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2023_2024_InternalAudit_SSSCRegistration_Report_Final2

Argyll and Bute Council · 13 June 2024
Back to Audit and Scrutiny Committee — 13 June 2024 and its agenda

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Argyll and Bute Council
Internal Audit Report
May 2024
FINAL 
High Medium Low VFM
Number of
Findings
1 1 4 0 
Scottish Social Services
Council (SSSC) Registration
Audit Opinion: Substantial

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Argyll and Bute Council – Internal Audit Report – SSSC Registration, May 2024 
Contents 
1. Executive Summary ........................................................................................................................ 3
Introduction ............................................................................................................................................ 3
Background ............................................................................................................................................. 3
Scope ....................................................................................................................................................... 4
Risks ........................................................................................................................................................ 4
Audit Opinion ......................................................................................................................................... 4
Recommendations ................................................................................................................................. 4
2. Objectives and Summary Assessment ........................................................................................... 5
3. Detailed Findings ............................................................................................................................ 6
Appendix 1 – Action Plan ..................................................................................................................... 12
Appendix 2 – Audit Opinion ................................................................................................................. 16 
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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Argyll and Bute Council – Internal Audit Report – SSSC Registration, May 2024
1. Executive Summary
Introduction
1. As part of the 2023/24 internal audit plan, approved by the Audit & Scrutiny Committee in
March 2023, we have undertaken an audit of Argyll and Bute Council’s (the Council) system of
internal control and governance in relation to Scottish Social Services Council (SSSC)
Registration.
2. The audit was conducted in accordance with the Public Sector Internal Audit Standards (PSIAS)
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 SSSC are the regulator for the social work and social care workforce in Scotland, they protect
the public by registering social care workers, social workers, social work students and children
and young people workers in a range of care services including residential and day centres,
community facilities and in people’s homes.  The SSSC Register was set up under the Regulation
of Care (Scotland) Act 2001 to regulate social service workers and to promote their education
and training.
5. The SSSC set standards for work practices, conduct, training and education and supports
professional development, their regulatory function means that services are provided by a
trusted, skilled, confident and valued workforce.  Where workers fail to meet the standards of
practice and conduct required, the SSSC can investigate and take action.
6. Registration with the SSSC depends on the employee’s role and responsibilities of their post and
formal qualifications must be achieved within the timeframe outlined by the SSSC.  Employers
and employees are legally bound by these requirements and therefore unable to provide
registered services with unregistered staff.
7. The Council must meet the following responsibilities as set out within the SSSC Codes of Practice
(prior to the new codes published on 1 May 2024): 
 Make sure people are suitable to be social service workers and that they understand
their roles and responsibilities
 Have the culture and systems in place to support social service workers to meet their
code of practice
 Provide learning and development opportunities to enable social service workers to
strengthen and develop their skills and knowledge
 Have written policies and procedures in place to protect people who use services and
carers, and to support social services workers

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Argyll and Bute Council – Internal Audit Report – SSSC Registration, May 2024
 Publicise and promote the Code of Practice for Social Service Workers to people who use
services and carers and cooperate with SSSC in their proceedings
8. As at 01 November 2023, within the Health and Community Care service area of the Health and
Social Care Partnership (HSCP) there are 386 employees, 314 of whom require to be SSSC
registered.  There are a further 270 employees within other service areas of the HSCP and 335
within Education nurseries and schools who also require to be SSSC registered.  
9. The policies, procedures and processes to support SSSC requirements are standardised across all
Council areas, a sample of care homes was selected to evidence the application of these and any
areas of best practice identified or recommendations raised as a result of this review will be
communicated across all relevant service areas.
Scope 
10. The scope of the audit was to assess the arrangements for evidencing SSSC registration,
monitoring and renewals within the Council as outlined in the Terms of Reference agreed with
the Head of Adults – Health & Community Care on 21 November 2023. 
Risks
11.  The risks considered throughout the audit were:
 Audit Risk 1:  The Council does not meet it responsibilities as set out in section 53 of the
Regulation of Care (Scotland) Act 2001 and the SSSC Codes of Practice
 Audit Risk 2: The Council is unable to provide a full range of services required or provides
services with unregistered employees
Audit Opinion
12. 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.
13. 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
residual risk that are slightly above an acceptable level and need to be addressed within a
reasonable timescale.  
Recommendations
14. We have highlighted one high priority recommendations, one medium priority
recommendations and four low priority recommendations where we believe there is scope to
strengthen the control and governance environment.  These are summarised below:
 Version control should be applied to the SSSC Registration Policy and Guidance
Documents
 Corporate HR Policies, procedures and guidance documents should be reviewed to
ensure content is up-to-date.

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Argyll and Bute Council – Internal Audit Report – SSSC Registration, May 2024
 Service user documentation should be updated to advise that instances of violence,
threats or abuse directed towards employees is not acceptable.
 The Supervision Policy should be reviewed and updated to ensure it incorporates up-to-
date needs and requirements of service delivery.
 The updated Supervision Policy should be circulated to managers with an instruction to
comply with the content in a consistent manner.
 The content of care home handbooks should be updated to ensure complaints contact
details are consistently provided.
15. 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
16. 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 Appropriate policies
and procedures
have been prepared
and communicated
to guide
management and
employees in
meeting the
requirements as set
out in the SSSC
Codes of Practice.
Audit Risks 1
& 2
Substantial Policies, procedures and guidance have
been prepared and made available to
all employees, however, some of these
are overdue for review or lack
application of version control.  A
comprehensive induction process is in
place to guide employees in their new
role in terms of duties and conduct,
however, there was no information to
service users regarding conduct
towards employees and only one care
home advised visitors of expected
conduct in their handbook. 
2 Processes are in
place and being
followed to ensure
compliance with
SSSC Codes of
Practice.
Audit Risks 1
& 2
Substantial Records of SSSC registration status are
maintained both locally and online with
the SSSC.  Recruitment follows a robust
and consistent corporate process with
appropriate checks in place.  The
Supervision policy is dated November
2011, it is applied inconsistently across
the care homes reviewed and
requirements documented are
considered to be resource intensive. 
Feedback is gathered from service
users and employees and used to
inform improvements, both on an
individual and service level.  A Social
Work Training Board has been
established to oversee training across
all Social Work services to identify
needs, discuss progress through SVQ

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achievements and CPL requirements
and monitor the assigned budget. 
Support is provided to managers and
employees via corporate processes. 
3 Reporting
arrangements are in
place to inform
management of
risks/issues
identified that may
require action to be
taken.
Audit Risks 1
& 2
Substantial Employees SSSC registration status is
recorded both locally and on the SSSC
database, these are monitored and
updated by managers, HR provide a six-
monthly SSSC Registration status
report for Senior Management
oversight.  Concerns may be reported
both informally and formally to
management or via the Council’s
“Whistleblowing” policy.  Reporting
arrangements are in place to notify the
Care Inspectorate with staffing reports
and referrals to SSSC where an
employee is considered unfit to
practice. 
17. Further details of our conclusions against each control objective can be found in Section 3 of this
report.  
3. Detailed Findings
Appropriate policies and procedures have been prepared and communicated to guide
management and employees in meeting the requirements as set out in the SSSC Codes of
Practice.
18. The Council’s Scottish Social Services Council (SSSC) Registration Policy and associated guidance
have been prepared to support compliance with SSSC requirements and made available to all
Council employees on the Council’s intranet site (The Hub) for those with a corporate email
address and on the employee website (My Council Works) available to all.  Printed copies are
also made available at Council offices and residential locations.  
19. The content of both documents is comprehensive, easy to use and outlines the duties of the
employer and employee in terms of maintaining registration.  These documents, however, are
not dated and there is no evidence of any review date having been considered.   
Action Plan 1
20. There are several additional policies, procedures and guidance that also support compliance
with SSSC requirements, most of which apply corporately and are prepared and updated by
Human Resources (HR):
 Dignity at Work Policy (Bullying & Harassment)
 Equality & Diversity Policy
 Equality and Socio-Economic Impact Assessment
 Grievance Procedure
 Disciplinary Procedures and Code of Practice
 Managers guide to recruitment & Selection

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 Phased Return to Work and Other Reasonable Adjustments: managers guide
 Employee Code of Conduct
 Social Work Complaints Procedure
These documents are comprehensive and provide specific information regarding SSSC
requirements where appropriate, several of these documents, however, do not exhibit
evidence of updates or review within either the stated or a reasonable timescale and some
embedded links to source further information are no longer active. 
Action Plan 1 & 2
21. The Council also provides Health, Safety and Wellbeing services and resources as well as an
Employee Assistance Programme for any employee to access should a need for specific support
be identified.  
22. Newly employed or transferring social workers/social care workers undertake an induction
programme under the guidance of their new line manager.  This is largely a corporate
programme supplemented with service and location specific information.  The specific roles and
requirements of each post are articulated by managers and colleagues as well as being
documented in the formal job descriptions and person specifications.
23. As part of the induction process, new employees are informed that bullying, harassment and
discrimination is not tolerated and formal action under the Council’s Disciplinary Procedures and
Code of Practice will be taken to deal with such behaviour.  
24. In addition to the formal policies and procedures noted above, the Council also operates a Public
Interest Disclosure (“Whistleblowing”) Policy whereby employees as well as the general public
can bring their concerns regarding social workers/social care workers to the attention of
management, including impairment of fitness to practice; exploitation, dangerous,
discriminatory or abusive behaviour/practice or cause of physical, emotional financial or
material harm/loss.  
25. Social workers/social care workers are clearly informed that violence, threats or abuse are not
acceptable via their terms and conditions of employment, employee codes of conduct and
dignity at work policy.  The Health and Social Care Standards advise service users and their
family, friends and non-Council carers of the principles based quality of care they can expect to
be provided.  There is no content within these documents to acknowledge that violence directed
towards employees from service users or their family, friends or non-Council Carers are not
acceptable.  The Resident and Family Handbook prepared for Ardfenaig does, however, advise
visitors that their conduct should allow employees to undertake their duties free from threat or
perceived threat of violence or intimidation. 
Action Plan 3
26. Policies, procedures and eLearning materials are in place and made available on both the Hub
and My Council Works to support wellbeing and equality of social workers/social care workers
and respect diversity.

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Processes are in place and being followed to ensure compliance with SSSC Codes of Practice.
27. Line managers maintain a record of registration status relevant to their teams and have access
to view the SSSC registration database for Council employees to help keep this up-to-date.  The
Council’s Human Resources (HR) team also have access to the SSSC registration database and
conduct a six-monthly exercise to monitor status and identify any anomalies, this is then passed
to Heads of Service for oversight and action as necessary.  As at September 2023, there were 76
employees registered, 46 registered with conditions and one application submitted for
registration within the Acute and Complex Care Service.  
28. Recruitment of social workers/social care workers follows a robust process that is applied
corporately using the TalentLink service.  This ensures that a standardised approach is followed
when filling a post following approval by management.  Each post is advertised and short-listed
by reviewing the application provided to assess suitability in terms of knowledge, skills, attitude
and values, an interview panel of at least two persons is then appointed to select the successful
candidate on a competitive basis.  Information for managers regarding the recruitment process
is available on the Hub to support this process.
29. Criminal conviction checks, membership of the Disclosure Scotland Protection of Vulnerable
Groups (PVG) scheme and references are required as part of the recruitment process.  A sample
of ten employees was selected from the registration lists provided and checked to HR records
where all ten were found to comply with the requirements. 
30. The Council has a Supervision Policy in place to ensure high standards of professional care are
maintained, areas for improvement are identified and employees are supported when
undertaking their duties.  The Policy provided is dated November 2011 with no evidence of
review or update and evidence of compliance with the policy, where provided, was limited and
inconsistent with the embedded templates.  Discussions with two managers reveal that they are
unable to fully comply with the requirements of the Policy and consider these to be unrealistic in
terms of current available resources. 
Action Plan 4 & 5
31. Feedback is gathered from service users at residents or focus group meetings with
representatives attending from the different staff groups to gather opinions and thoughts on the
care and facilities provided and consider where service improvements can be made.  Review
meetings are also carried out for individual residents to gather feedback on more personal
requirements to help inform revisions to care plans and specific individual needs.   
32. Managers support employees to various extents depending on their specific training, continuous
professional learning (CPL) needs and current operational demands.  The various needs and
opportunities for training are discussed collectively at staff meetings and individually at
supervision meetings or during career conversations, observational monitoring also takes place
to identify any additional areas for improvement or further training.   SVQ assessors visit
learners where possible or conduct interviews online using Teams.  
33. Employees from other professions such as nursing or teaching are considered to be equally
supported to meet the requirements as set out within their codes of practice.
34. There is a robust induction process in place for new employees with guidance provided both
verbally and via access to formal documentation covering a range of both corporate and service

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specific information.  There are four stages to the induction process, each with specific goals to
be met within the first few days, first week, six weeks and six months.  
35. Training opportunities are available to permanent employees wishing to progress through
formal SVQs and are tailored to their individual needs identified at recruitment or via
supervision meetings and career conversations.  
36. The Social Work Training Board has been established to oversee training across all Social Work
and Social Care services.  This Board identifies needs, discusses SVQ attainment progress and
monitors the assigned budget to ensure service delivery is aligned with strategic priorities and
staff are appropriately developed to meet their registration conditions and CPL requirements. 
Training opportunities focus on permanent employees, casual employees cannot be retained
after five years without receipt of training to meet registration conditions resulting in loss of
experienced employees.  Discussions have taken place regarding provision of support to casual
employees to obtain qualifications, however, with limited budget, permanent employees must
be prioritised.  
37. Managers and colleagues support employees who feel unable or unprepared to carry out their
work wherever possible to ensure an acceptable standard of service is provided, this will vary
from person to person.  A corporate Performance Improvement Procedure has been prepared
and made available to all on the Hub should a more formal approach be required.   Protected
conversations and allocation of a mentor to provide closer support may also be provided and
where support of a more personal nature is required the employee and eligible family members
have access to the Employee Assistance Programme (EAP) for independent and confidential
support and information.
38. Reflective practice identifies development and improvement opportunities and takes place daily
at hand-over between teams and at scheduled team meetings, supervision sessions and career
conversations.  
39. Employees who have experienced violence or trauma in the work place are provided with peer
support and opportunities to talk about issues identified.  Stress risk assessments are also used
and an accompanying action plan prepared to manage future work.   Where the experience has
led to a period of employee absence, the corporate Phased Return to Work Procedure may be
used and occupational health referrals made.   The EAP may also be accessed to provide support
in these circumstances.
40. Where an employee’s fitness to practice is considered to be impaired, they are provided with
clear communications and documentation to ensure processes are followed through and
wellbeing support is provided.  In some instances the employee may be redeployed or
suspended pending investigation and subsequent findings.
41. The care and safety of service users is prioritised while employees are receiving additional
support and adhere to the Adult Support and Protection (Scotland) Act 2007 and the new Health
and Care (Staffing) (Scotland) Act 2019 to ensure that “suitable qualified and competent
individuals are working in such numbers as are appropriate for the health, wellbeing and safety
of people using the service”.  A staffing level calculation tool is used to ensure there are
sufficient suitably qualified and competent employees present to provide services.
42. Copies of the SSSC Code of Practice are provided to employees as part of their induction process,
made available within their service location and freely available on the SSSC website.  All Social

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Workers/Social Care Workers are required to read and comply with the content in addition to
the content of the Registration Policy and guidance.  
43. The SSSC Codes of Practice are available online and at care homes for service users and visitors
to view.  They are also advised that employees are appropriately qualified (or working towards a
qualification), skilled and competent to carry out their duties and made aware that there is a
complaints procedure in place to report any concerns.  Two of the three handbooks provided
contained details of how to communicate any concerns.   
Action Point 6
44. The Council’s Employee relations team provide support to lead managers via the corporate
disciplinary process when concerns are raised about an employee’s fitness to practice.  As part
of this support, lead managers are provided with a suite of documents including templates and a
worked example to ensure the process is conducted in a fair and consistent manner, they are
also provided with guidance on when to refer the employee to the SSSC or other relevant
professional body.  Documentation reviewed indicated that the process had been followed
accordingly.  Managers are also able to contact the relevant professional body directly for
specific advice prior to any referrals being made. 
45. The Chief Social Worker is the first point of contact within the HSCP where the SSSC, other
relevant professional body or authority require assistance when investigating an employee’s
fitness to work, this could be in the form of documentation, attendance at hearings or responses
to enquiries.  Employees are enabled and supported to assist in these instances e.g. attend
hearings or provide witness statements.   
Reporting arrangements are in place to inform management of risks/issues identified that may
require action to be taken.
46. Management information regarding employee’s registration status is maintained locally via
spreadsheets and online access to the SSSC registers.  This information enables managers to
ensure records reflect current employee status, monitor progress in meeting any conditions set
and take action where registrations have or are about to expire.  The Council’s HR service also
undertake a six-monthly exercise to assess registration status and renewal position and flag
individuals appearing on the list who no longer work for the Council.
47. Where allegations of harm or abuse are received, the Council’s formal disciplinary process is
followed by management with support from the HR service and this includes appropriate
investigation and reporting.  
48. Employees may approach managers at any time to report and discuss concerns they may have
regarding inadequate resources, difficulties in delivering care or inappropriate/unsafe working
practices, they are also aware of the overarching management structure should they feel issues
need to be escalated.   The Council’s “Whistleblowing” policy provides an additional avenue for
concerns to be reported.
49. Weekly notifications are submitted to the Care Inspectorate on staffing issues including
absences and vacancies that may have an impact on service delivery.  Any concerns are raised
with senior management as they arise and are carefully monitored and managed via resident’s
dependency analysis.

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50. Managers are aware of their responsibility to make referrals regarding employees who are unfit
to practice to the appropriate authorities and are fully supported by the Council’s HR Service to
do so when the need arises.

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Appendix 1 – Action Plan 
No Finding Risk Agreed Action Responsibility / Due Date
Low 1
SSSC Registration Policy and Corporate HR Policies and
Guidance Documents
Finding:  The SSSC Registration Policy and guidance
document are not dated and there is no evidence of
review date having been considered.   
Finding: Several of the corporate policy and guidance
documents reviewed contained no evidence of update or
review in a reasonable timescale. 
Recommendation: Management should apply version
control and review schedules to the SSSC Registration and
wider Corporate HR Policy and Guidance documents. 
Management and employees
may use superseded versions
containing outdated
information, legislation,
regulations or standards. 
SSSC Registration Policy and
Guidance are currently under
review to reflect revised SSSC
Codes of Practice 1 May 2024,
version control will be applied
during this review. 
An exercise will be undertaken to
apply review dates to corporate
HR policy and guidance
documents and these reviews will
be scheduled to take place.
HR Officer 
HR Manager - Operations 
30 September 2024
Low 2
Corporate HR Policy and Guidance Documents 
Finding: Embedded links within policy and guidance
documents were no longer active in some instances. 
Recommendation: Links provided within documentation
should be reviewed and updated as necessary to ensure
they are returning expected information for employees. 
Links fail to provide further
information to assist
employees.
Links provided in policy and
guidance documents will be
reviewed and updated where
found to be no longer working. 
HR Manager - Operations 
30 September 2024
Low 3
Service-user information 
Finding: Service-users and their family, friends and non-
Council carers are advised that violence, threats or abuse
towards them from Council employees will not be
tolerated, however, only one handbook provided advised
visitors on expected conduct regarding violence, threats or
abuse towards employees.  There was no documentation
containing information regarding conduct of service users
towards employees. 
Lack of awareness that
violence, harm or abuse
directed at Council employees
from service-users or their
family, friends or non-Council
carers is not acceptable.
Review all social work and social
care service user documentation
in adult services.
Senior Manager –
Resources/ Professional
Lead – Social Work 
31 August 2024

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No Finding Risk Agreed Action Responsibility / Due Date
Recommendation: Service-user documentation should be
revised to advise that instances of violence, threats or
abuse directed towards employees is not acceptable. 
Medium
4
Supervision Policy 
Finding:  The Supervision Policy is dated November 2011
with no evidence of review or update, additionally, the
requirements in terms of frequency and duration of
supervision meetings are considered by mangers to be
unrealistic in terms of current available resources. 
Recommendation:  The Supervision Policy be reviewed and
updated to ensure it incorporates up-to-date needs and
requirements of service delivery. 
Supervision Policy does not
reflect current SSSC or Council
requirements.
Develop a social work and social
care supervision policy.
Professional Lead – Social
Work 
31 August 2024
High 5
Compliance with Supervision Policy 
Finding:  evidence of compliance with the supervision
policy was limited and embedded templates were not
being consistently used. 
Recommendation: Following review of the Supervision
Policy, Managers should be reminded of the need to
schedule supervision meetings with employees in advance
and retain records in an appropriate and consistent
format.   
Failure to comply with the
Council’s Supervision Policy.
Appropriate documentation will
be provided following
development of social work and
social care supervision policy.
Professional Lead – Social
Work 
31 August 2024
Low 6
Care Home Handbook 
Finding: Details of how to communicate
concerns/complaints were provided in two out of three
handbooks provided. 
Service users and visitors are
unable to escalate unresolved
concerns to the appropriate
bodies.
Review all care home
complaints/concerns processes.
Lead Nurse (Care Homes)   
31 July 2024

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No Finding Risk Agreed Action Responsibility / Due Date
Recommendation:  Review and update content of care
home handbooks to ensure complaints contact details are
consistently provided.

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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.