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Internal Audit Reports to Audit and Scrutiny Committee 2025-26

Argyll and Bute Council · 12 June 2025
Back to Audit and Scrutiny Committee — 12 June 2025 and its agenda

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LiveArgyll
Internal Audit Report
May 2025
FINAL 
High Medium Low VFM
Number of
Findings
0 1 1 0 
Disclosure Checks –
Protecting Vulnerable Groups
Audit Opinion: Substantial

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LiveArgyll – Internal Audit Report – Disclosure Checks - PVG, May 2025 
Contents 
1. Executive Summary ........................................................................................................................ 3
Introduction ............................................................................................................................................ 3
Background ............................................................................................................................................. 3
Scope ....................................................................................................................................................... 4
Key Dates ................................................................................................................................................ 4
Risks ........................................................................................................................................................ 4
Audit Opinion ......................................................................................................................................... 4
Recommendations ................................................................................................................................. 5
2. Objectives and Summary Assessment ........................................................................................... 5
3. Detailed Findings ............................................................................................................................ 6
Appendix 1 – Action Plan ..................................................................................................................... 11
Appendix 2 – Audit Opinion ................................................................................................................. 13 
Contact Details 
Internal Auditor: Mhairi Weldon 
Telephone:  01546 604294 
e-mail:   Mhairi.weldon@argyll-bute.gov.uk 
www.argyll-bute.gov.uk

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LiveArgyll – Internal Audit Report – Disclosure Checks - PVG, May 2025 
1. Executive Summary
Introduction
1. As part of the 2024/25 internal audit plan, approved by the Audit & Scrutiny Committee in
March 2024, we have undertaken an audit of LiveArgyll’s system of internal control and
governance in relation to Disclosure Checks – Protecting Vulnerable Groups (PVG).
2. The audit was conducted in accordance with the Public Sector Internal Audit Standards (PSIAS)
with our conclusions based on discussions with LiveArgyll 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 LiveArgyll.
3. The contents of this report have been agreed with the appropriate LiveArgyll and Argyll and Bute
Council (The 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 PVG scheme is managed by Disclosure Scotland.  It helps ensure people who are unsuitable
to work with children and protected adults cannot undertake regulated roles with these
vulnerable groups.
5. From 1 April 2025, it is a legal requirement for individuals to be a member of the PVG scheme
when carrying out a regulated role with children, protected adults, or both.  Organisations must
ensure that individuals who are to carry out a regulated role (paid or voluntary) have PVG
scheme membership from 1 April 2025 onwards.  Failure to do so will be considered an offence.
6. It is also an offence for individuals to seek, agree to do or carry out a regulated role if they are
barred from doing so or for organisations to offer a regulated role to someone who is barred
from that specific type of regulated role.  Penalties for these offences are up to five years
imprisonment and/or a fine up to the statutory maximum.
7. Schedules 2 and 3 of the PVG Act 2007 provides listings of regulated roles in working with
children and protected adults.  The listings are comprehensive and roles that are relevant to
services provided by LiveArgyll include:
• Education and training – Teaching, instructing or delivering training 
• Leisure activities – Providing cultural, leisure, social or recreational activities 
• Sports activities – Coaching in relation to sports or physical activity
8. Any posts that fall within the scope of the PVG scheme requires the successful candidate to
obtain membership of the scheme prior to any unconditional offer of appointment being made,
additionally, any current employee changing to a regulated role must have the necessary
membership in place.
9. The disclosure process includes a requirement for applicants to share a copy of their disclosure
with the accredited body that countersigned the application from 1 April 2025, or to notify
Disclosure Scotland that they will seek a review of the content of their disclosure result.

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LiveArgyll – Internal Audit Report – Disclosure Checks - PVG, May 2025 
10. Organisations should notify Disclosure Scotland when a PVG scheme member stops doing
regulated work with them to ensure compliance with data protection legislation.
11. The Council operates as the lead signatory on the overarching account with Disclosure Scotland,
including PVG requirements for LiveArgyll employees and volunteers.  All correspondence on
behalf of LiveArgyll, therefore, takes place through the Council’s Human Resources (HR) and
Education services.  
Scope 
12. The scope of the audit was to assess the systems in place for the processing of staff and
volunteer Disclosure Checks for those working and volunteering with vulnerable individuals. 
This review covered staff employed and volunteers engaged by LiveArgyll in such roles as
outlined in the Terms of Reference agreed with the Chief Officer on 01 May 2025. 
Key Dates
13. 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 01 May 2025
Fieldwork Commencement 18 March 2025
Draft Report issued 16 May 2025
Management Comments received 29 May 2025
Final Report issued 29 May 2025
Audit and Scrutiny Committee 12 June 2025 
Risks
14.  The risks considered throughout the audit were:
• LA RR People 3:  Failure to ensure young people and vulnerable adults are safeguarded
when engaging with LiveArgyll
• Audit Risk 1:  Failure to comply with requirements of the Protection of Vulnerable
Groups (Scotland) Act 2007 
Audit Opinion
15. 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 are provided in Appendix 2 to this report.
16. Our overall audit opinion for this audit is that we can take a substantial level of assurance.  This
means that 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

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LiveArgyll – Internal Audit Report – Disclosure Checks - PVG, May 2025 
residual risk that are slightly above an acceptable level and need to be addressed within a
reasonable timescale.
Recommendations
17. We have highlighted one medium priority recommendations and one low priority
recommendations where we believe there is scope to strengthen the control and governance
environment. These are summarised below:
• Management should be reminded of the importance of ensuring that all documentation
in support of employee PVG applications is checked and passed to the Council’s HR team
in its entirety for retention purpose.
• Version control should be added to the managers guide to recruitment and the
Safeguarding policy should have existing errors corrected during review to update for
new PVG legislation requirements.
18. 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
19. Exhibit 1 sets out the control objectives identified during the planning phase of the audit and our
assessment against each objective.  
Exhibit 2 – Summary Assessment of Control Objectives 
Control Objective Link to Risk Assessment Summary Conclusion
1 Policies, procedures
and processes are in
place to manage
PVG requirements,
are regularly
reviewed and clearly
guide management
to identify regulated
roles requiring PVG
scheme
membership
All Risks Substantial LiveArgyll operates using the Council’s
policies, processes and guidance in
respect of recruitment and PVG
requirements. These documents are
available to all employees and are due
to be updated to incorporate new
legislation, however there is no version
control on one document and some
historic errors have not been corrected
on another.  Guidance is available and
followed to identify roles requiring PVG
membership and comprehensive
information is provided to applicants
during advertising and recruitment.
2 Job descriptions and
volunteer roles
clearly identify
where PVG
membership is
required and
mechanisms are in
place to ensure
membership is in
place prior to
All Risks Substantial Records of employee and volunteer
applications and status are maintained.
Regulated roles requiring PVG
membership are clearly communicated
at recruitment, and management are
advised of relevant documentation
required to support applications. PVG
membership had been confirmed for
all relevant employees and volunteers
within the samples selected, however,

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LiveArgyll – Internal Audit Report – Disclosure Checks - PVG, May 2025 
Control Objective Link to Risk Assessment Summary Conclusion
commencing these
roles
all supporting documentation could
not be located for 2 employees.
3 Arrangements are in
place to follow-up
on allegations made,
updates provided by
Disclosure Scotland
and to renew
membership after 5
years
All Risks Substantial Safeguarding training is provided at
induction and periodically thereafter
with records maintained at each
LiveArgyll facility.  A Safeguarding Lead
and Officers have been appointed and
are appropriately positioned within
LiveArgyll to progress any reported
matters regarding safeguarding.  A
robust disciplinary process is in place to
progress any safeguarding concerns
arising.  Plans for routine renewal of
PVG membership will be considered
once the current exercise to process
new PVGs as a result of changed
legislation is complete.
4 Arrangements are in
place to confirm
that partner
organisations have
valid PVG
membership and
training in place
All Risks Substantial Independent organisations are
responsible for ensuring their own
compliance with PVG legislation.  To
use LiveArgyll facilities, these
organisations are required to indicate
compliance on their registration and
booking information and are subject to
periodic sample checking for ongoing
compliance.  Any organisation
indicating non-compliance will be
refused use of the facility. 
20. Further details of our conclusions against each control objective can be found in Section 3 of this
report.  
3. Detailed Findings
Policies, procedures and processes are in place to manage PVG requirements, are regularly
reviewed and clearly guide management to identify regulated roles requiring PVG scheme
membership
21. LiveArgyll has adopted the Council’s policies and processes in respect of recruitment and
safeguarding with some adjustments made to accommodate local requirements.  The Council’s
suite of documentation is available via the HUB intranet site and MyCouncilWorks resource
website and are accessible to management and employees with corporate email accounts.  The
LiveArgyll specific versions are available to relevant employees on a shared drive within the
corporate server area.
22. Both the LiveArgyll specific Manager’s Guide to Recruitment and Safeguarding Policy are
planned to be updated to incorporate new legislation.  The Managers Guide is comprehensive,
providing clear guidance on PVG requirements when recruiting, however, it has no version
control applied to help ensure the most up-to-date guidance is being used.  The Safeguarding

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LiveArgyll – Internal Audit Report – Disclosure Checks - PVG, May 2025 
Policy, is also comprehensive, however, it contains historic errors regarding page numbering and
an incorrect reference to a PVG policy.  The errors had previously been identified by the Senior
Business Support Officer and amendments requested but these have not yet been completed
and made available to the relevant employees.
Action Plan 2
23. The need for PVG membership is most commonly identified during recruitment or transfer to
regulated roles.  The overarching recruitment process adopted by the Council and LiveArgyll is
embedded within the MyJobScotland recruitment portal used by local authorities and other
public sector bodies in Scotland.  Within this portal, the need for PVG membership is
communicated to all applicants alongside the specific role requirements to help guide the
applicant through the recruitment process and provide the relevant supporting documentation.
Where PVG membership is a requirement of a specific role, all applicants are advised at
interview stage that no formal offer of employment is made pending PVG clearance.
24. Roles requiring PVG membership are identified by management in consideration of duties to be
performed and who the employee is likely to interact with, additionally, guidance provided
within the Disclosure Scotland website and details stated within the Protection of Vulnerable
Groups (Scotland) Act 2007 and Disclosure (Scotland) Act 2020 are referred to.  All job
descriptions are currently under review to ensure compliance with updated legislative
requirements which extends the necessity for PVG membership to roles where it may not have
previously been required, this includes both frontline employees and their respective managers
throughout the LiveArgyll hierarchy.  
25. The Council is the “umbrella” organisation for progressing PVG scheme memberships on behalf
of LiveArgyll, and as such, it submits all applications to Disclosure Scotland via an online portal
and receives outcomes that are passed onto LiveArgyll via confirmation email. 
26. The Council’s new HR system contains a user defined field to identify whether a post requires
the holder to be a member of the PVG scheme and the supporting documentation is retained on
the associated document management system.  
27. Volunteer information is not retained on the HR system, instead, a database is maintained by
the Council’s Education team to monitor PVG status.  Documentation required in support of PVG
applications for volunteers is not retained once confirmation of membership is received so as to
comply with data protection requirements.   
Job descriptions and volunteer roles clearly identify where PVG membership is required and
mechanisms are in place to ensure membership is in place prior to commencing these roles
28. LiveArgyll maintain a register of PVG applications sent to the Council for processing dating from
January 2023.  A full list of current post holders requiring membership of the PVG scheme was
requested from the Council’s HR team and this was used to select a sample for review to assess
if PVGs were in place and that the application process was followed correctly.  
29. Job adverts are not retained in the individual’s HR file, these are posted on the MyJobScotland
recruitment portal and can be viewed while active and for a period when recruitment has
completed.  Adverts state that applicants should note that the post requires PVG membership in
relation to the specific protected groups for which the role covers i.e. children or vulnerable
adults.

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LiveArgyll – Internal Audit Report – Disclosure Checks - PVG, May 2025 
30. Job descriptions do not routinely include details of whether the post is considered to be a
regulated role or whether PVG membership is required, however, where the post does entail a
regulated role, a separate information document is included within the portal advising this is the
case and the additional information required to be provided to support the application process.
31. An additional pack of documents is provided to the recruiting manager to ensure all information
required in support of a PVG application is gathered, verified and passed to their relevant
colleagues for processing.
32. A sample of 15 LiveArgyll employees requiring PVG membership was selected for review to
confirm that the appropriate supporting documentation had been provided to management for
passing to HR to progress a PVG application.  The appropriate documentation was located for all
but 2 employees, one of whom was transferred from Education and one whose recruitment pre-
dates information held on “Cryoserver” (email archive) for retrieval.  We are advised that the
appropriate documentation must have been provided to enable the application to progress,
however, this could not be located at the time of the audit.
Action Plan 1
33. Evidence of PVG membership was located for 13 of the 15 employees reviewed, one did not
require a PVG and one was in progress due to updated legislation.  
34. The same sample was reviewed to assess if the appointment commenced prior to confirmation
of PVG membership and this was found to be satisfactory taking into account a brief supervised
induction period, changes to roles and new legislation requirements.  
35. A full list of current volunteers requiring membership of the PVG scheme was requested from
the Council’s Education team and this was used to select a sample of 15 for review to assess if
PVG memberships were in place and that the application process was followed correctly.
36. The LiveArgyll website provides a dedicated area for volunteering allowing interested parties to
obtain information and apply for roles they are interested in, specific roles are not advertised as
vacancies for filling. 
37. A suite of documents was made available for review including a volunteer policy, agreement and
forms for completion and were found to be comprehensive in providing the volunteer and
management with relevant and useful information regarding PVG membership requirements.
38. As with employees, volunteers are required to provide 3 forms of ID to enable their PVG
application to be processed.  These documents along with the application form are passed to the
Council’s Education team and deleted by both parties upon receipt of confirmation of PVG
scheme membership so as to comply with data protection requirements.  
39. Confirmation of PVG membership was provided for all 15 volunteers within the sample selected
and whilst there is no evidence of volunteer start date, we are advised that roles do not
commence prior to receipt of PVG confirmation in compliance with the Safeguarding Operating
procedure. 
40. The Council’s HR team routinely advise Disclosure Scotland when employees undertaking
regulated roles leave the Council/LiveArgyll to remove the noted interest in the individual.  The
Council’s Education team also indicate that Disclosure Scotland are informed of leavers upon
completion of their annual review of volunteers.

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Arrangements are in place to follow-up on allegations made, updates provided by Disclosure
Scotland and to renew membership after 5 years
41. The Safeguarding Policy states that induction and ongoing training is provided to employees,
safeguarding training is also included within employee conversations and refresher training
provided every 3 years.  Each LiveArgyll facility retains its own training records and these were
reviewed for 2 facilities where safeguarding training was evidenced as having been completed
between January 2024 and March 2025.  
42.  The Safeguarding Policy is available within the staff rooms of each facility and includes the
named Designated Safeguarding Lead (DSL) and Officers (DSO) who are appropriately positioned
within the organisation to take action regarding any reported matters. 
43. LiveArgyll follows the Council’s disciplinary process, this is a robust process guided by the
Council’s HR team and Disclosure Scotland would be notified if there were any reportable
findings.  Similarly, should the Council/LiveArgyll be notified of any concerns directly from
Disclosure Scotland, an investigation would take place in accordance with the Disciplinary
process.  Results of any investigation would be assessed on an individual basis to arrive at a
decision with the employee/volunteer placed on suspension in the intervening period.  To date,
there has been no requirement to follow this process for either employees or volunteers.
44. From 1 April 2026, lifetime membership of the PVG scheme will end and be replaced by a time-
limited membership requiring to be renewed every 5 years.   The Council’s HR system is under
development to generate alerts when PVG renewals are due and will liaise with LiveArgyll in
respect of their employees.  In addition to this planned functionality of the HR system, LiveArgyll
currently maintains a spreadsheet containing date fields that will enable identification of
employees who are due for PVG renewal.   LiveArgyll has commenced an exercise to identify
employees whose PVG membership requires to be renewed in advance of the 1 April 2026
implementation date and will be progressed upon completion of the current exercise to arrange
PVG membership for employees whose roles newly require PVG membership as a result of the
recent legislative changes.
45. Initial discussions have taken place within the Education team regarding renewal requirements
of PVG membership for volunteers.  The PVG records maintained within the database contain
the relevant date fields required to identify volunteers approaching their renewal dates and
management will be informed using the same communication links as the annual review of
volunteers.
Arrangements are in place to confirm that partner organisations have valid PVG membership
and training in place 
46. Independent organisations using LiveArgyll facilities may opt for accreditation to demonstrate
their commitment to being safe, well organised, inclusive and making a difference to their local
community.  Accreditation must be renewed annually and is encouraged, it also provides the
additional benefits of discounts, recognition and support from LiveArgyll.   As part of the
accreditation requirement, organisations must have PVG processes and safeguarding policies in
place unless they provide assurance that no under 18s or vulnerable adults participate.
47. The facility booking form includes a section advising that it is the responsibility of the
independent organisation to ensure compliance with the PVG Act where relevant and a link to

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LiveArgyll – Internal Audit Report – Disclosure Checks - PVG, May 2025 
the national guidance is provided for further information.  Any organisation indicating non-
compliance will be refused use of the facility.  
48. Independent organisations using LiveArgyll facilities are subject to a periodic sample check to
ensure ongoing compliance with PVG requirements and other specific criteria.

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Appendix 1 – Action Plan 
No Finding Risk Agreed Action Responsibility / Due Date
Medium
1 PVG application Supporting ID documentation 
Finding:  The appropriate supporting documentation to
progress a PVG application was located for all but 2
employees, one of whom was transferred from a long-
term role in Education and one whose recruitment pre-
dates information held on “Cryoserver” for retrieval. 
Recommendation:  Whilst these are exceptional and
historical issues, it would be prudent to remind 
management of the importance of ensuring that all
supporting documentation is checked and provided to HR
for retention in support of employee’s PVG applications.
PVG may be processed
based on provision of
insufficient/incorrect
documentation 
Communication to all
managers reminding
them of the importance
of ensuring that all
supporting
documentation is sent
to LiveArgyll HR to be
checked and
documented.
Services and Support
Manager 
02 June 2025 
Low
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.
Managers and
employees may refer to
and follow expired or
erroneous guidance
Document control
protocols in relation to
legislative updates will
be reviewed and the
process updated where
needed.
Services and Support
Manager 
31 July 2025

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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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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.