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Internal Audit Reports to Audit and Scrutiny Committee 2024/2025

Argyll and Bute Council · 17 December 2024
Back to Audit and Scrutiny Committee — 17 December 2024 and its agenda

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ARGYLL AND BUTE COUNCIL  AUDIT AND SCRUTINY COMMITTEE 
FINANCIAL SERVICES  17 DECEMBER 2024 
INTERNAL AUDIT REPORTS TO AUDIT AND SCRUTINY COMMITTEE 2024/2025 
1. EXECUTIVE SUMMARY 
1.1 There are seven audits being reported to the Audit and Scrutiny Committee.     
1.2 The table below provides a summary of the conclusions for the audits performed.
The full reports are included as appendices to this report. 
Audit Name Level of
Assurance
High
Actions
Medium
Actions
Low
Actions
VFM
Actions
Non-Domestic Rates Substantial 0 3 0 0
IR35 Off-Payroll Working and
Compliance Limited 2 2 0 0
IT Risk Register and Mitigation
Processes High 0 0 2 0
Community Education High 0 0 1 0
Culture (HSCP) Reasonable 0 5 0 0
Joint Strategic Planning (HSCP) Reasonable 0 2 1 0
Information Governance (HSCP) Substantial 0 2 1 0 
1.3 Internal Audit provides a level of assurance upon completion of audit work. A
definition for each assurance level is documented in each audit report. 
2. RECOMMENDATIONS 
2.1 Audit and Scrutiny Committee to review and endorse this summary report and the
detail within each individual report. 
3.  DETAIL 
3.1 A high level summary of each completed audit report is noted below: 
Non Domestic Rates (NDR): this audit has provided 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 residual risk that are slightly
above an acceptable level and need to be addressed within a reasonable
timescale. Policies and procedures are largely driven by legislation, with regular
annual updates provided by the Scottish Government. Standard procedures,
dated October 2023 are in place, this document covers Business Rates -

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liability, changes and business rates relief. On an annual basis the Scottish
Government provide regular bulletins as updates, however, this document is not
statutory. The document aims to inform a mutual understanding amongst local
authority practitioners. Detailed information about the reliefs available are found
on the Council website including standard application forms to be completed for
each category of relief.  Application for relief can be made online. During the
testing process of records it was found that there was very little in the way of
supporting documentation to substantiate claims for reliefs, in particular for
SBBS relief. There are no further checks undertaken to ensure that where relief
is applied that the business is still trading and entitled to the relief. Thirty
properties were selected testing, across a mix of available reliefs. Where
businesses are jointly owned, liability for NDR is joint and several, however, at
present, only one party is required to complete the application form and
declaration. There is very little guidance available to the Council to support how
NDR relief appeals should be managed, therefore the Council have adopted
their own system and processes.  At present there is no appeals process or an
independent panel set up and trained to hear NDR appeals. 
IR35 Off-Payroll Working and Compliance: This audit provided a limited level
of assurance, indicating that internal control, governance, and risk management
are displaying an unacceptable level of residual risk, which may compromise
system objectives. Key weaknesses identified must be addressed within a
reasonable timeframe, with management allocating appropriate resources to
resolve these issues. The audit report identified key areas for improvement in
the Council’s IR35 compliance process, resulting in two high priority, two
medium priority and one low priority recommendations. Main recommendations
include establishing a documented process for IR35 assessments, appointing a
responsible team or individual to improve clarity and accountability, ensuring
relevant staff receive training on the HMRC’s CEST tool, and implementing a
formal process to communicate IR35 legislative changes or procedural updates
to staff. It is important to note the context of the impact and this is unlikely to be
a widespread problem but will involve small pockets of staff across the
organisation in very specific roles. 
IT Risk Register and Mitigation Processes: this audit provided a high level of
assurance.  This means that internal control, governance and the management
of risk are of 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.  The Council’s Risk Management Manual has been followed in
preparation of the Cyber Security Risk Register (CSRR).  The CSRR includes
risks identified via sound judgement of officers involved and credible information
sources and are appropriately detailed along with evaluation and scoring.  All
risks have been assessed, scored and prioritised, however, current mitigations
are not recorded for all risks despite key actions and deadlines having been
identified and progressed, additionally, six risks were found to have residual
scores lower than gross scores although no current mitigations are recorded.  
Risks, mitigating controls and key actions are identified by Officers with
appropriate technical knowledge in collaboration with the ITC-CSO and passed
to Management for oversight and approval purposes.  All open risks are
reviewed monthly and reported to security, ITMT and DMT meetings, any new
insights received are considered immediately and escalated where required.  All
mitigating controls are reviewed and assessed for effectiveness and comments
noted on the CSRR where appropriate, however, evidence of review is not

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always retained and scoring is not regularly reassessed.  Management is made
aware of progress in managing identified risks at appropriate forums via formal
reporting mechanisms, the subsequent minutes indicate that the contents have
been discussed, noted and actions assigned where required. 
Community Education: 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. As required by the Community Learning & Development (Scotland)
Regulations 2013, the Argyll and Bute Community Learning and Development
(CLD) Strategic Partnership Plan 2024-2027 has been created and published
on the liveArgyll website in September 2024.There should be consistent use of
names throughout the new plan, and a check carried out to determine if all
appropriate logos are displayed. There are arrangements in place for the
provision of CLD across all four of Argyll and Bute Council areas for both
identified priority age groups - youth and adult. It is recognised by the Scottish
Government that the ability to meet the needs of learners is bound by funding
restrictions. The Adult Numeracy and Literacy provision is dependent on
funding, which is due to end March 2025. Alternative options are being explored
but there is a risk that these may not be met once funding ends. The Council
and liveArgyll via the SLA have agreed monitoring and reporting for
arrangements to ensure that there is appropriate strategic oversight and
scrutiny of the community learning provision across Argyll and Bute and
progress towards the strategic priorities and allows evaluation of the
effectiveness of CLD provision. 
Culture (HSCP) (For Noting): this audit provided a reasonable level of
assurance. This means that 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. The HSCP Culture
& Wellbeing Group work plan, dated 2023, should be updated to reflect priorities
that are specific, focussed, measurable and have clear outcomes with target
completion dates. Progress against the work plan should be clearly recorded
within the work plan. Consideration should be given as to how staff surveys
could focus on specific issues relating to the HSCP in order to assess the culture
within the HSCP. Consideration should be given to how the HSCP can better
communicate with staff across both organisations to encourage staff to
participate and share their views in surveys. Consideration should be given to
how a balance of staff between NHS Highland and the Council could be
represented on the Culture and Wellbeing Group. The HSCP Culture &
Wellbeing Group have developed a work plan, dated 2023, which outlines
priorities, outcomes, responsible person and timeframes. The group is
monitoring progress against the work plan which was approved in 2023. 
Progress reports are updated at Culture Group meetings and recorded in the
notes of the meeting Quarterly performance data reports on FOI’s are provided
to all Departmental Management Team (DMT) meetings. The Culture Group
meets on a regular basis.  The Terms of Reference for the Culture and
Wellbeing group were created in June 2022 with the most recent update in May
2023. Initially to get momentum going the group met 4 weekly, however, it was
felt to be too often and it was agreed to meet bimonthly. In 2023 the Group met
most months, with the exception on a few months when meetings were
cancelled.  Updates from the Culture Group are reported to the Senior

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Management Team (SLT) and the IJB, with minutes of the IJB available to
assess on the website. 
Joint Strategic Planning (HSCP) (For Noting): this audit provided a
reasonable level of assurance. This means that 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. In order to support the delivery of the JSP it is important that a
corresponding workforce plan is in place that is aligned with priorities and
objectives of the JSP and that it supports the attraction, recruitment,
development and retention of the workforce required to deliver the JSP. A
workforce plan has been published that covers the same period of the JSP i.e.
2022-2025. A review of the workforce plan noted that there was no evidence of
a direct alignment between the current workforce planning document and the
priorities and objectives set forth in the Joint Strategic Plan. Discussions with
the Head of Strategic Planning, Performance and Technology, HSCP noted that
the workforce plan was completed after the JSP due to COVID interfering with
the initial timelines of the workforce plan. Whilst there is extensive documentary
evidence of various implementation plans to meet the priorities and objectives
outlined within the JSP (see below) there is no documentary evidence that an
alignment has been carried out between the workforces and financial spends
against each of the priorities specified within the JSP. A review of the minutes
to the Strategic Leadership Team on 3rd May 2023 noted “difficulties in aligning
workforce and financial spends to priorities”. The Health and Social Care
Partnership (HSCP) has in place a Strategic Risk Register, which identifies the
risk of failing to achieve the Joint Strategic Plan and the potential consequences.
A review of the risk register confirmed the presence of mitigation measures
aimed at mitigating this risk. However, it was observed that there is a lack of a
specific risk register focusing on the risk and subsequent impact of not meeting
the individual priorities and objectives outlined within the Joint Strategic Plan
(JSP). It is recommended that the HSCP consider developing such a risk
register to address this gap. HSCP publish quarterly performance reporting
based on the Integrated Performance Management Framework (IPMF). A
review of a sample of performance reports noted that the performance reports
focus on eight key service areas. The reports provide detailed performance
analysis of each service area and the 93 supporting Key Performance Indicators
(KPIs), complemented by commentary from Heads of Service and Service
Leads. It also includes performance data on National Health & Wellbeing
Indicators, System Pressures, and National Delayed Discharge, utilising the
new performance dashboard within SharePoint for enhanced data access and
analysis. Whilst it was confirmed that the reports provide a wide range of
performance, it was noted that the reports do not specifically align to the
objectives and priorities of the JSP. 
Information Governance (HSCP) (For Noting): this audit provided 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 residual risk
that are slightly above an acceptable level and need to be addressed within a
reasonable timescale. The Integrated Joint Board adopted Argyll and Bute
Council's Records Management Policy (RMP) on January 30th, 2019 as the
basis for the IJB Records Management Plan. The Keeper of the Records of
Scotland's Assessment Team confirmed the Argyll and Bute Integrated Joint
Board (IJB) RMP is compliant with the Act. An information-sharing agreement

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was signed between Argyll and Bute Council and NHS Highland on May 28th,
2024. The Public Records (Scotland) Act 2011 mandates that the IJB appoints
the Governance, Risk, and Safety Manager of Argyll and Bute Council as the
operational lead for records management, with additional support from the
Business Improvement Manager of the HSCP, both of whom are skilled and
responsible for overseeing records management, data protection, and FOI
requests. Document reviews are outstanding in regards to the Records
Management Plan and the Information Governance Policy Framework. A
number of improvement recommendations made by the Keeper of Scotland
were identified in the areas such as Business clarification, retention schedules,
destruction arrangements, Archiving and Transfers and Business Continuity
and vital records. An action plan to address these areas should be agreed and
implemented. During 2023/24, the Council received 165 Subject Access
Requests, with 73% being responded to within the required 20-day timescale. It
is estimated that 85% of these requests pertain to the Social Work services
within the HSCP. However, a precise breakdown of the SARs pertaining to
Social Work services was not available. 
4. CONCLUSION 
4.1 Management has accepted each of the reports submitted and have agreed
responses and timescales in the respective action plans. 
5. IMPLICATIONS 
5.1 Policy – None 
5.2 Financial – None 
5.3 Legal – None 
5.4 HR – None
5.5 Fairer Scotland Duty – None 
5.5.1 Equalities – protected characteristics – None
5.5.2 Socio-economic Duty – None
5.5.3 Islands – None
5.6 Climate Change – None 
5.7 Risk – The implementation of recommendations contained in audit reports may
help mitigate the risk to the Council. 
5.8 Customer Service – None
5.9 The Rights of the Child (UNCRC) – None 
Paul Macaskill
Chief Internal Auditor
17 December 2024 
For further information contact: 
Paul Macaskill, Chief Internal Auditor
Tel:  01546 604108
Email: paul.macaskill@argyll-bute.gov.uk 
APPENDICES 
1. Non Domestic Rates (NDR) 
2. IR35 Off-Payroll Working and Compliance
3. IT Risk Register and Mitigation Processes

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4. Community Education
5. Culture (HSCP)
6. Joint Strategic Planning (HSCP)
7. Information Governance (HSCP)