertake more of the administration.

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Argyll and Bute Council – Internal Audit Report –Process for School Residential Trips November 2025 
30. The School Support Team is the corporate support team which consists of the School Support
Manager, the Admin and Finance Officers and clerical staff. Schools are advised to send a copy of
the approval forms to school support for them to record. The tasks carried out by theses staff
are not detailed in the circular. 
31. When updating the circulars there would be benefit to reviewing the tasks at each stage of the
process and clarifying the roles and responsibilities of the staff involved.
Action Plan 1
32. As noted above, EMC 3.14 Insurance provides details of the insurance policies in place for school
trips and procedures for notifying and liaising with Insurance Services, it was last reviewed 2017.
33. The Council has four policies available to schools’ undertaking trips, the costs of these are
apportioned into school budgets:
• Public Liability & Employers Liability insurance automatically covers all employees and all
activities officially approved by school, outdoor centre, youth club etc are covered.
Cover is automatic and insurance documents are published on the Hub.
• Group personal accident policy - applicable to staff only, cover is automatic.
• School journey policy is available for trips involving overnight stays, it covers
participants, teachers and other adults, whether employees or not, who accompany
them. Examples of cover include medical expenses, cancellation expenses, personal
effects and legal liability. 
o This policy is optional, and cover is supplied only when schools complete the School
Travel Insurance Policy Proposal form (appendix 1) and submit this to Insurance
Services, before the event.
34. Schools are not directly provided with copies of the policies where there is automatic cover and
there are no links in the circular to these, rather it states that it is the Head Teachers
responsibility to “ensure that all staff who may be involved in organising school journeys are
made aware of the content”. 
35. When Insurance Services receive Appendix 1 requests from schools, they record this so that they
have the details in the event of a claim and provide schools with a copy of the School Journey
policy.  
36. The guidance contained in the Insurance circular could be clearer, and some gaps were identified
which create the potential that trips are booked without fully checking the existing cover
available. These include:
• Appendix 1 - staff are advised to submit this before the event, there are no minimum
timescales within which schools should submit this form to Insurance Services nor any
retention period for this. 
• Appendix 1 - asks for minimal details only and does not require to be signed by the Head
Teacher/ person approving the trip.
• The School Journey Policy schedule is only provided to schools after Appendix 1 has
been submitted, this has some exclusions, e.g. maximum age covered is 70 and
limitations on winter sports, which are not reflected in the Insurance circular.

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Argyll and Bute Council – Internal Audit Report –Process for School Residential Trips November 2025 
37. The Insurance Circular and its appendix should be reviewed and updated with the assistance of
Legal Services to ensure it reflects current working practices and requirements. 
Action Plan 2
38. Residential trips are classified as all school journeys involving an overnight stay, these should be
notified to Insurance Services and as the School Journey Policy cover is an extensive policy
additional insurance is not normally required. 
39. Testing of processes within schools found that there are occasions when schools do not advise
Insurance Services of residential trips and pay for insurance cover with external parties,
examples included an outdoor centre being visited and a company organising an overseas trip.
The costs of this are included in the total trip costs, either some or all of which are paid by for
mostly by families of those participating in the trips.
40. Insurance Services maintain a record of all insurance claims. In the past five years there have
only been twelve claims, six of which related to cancellations due to lockdown.
41. The Outdoor Education circular gives overarching guidance for individual activities. In
recognition that many heads of educational establishments and staff involved in the planning of
outdoor education and activities are not specialists in these areas and so may have difficulty in
the exercise of judgements on certain outdoor activities. To provide support with this, the
Council has engaged the services of a technical adviser, who is kept on retainer, and is available
to provide advice. 
42. The Outdoor Education circular was reviewed in 2023, but this document appears incomplete as
there are missing sections, specifically those relating to the Scottish Government “Going Out
There” best practice framework/toolkits.
Action Plan 3
43. Both the School Trips and Outdoor Education circulars provide some guidance on the use of
external providers, requiring that Head Teachers/Head of Establishment should be fully satisfied
as the capability of the external provider, e.g. travel or activity provider. 
44. When enquiring with schools about the trips that they have undertaken, some have used
external companies to help with the provision and planning of the trips. There has been no
direct instruction from Senior Managers that advice should be sought from Procurement and
Commercial Contract Management Team (PCCMT).  
45. Some providers have been engaged with via PCCMT, but this has only happened when the team
having become aware, via their overview and monitoring of spend, that providers are being used
or will be used on a regular basis for school trips. PCCMT have then followed procurement
processes and put appropriate arrangements in place. Consideration should be given to PCCMT
being consulted prior to making bookings/ entering an agreement with external providers for
school residential trips.
Action Plan 5
46. Education Maintenance Circulars are all published on the Council’s website but procedures are
not easily accessible to staff as the end-to-end process for planning school residential trips and
are  not contained in one document.

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Argyll and Bute Council – Internal Audit Report –Process for School Residential Trips November 2025 
47. School offices tend to keep copies of school trip packs which contain forms that are required,
with some schools developing a covering checklist with key tasks. Staff planning trips are
provided with copies of these packs from the offices, however, these do not always contain a
copy of the circular and similarly do not always read the School Trip and Insurance circulars in
full; most were unaware of the linkages to the Outdoor Education circular. 
48. When reviewing and updating the circulars there would be benefit to considering including a
flow chart providing a visual overview and a checklist as these could help streamline and
standardise the processes.  This may help navigate the process more effectively and support
consistency of approach.
Action Plan 1,2 and 3
There are appropriate oversight and monitoring arrangements in place for schools undertaking
residential trips.
49. The Education Management Circulars provide information and instruction to schools to assist
staff in planning and approval processes for school residential trips.  There is no mention of
centralised monitoring arrangements in these documents and our testing established that out
with schools there are no monitoring arrangements in place. 
50. In schools, Head Teachers, or their nominated deputies, as Head of the establishment, are
responsible for checking and approving arrangements for school residential trips and are
expected to ensure staff are supported in organising school trips.
51. The School Trips circular appendix 2 – Residential Trips is the approval form that Leaders in
Charge complete with the main details of the proposed trip. This form is passed to the Head
Teacher for review and approval. Copies of this should be retained in the office and emailed to
the School Support Team for recording. A review of forms found most are completed and signed
but there are other examples that were incomplete, some unsigned and some were out of date
forms from 2013.
52. Clerical staff within the school support team file the documents received from schools and
record some of the information on the Master School Trip spreadsheet.  Limited checks are
carried out e.g. there is a formula built into the spreadsheet to check the ratios of pupils to
teachers. This information is available on request but nothing else appears to be done with the
information. 
53. Schools do not receive any acknowledgement nor feedback, unless the ratios need queried.
Discussions with Head Teachers and staff in schools established that the assumption is that no
response or feedback means that there are no issues with the forms and processes. 
54. A sample of available Appendix 2 Approval forms, from schools and from the school support
records were reviewed and compared with the Master School Trip spreadsheet, this found that
not all trips undertaken were notified to school support, some schools submitted copies of risk
assessments, others did not. 
55. The lack of sufficient monitoring of both schools and school support processes has meant that
there are no mechanisms for providing feedback to staff. As a result, staff are unaware where
procedures could be improved.

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Argyll and Bute Council – Internal Audit Report –Process for School Residential Trips November 2025 
56. Appropriate corporate monitoring arrangements should be established and implemented. There
would be benefit to updating the School Trips Master spreadsheet to ensure that it capture all
the information required to support monitoring arrangements.
Action Plan 4
Staff involved in school residential trips have been provided with appropriate information,
instruction and training regarding their responsibilities.
37. The EMC’s provide written information and instruction to staff, outlining responsibilities for
Head Teachers and Leaders in Charge, but as noted above, these require updating.
38. No corporate/ practical training is made available to staff involved in the planning and
undertaking of school residential trips, rather Head Teachers are expected to follow the
management circular and ensure staff are supported to organise school trips.  Head Teachers
can contact the Education Managers for support, but this is not detailed in either the School Trip
or Outdoor Learning circulars. 
39. Feedback during testing highlights that staff would like some formal or tailored training to help
them feel more confident planning and undertaking school residential trips.  Most go to other
teachers who have undertaken trips previously for advice.
40. School excursions and educational visits can involve an element of risk, and the School Trips
circular instructs staff to carry out a risk assessment at the planning stage. A review of the
circulars and wider testing established that:
• There are no arrangements in place to provide training on the completion of risk
assessments to Leaders in Charge/ staff planning school trips and those expected to
approve school trips. 
• The circulars do not refer staff to the Council’s LEON Risk Assessment training module.
• No risk assessment template is included in any of the circulars.
• The further information section on P19 of the School Trips circular provides a link to  The
Health and Safety Executive leaflet Five steps to risk assessment
• Some schools had been provided with a risk assessment template by the Council’s
Health and Safety Team.
• There is no retention period stated for completed risk assessments.
• There is no monitoring of risk assessments carried out.
41. EMC 1.26 Outdoor Education states the “First Aid certificate - requirements “the level of first aid
training required by the authority for all activities is the 'standard' first aid course”. There is no
mention of First Aid requirements in EMC 3.25 School Trips. 
Action Plans 1 and 3
42. Testing highlighted that there is not always a First Aid trained member of staff participating in all
school residential trips. In some instances, like trips to outdoor centres, this is covered by the
facility being visited.

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Argyll and Bute Council – Internal Audit Report –Process for School Residential Trips November 2025 
43. The Council’s Corporate Health and Safety plan states that Services should “undertake a training
needs analysis and provide suitable training to staff, taking into account risk assessments for
work activities and the need to provide appropriate Health and Safety induction and refresher
training, in line with the relevant policies and local risk assessment”. This has not been carried
out for school trips processes. 
44. A training needs analysis should be undertaken, and suitable training provided, for Head
Teachers and staff, including clerical, involved in the processes of planning and undertaking of
school residential trips. This should consider, making the LEON Risk Assessment Module
compulsory and requirements for First Aid Training. 
Action Plan 5
Adults participating in school trips have received the required child protection information/basic
training and evidence of this is retained.   
45. The Council has well established processes and arrangements in place to ensure that all school
staff receive the required child protection information and training with appropriate records
kept for evidence of this occurring.
46. Prior to the start of each new academic year, schools have two in-service days, child protection
training is provided to all staff and records maintained by schools of this.
47. From 1 April 2025, it is a legal requirement for individuals to be a member of the Disclosure
Checks – Protecting Vulnerable Groups (PVG) scheme when carrying out a regulated role with
children, protected adults, or both. Organisations had to ensure that individuals who are to carry
out a regulated role (paid or voluntary) have PVG scheme membership from 1 April 2025
onwards. 
48. To comply with this legislation the Council carried out an organisation wide check of regulated
roles and took steps to ensure that the individuals in those roles undertook the required level of
Disclosure Checks and evidence of this is retained. 
49. Testing identified that during home stay trips PVG checks were not undertaken in line with
Council procedures.
50. The revised PVG scheme requirements should be included when updating the guidance and
instructions within the EMCs, including EMC 1.56 Disclosures, and considered when developing
monitoring arrangements. 
Action Plans 1, 3 and 4

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Appendix 1 – Action Plan
No Finding Risk Agreed Action Responsibility / Due Date
High 1
EMC 3.25 School Trips and its appendices are not up to
date and gaps have been identified. 
The School Trips circular should be reviewed, clarified and
updated. There would be benefit to including a flow chart
providing a visual overview and a checklist as these could
help streamline and standardise the processes, improving
consistency of approach while helping document and
evidence compliance with relevant legislation and Scottish
Government best practice contained in the “Going Out
There” Framework.
Processes and procedures for
school residential trips are
not effective and record
keeping arrangements may
not provide sufficient
evidence of compliance with
relevant legislation. 
The Education working group
established to facilitate the
Council’s adoption of the “Going
Out There” best practice
framework, will lead the review of
the circular.
Education Officer
30 August 2026
High 2
EMC 3.14 Insurance and its appendix have not been
updated since 2017. 
The circular could be clearer, and some gaps were
identified which create the potential that trips are booked
without fully checking the cover available.
This circular should be reviewed and updated with the
assistance of Legal Services. 
There is the potential that
trips are booked without
fully checking exclusions
within the cover available.
The Education working group
established to facilitate the
Council’s adoption of the “Going
Out There” best practice
framework will lead the review of
the circular, with the assistance of
Legal Services. 
Education Officer
30 August 2026
High 3
EMC 1.26 Outdoor Learning and its appendices, do not take
account of best practice “Going Out There” framework.
The circular should be reviewed, clarified and updated to
ensure it takes cognisance of the best practice contained in
the “Going Out There” Framework.
The Councils current
processes are not as efficient
and effective as they could
be if they were following
best practice guidance in
relation the planning of
school residential trips.
The Education working group
established to facilitate the
Council’s adoption of the “Going
Out There” best practice
framework will lead the review of
the circular.
Education Officer
30 August 2026
High 4
Insufficient oversight of schools undertaking residential
trips. 
The lack of monitoring of both schools and school support
processes has means there is no mechanism for providing
feedback to staff. As a result, there are inconsistent
Monitoring arrangements do
not provide sufficient
oversight of school
residential trips.
The Education working group
established to facilitate the
Council’s adoption of the “Going
Out There” best practice
framework will determine
appropriate corporate monitoring
Education Officer
30 August 2026

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Argyll and Bute Council – Internal Audit Report –Process for School Residential Trips November 2025 
No Finding Risk Agreed Action Responsibility / Due Date
approaches, and staff are unaware where procedures could
be improved. 
Appropriate corporate monitoring arrangements should be
established and implemented.
arrangements which will be
implemented.
Medium
5
Insufficient guidance on use of external providers.
Guidance on the use of external providers places
responsibility for checks on those approving school
residential trips. When enquiring with schools about the
trips that they have undertaken, some have used external
companies to help with the provision and planning of the
trips.
Consideration should be given to the Procurement and
Commercial Contract Management Team (PCCMT) being
consulted prior to making bookings with external providers
for school residential trips. 
Staff have not been provided
with appropriate
information, instruction and
training regarding their
responsibilities related to
school residential trips.
The Education working group
established to facilitate the
Council’s adoption of the “Going
Out There” best practice
framework, in consultation with
Procurement and Commercial
Contract Management Team
(PCCMT), will consider this.
Education Officer
30 August 2026
Medium
6
Staff involved in school residential trips have not been
provided with training regarding their responsibilities.
No training analysis has been undertaken, and no
corporate/ practical training is made available to staff; gaps
include the completion of risk assessments and first aid
training. Head Teachers are expected to follow the circular
and ensure staff are supported to organise school trips.  
A training needs analysis should be undertaken, and
suitable training be provided, for Head Teachers and staff,
including clerical, involved in the processes of planning and
undertaking of school residential trips. This should consider:
• making the LEON Risk Assessment Module compulsory.
• requirements for First Aid training.
Staff have not been provided
with appropriate
information, instruction and
training regarding their
responsibilities related to
school residential trips.
The Education working group
established to facilitate the
Council’s adoption of the “Going
Out There” best practice
framework will consider the
training needs analysis and what
training should be provided for
those involved in the processes of
planning and undertaking of
school residential trips.
Education Officer
30 August 2026

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Argyll and Bute Council – Internal Audit Report –Process for School Residential Trips November 2025 
In order to assist management in using our reports a system of grading audit findings has been adopted to allow the significance of findings to be ascertained.  The definitions
of each classification are as follows:
Grading Definition
High A major observation on high level controls and other important internal controls or a significant matter relating to the critical success of the
objectives of the system.  The weakness may therefore give rise to loss or error.
Medium
Observations on less significant internal controls and/or improvements to the efficiency and effectiveness of controls which will assist in meeting
the objectives of the system.  The weakness is not necessarily substantial however the risk of error would be significantly reduced if corrective
action was taken.
Low Minor recommendations to improve the efficiency and effectiveness of controls or an isolated issue subsequently corrected.  The weakness does
not appear to significantly affect the ability of the system to meet its objectives.
VFM An observation which does not highlight an issue relating to internal controls but represents a possible opportunity for the council to achieve
better value for money (VFM).

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Argyll and Bute Council – Internal Audit Report –Process for School Residential Trips November 2025 
Appendix 2 – Audit Opinion
Level of Assurance Definition
High Internal control, governance and the management of risk are at a high standard. Only marginal elements of residual risk have
been identified with these either being accepted or dealt with. A sound system of control designed to achieve the system
objectives is in place and being applied consistently. 
Substantial Internal control, governance and the management of risk is sound. However, there are minor areas of weakness which put some
system objectives at risk and specific elements of residual risk that are slightly above an acceptable level and need to be
addressed within a reasonable timescale. 
Reasonable
Internal control, governance and the management of risk are broadly reliable. However, whilst not displaying a general trend,
there are areas of concern which have been identified where elements of residual risk or weakness may put some of the system
objectives at risk.
Limited Internal control, governance and the management of risk are displaying a general trend of unacceptable residual risk above an
acceptable level and placing system objectives are at risk. Weakness must be addressed with a reasonable timescale with
management allocating appropriate resources to the issues raised. 
No Assurance Internal control, governance and the management of risk is poor. Significant residual risk and/or significant non-compliance with
basic controls exists leaving the system open to error, loss or abuse. Residual risk must be addressed immediately with
management allocating appropriate resources to the issues.