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2025_26_InternalAudit_BuildingCleaning_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 2025/6
FINAL
High Medium Low VFM
Number of
Findings
0 0 1 0
Building Cleaning
Audit Opinion: High

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Argyll and Bute Council – Internal Audit Report – Building Cleaning, November 2025 
Contents
1. Executive Summary ........................................................................................................................ 3
Introduction ............................................................................................................................................ 3
Background ............................................................................................................................................. 3
Scope ....................................................................................................................................................... 3
Key Dates ................................................................................................................................................ 3
Risks ........................................................................................................................................................ 4
Audit Opinion ......................................................................................................................................... 4
Recommendations ................................................................................................................................. 4
2. Objectives and Summary Assessment ........................................................................................... 4
3. Detailed Findings ............................................................................................................................ 6
Appendix 1 – Action Plan ..................................................................................................................... 10
Appendix 2 – Audit Opinion ................................................................................................................. 12
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 – Building Cleaning, 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 building cleaning.
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. The purpose of the Cleaning Service is to provide a clean and safe working and learning
environment for Council employees and for pupils and staff in schools and nurseries across the
Council area. Cleaning is provided to 46 Council offices and buildings, and to the 36 larger
schools across the Council: the remainder of cleaning in very small schools is carried out by
janitor/cleaners who are directly managed by Education.
5. The cleaning service employs around 220, part time and term time staff, the majority of which
are female.  Cleaning staff often work out of hours and are employed on the lowest SLGE grades.
These are entry level jobs that offer meaningful and valuable employment opportunities to a
range of people, including to young people with no work experience elsewhere.
6. The cleaning team provides commercial cleaning services to Argyll Community Housing
Association (ACHA) and the Valuation Joint Board, generating income for the council via this
approach.  Services are provided to ACHA offices and sheltered housing facilities across the
Council area. 
Scope
7. The scope of the audit was to review and assess the arrangements for cleaning across the
Council establishments, as outlined in the Terms of Reference agreed with the Head of
Commercial Services on 02 September 2025.
Key Dates
8. The Terms of Reference provided provisional timescales for the review to take place, the actual
dates are noted below.

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Argyll and Bute Council – Internal Audit Report – Building Cleaning, November 2025 
9. Exhibit 1 – Key Dates
Stage Actual Date
Terms of Reference agreed 02 September 2025
Fieldwork Commencement 22 September 2025
Draft Report issued 18 November 2025
Management Comments received 26 November 2025
Final Report issued 26 November 2025
Audit and Scrutiny Committee 16 December 2025
Risks
10.  The risks considered throughout the audit were:
• Audit Risk 1: Arrangements for the cleaning of Council establishments are adversely
impacted due to insufficient staff cover in each location.
• Audit Risk 2: Monitoring and reporting of the quality of cleaning is not undertaken.
Audit Opinion
11. 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.
12. Our overall audit opinion for this audit is that we can take a high level of assurance.  This
means that 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.
Recommendations
13. We have highlighted one low priority recommendations where we believe there is scope to
strengthen the control and governance environment.  This is summarised below:
• The Induction Pack contains out of date links and should be reviewed to ensure it
reflects current working practices, and if applicable, reflect changes to the PVG scheme.
14. 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
15. Exhibit 1 sets out the control objectives identified during the planning phase of the audit and our
assessment against each objective.

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Argyll and Bute Council – Internal Audit Report – Building Cleaning, November 2025
Exhibit 1 – Summary Assessment of Control Objectives
Control Objective Link to Risk Assessment Summary Conclusion
1 The Council has
arrangements in
place to carry out
regular cleaning
of Council
establishments.
Audit Risk 1
Audit Risk 2
Substantial • The Council’s Cleaning Service has
arrangements in place to carry out
regular cleaning of establishments
where this has been requested. 
• Each establishment has specific cleaning
staff allocated to undertake a pre-
planned schedule of cleaning at an
agreed frequency.
• Cleaning staff do not have access to
Council computers, so all training
records, including Induction training, are
manual records. These are stored at
each premises in the on-site Health and
Safety folders, except for GDPR training
which is collated by Operational Delivery
Managers. 
• New employees are provided with an
induction pack with contains links to key
Council policies. These links do not work.
• Casual staff are retained in locations to
provide cover for staff annual leave and
absence.  Changes to the Disclosure
Checks requirements affect some
cleaning staff who work in what are
deemed regulated roles e.g. schools and
nurseries.  
• The induction pack should be reviewed
to ensure that it contains up to date
links to key documents/ policies, reflects
current working practices and if
applicable, any changes to processes
required as a result of the change to the
PVG scheme.
2 Cleaning
standards are
being utilised, and
the quality of
cleaning is
monitored and
reported
regularly.
Audit Risk 2 High • There are detailed cleaning schedules
and standards to support the cleaning of
council premises, these are based on
industry standards.
• Monitoring of cleaning in premises is
undertaken by the cleaning services
manager who conducts regular reviews
and audits of cleaning practices against
established benchmarks such as the BICs
standards. The Operations Officers or
Managers carry out ad- hoc spot check
on premises on a regular basis. No
documentation relating to this was
reviewed as part of the audit.

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Argyll and Bute Council – Internal Audit Report – Building Cleaning, November 2025 
• Building users are sent surveys
requesting feedback but these are rarely
returned, instead any issues are raised
with the Operational Delivery Managers,
who discuss these at weekly catch up
meetings with the Senior Manager -
Catering, Cleaning, Events and Food
Strategy. 
• Reporting of performance and issues for
the cleaning services are discussed at
the Commercial Services Teams
meetings. No reports are currently
provided to Council Committees.
16. Further details of our conclusions against each control objective can be found in Section 3 of this
report.
3. Detailed Findings
The Council has arrangements in place to carry out regular cleaning of Council establishments.
17. The Council’s Cleaning Services has arrangements in place to carry out regular cleaning of
Council establishments where this has been requested.  Each establishment has specific cleaning
staff allocated to undertake a pre-planned schedule of cleaning at an agreed frequency. 
18. The service has recently gone through changes to the management structure.  To support
delivery of cleaning services across the geographic area of the Council, the Commercial Services
current structure is:
• Senior Manager - Catering, Cleaning, Events and Food Strategy
• two Operational Delivery Managers, one East and one West
• four Operational Officers, one for each Council area, have responsibility for both
catering and cleaning staff for the establishments within the areas.
19. Cleaning Services maintain the Cleaning Premises spreadsheet which has a list of premises
where cleaning has been requested.  This list is not compared to a Council premises list as it is
the responsibility of the Service occupying the building to request cleaning arrangements and to
notify any changes to cleaning services.
20. Specific arrangements for each premises and the assessed/measured area to be cleaned, are
detailed on the Cleaning Template which is maintained by the Operational Delivery Managers
who updates the template as changes occur.  For each establishment, this lists:
• The assessed/measured area to be cleaned
• The number of staff allocated to clean that premises
• The weekly hours per post and the working pattern of these hours.
21. Education Service has a central process for notifying changes to the cleaning requirements in
schools and, for other services, the Building Responsible Person for that establishment, will
contact the Operation Delivery Managers for that area.

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Argyll and Bute Council – Internal Audit Report – Building Cleaning, November 2025 
22. There are location-based arrangements in place to cover for staff annual leave and absence.
Each area has a list of casual staff to cover absences.  Cleaning services advised that they often
have difficulty recruiting cleaners for several different reasons, e.g. usually the hours are very
small, it is very hard physical work, the Council only advertise posts on My Job Scotland, and
many people don't actively look on this for cleaning jobs.  Cleaning staff often work out of hours
and are employed on the lowest pay grades and external cleaning companies may have more
enhanced benefits. 
37. Commercial Services maintain the Cleaning Manual, last updated August 2023.  This is a working
guide for managers and employees, it outlines the roles and responsibilities for cleaning, within
Commercial Services.  It is a practical reference tool to aid training and support compliance with
clearly defined cleaning procedures.  The manual sets out the health and safety standards and is
the overarching document that other cleaning service processes and documents are sourced.
38. New employees are given an induction pack which contains:
• Contact telephone numbers
• Council Health and Safety Policies -links and overview, how to report incidents
• General Health and Safety policies
• HR procedures including holiday entitlement
• Training Record card which should be signed by both the employee and the trainer
• Details “toolbox talks” available.
39. Operations Officers provide induction training to all new employees and existing staff moving
either location or changing type of establishment:
• Explanations of all sections within the induction pack
• Control of Substances Hazardous to Health Regulations (COSHH) training
• A walk though of the establishment explaining the requirements on the cleaning
schedule and materials to be used and location of the onsite Health and Safety folder.
40. Additional training after initial Induction training is only carried out if there have been changes
to legislation, cleaning schedules, or products used.  As cleaners undertake manual tasks that do
not require access to the Council computer network, they are classed as non-network staff and
have manual training records.
41. The On-Site Health and Safety folder contains employee training records.  This folder is reviewed
and updated biannually.  All updates must be read and signed off by all cleaners.  Operational
Delivery Managers also collate a manual record of GDPR training as a check that non-networked
staff have completed the training.  No documentation was checked during this review. 
42. 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.  This includes cleaning staff who work in schools and
nurseries etc.  
43. To comply with this legislation the Council carried out an organisation wide check of regulated
roles and took steps to ensure that the individuals, currently employed, in those roles undertook
the required level of Disclosure Checks and evidence of this is retained. The Council bore the
costs associated with this exercise.

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Argyll and Bute Council – Internal Audit Report – Building Cleaning, November 2025 
44. The Cleaning Services Induction pack should be reviewed to ensure that it contains up to date
links to key documents/ policies, reflects current working practices and if applicable, any
changes to processes required as a result of the change to the PVG scheme.
Action Plan 1
Cleaning standards are being utilised, and the quality of cleaning is monitored and reported
regularly.
23. The cleaning service operates under a structured cleaning methodology that aligns with industry
standards and best practices.  This methodology outlines the processes, equipment, and
materials to be used for different areas and ensures that all cleaning activities are carried out
effectively and consistently. 
24. The British Institute of Cleaning Science (BICs) is responsible for producing standards and
educational frameworks for the cleaning industry.  All cleaning staff and management undergo
regular training and professional development, including BICSc -accredited training, to maintain
high levels of competency and stay up to date with the latest cleaning techniques, health and
safety requirements, and quality assurance standards. 
25. Appropriate cleaning schedules and standards are in place to support the cleaning of council
establishments where this is requested.  The schedules vary depending on the Service occupying
the establishment, examples include Pre 5 Nursery, Schools and offices. 
26. Schedules are based on the structure cleaning methodology and are reviewed annually or as
required and detail:
• area to be cleaned, restricted to those that are accessible
• description of what should be cleaned and frequency i.e. daily/weekly
• description of cleaning activity that should be carried out
• acceptable standards
• description of what is not acceptable.
27. The cleaning service significantly reduced its cleaning specification in 2012 following the service
choices exercise that was undertaken in 2010 and was subject to an independent review in
2016/17 as part of the Catering and Cleaning Service Choices review.  This review noted that
“the current hours and standards are at the lower end of acceptable, but meet the basic
minimum requirements expected”.  We have been advised by the service that this remains the
case.
28. The current cleaning arrangements in schools and offices across the Council are historical,
although, plans have been developed to review this going forward.  Currently, in some cases,
cleaning is carried out based on the customer request, i.e. 2 hours, 1 day per week.
29. Cleaning services have implemented a review of these historical arrangements.  Plans are being
developed to re-measure all cleaning premises and re-calculate the cleaning requirements to
ensure the required standards are met.  To facilitate this re-measure, it was necessary for some
managers to have undertaken and completed the required BICs training.  
30. In addition to the above, cleaning services are working together with the Education
Management Team to update the cleaning schedules for Janitors and day cleaners, as this aspect

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Argyll and Bute Council – Internal Audit Report – Building Cleaning, November 2025
of the service sits within Education. In order to prevent confusion regarding roles and
responsibilities, it was agreed that job descriptions get reviewed at the same time.
31. To ensure that the Council’s cleaning schedules continue to meet industry standards, cleaning
services managers conduct regular reviews and audits of cleaning practices against established
benchmarks such as the BICs standards.  The Operations Officers or Managers carry out ad- hoc
spot check on premises on a regular basis.  No documentation relating to this was reviewed. 
32. The opportunity to feedback on the performance of the cleaning service is available to building
users via customer satisfaction questionnaire forms.  Responses are rarely received from internal
clients e.g. schools or offices, as they usually email or phone if there is a problem and the
operations officer or manager resolves any issues that have been highlighted.  Any issues arising
are discussed with the Senior Manager, Catering, Cleaning, Events and Food Strategy during the
weekly catch up meetings with the two Operational Delivery Managers.
33. Due to the lack of returns of the current customer satisfaction questionnaire forms, this has not
been included in the new performance dashboard.  To try and boost engagement, cleaning
services are considering the introduction of an online survey using MS Forms to capture
feedback. 
34. Commercial services submit data on the delivery of the cleaning service to an Annual Public
Sector Excellence Building Cleaning (APSE) benchmarking exercise.  APSE use this data and other
benchmarking information to create an annual benchmarking report. The results of this are used
to monitor performance year on year.  The Council benchmark against similar Local Authorities
but due to the logistical and unique issues in Argyll and Bute, benchmarking with another
authority can be more complex.
35. Reporting of performance and issues for the cleaning servicers are discussed at the Commercial
Services Teams meetings. No reports are currently provided to Council Committees.

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Appendix 1 – Action Plan
No Finding Risk Agreed Action Responsibility / Due Date
Low 1
Induction Pack
The Induction Pack contains out of date links and should
be reviewed to ensure it reflects current working
practices, and if applicable, reflect changes to the PVG
scheme.
New employees are not
provided with access to
relevant current Council
policies and procedures.
Induction pack to be reviewed and
all links updated.
Information on PVG changes will
be added when available.
Operational Delivery
Manager
30 March 2026

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Argyll and Bute Council – Internal Audit Report – Building Cleaning, 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 – Building Cleaning, 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.