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

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Page 1

Argyll and Bute Council 
Comhairle Earra-Ghàidheal Agus Bhòid 
Executive Director:  Douglas Hendry 
Kilmory, Lochgilphead, PA31 8RT
Tel:  01546 602127  Fax:  01546 604435
DX 599700 LOCHGILPHEAD
6 June 2024 
NOTICE OF MEETING 
A meeting of the AUDIT AND SCRUTINY COMMITTEE will be held BY MICROSOFT TEAMS on
THURSDAY, 13 JUNE 2024 at 11:00 AM, which you are requested to attend. 
Douglas Hendry
Executive Director 
BUSINESS 
1. APOLOGIES 
2. DECLARATIONS OF INTEREST 
3. MINUTE OF PREVIOUS MEETING OF THE AUDIT AND SCRUTINY COMMITTEE,
HELD ON 14 MARCH 2024 (Pages 3 - 10) 
AUDIT ITEMS 
4. INTERNAL AUDIT AND COUNTER FRAUD SUMMARY OF ACTIVITIES (Pages 11
- 18)  
Report by Chief Internal Auditor 
5. INTERNAL AND EXTERNAL AUDIT REPORT FOLLOW UP 2023-24 (Pages 19 -
36)  
Report by Chief Internal Auditor 
SCRUTINY ITEMS 
6. INTERNAL AUDIT - ANNUAL REPORT 2023/24 (Pages 37 - 60)  
Report by Chief Internal Auditor 
7. STATEMENT OF GOVERNANCE AND INTERNAL CONTROL (Pages 61 - 78)  
Report by Executive Director with responsibility for Legal and Regulatory Support 
8. EXTERNAL AUDIT - ANNUAL AUDIT PLAN, YEAR ENDING 31 MARCH 2024
(Pages 79 - 122)  
Report by Mazars 
9. LOCAL GOVERNMENT BENCHMARKING FRAMEWORK (LGBF): 2022/23 (Pages
Public Document Pack

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123 - 132)  
Report by Executive Director with responsibility for Customer Support Services 
10. UNAUDITED FINANCIAL ACCOUNTS - TO FOLLOW 
Report by Head of Financial Services 
11. WORKPLAN (Pages 133 - 136)  
For noting and updating 
12. INTERNAL AUDIT REPORTS TO AUDIT AND SCRUTINY COMMITTEE 2023/2024 
(a) Covering Report and Internal Audit Reports (Pages 137 - 212)   
Report by Chief Internal Auditor 
• Financial Ledger 
• Learning and Physical Disability Care Packages 
• Scottish Social Services Council (SSSC) Registration 
• Freedom of Information Requests
• Cloud Based Computer Services 
E1  (b) Internal Audit Report (Pages 213 - 230)   
• Client Funds Progress Review 
The Committee will be asked to pass a resolution in terms of Section 50 (A)(4) of the Local
Government (Scotland) Act 1973 to exclude the public for items of business with an “E” on the grounds
that it is likely to involve the disclosure of exempt information as defined in the appropriate paragraphs
of Part 1 of Schedule 7a to the Local Government (Scotland) Act 1973. 
The appropriate paragraphs are:- 
E1 
Paragraph 6 
Information relating to the financial or business affairs of any particular person (other than the
authority). 
Audit and Scrutiny Committee 
Janice Wason Hall (Chair) Councillor Daniel Hampsey
Councillor Graham Hardie Councillor Fiona Howard
Councillor Reeni Kennedy-Boyle Councillor Gary Mulvaney (Vice-Chair)
Councillor Andrew Vennard   
Shona Barton, Governance Manager 
Contact: Lynsey Innis, Senior Committee Assistant  Tel:  01546 604338

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MINUTES of MEETING of AUDIT AND SCRUTINY COMMITTEE held BY MICROSOFT TEAMS 
on THURSDAY, 14 MARCH 2024 
Present: Martin Caldwell (Chair) 
Janice Wason Hall
Councillor Daniel Hampsey
Councillor Graham Hardie 
Councillor Reeni Kennedy-Boyle
Councillor Dougie McFadzean 
Attending: Kirsty Flanagan, Executive Director/Section 95 Officer
Anne Blue, Head of Financial Services
Jane Fowler, Head of Customer Support Services
Paul MacAskill, Chief Internal Auditor
Shona Barton, Governance Manager
Morag Cupples, Finance Manager
Jennifer Coyle, Senior HR Business Partner
Mhairi Weldon, Senior Audit Assistant
Cameron Waddell, Partner, Mazars LLP
Gregory Odour, Audit Manager, Mazars LLP 
1. APOLOGIES 
The Chair welcomed everyone to the meeting and took the opportunity to introduce Janice
Wason Hall, who would be taking over the role of Chair of the Audit and Scrutiny
Committee from its next meeting in June 2024. 
Apologies for absence were intimated on behalf of Councillor Jim Lynch.   
2. DECLARATIONS OF INTEREST 
There were no declarations of interest intimated.   
3. MINUTE OF PREVIOUS MEETING OF THE AUDIT AND SCRUTINY
COMMITTEE HELD ON 19 DECEMBER 2023 
The Minute of the previous meeting of the Audit and Scrutiny Committee, held on 19
December 2023 was approved as a correct record. 
4. INTERNAL AUDIT AND COUNTER FRAUD SUMMARY OF ACTIVITIES 
The Committee gave consideration to a report providing a summary of Internal Audit
activity and progress during quarter four of 2023/24 against the following areas: 
Audits Completed 
• Piers and Harbours
• Pupil and Public Transport
• Human Resources – Casual Workers 
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Audits in Planning/in Progress 
• Client Funds 
• Learning and Disability Care Packages 
• Financial Ledger 
• Scottish Social Services Council (SSSC) Registration
• Freedom of Information Requests
• Cloud Based Computer Services 
The report also provided information on the work carried out by the Counter Fraud Team
(CFT); the continuous monitoring programme and the progress of work carried out as a
result of information received from the National Fraud Initiative (NFI). 
Decision 
The Audit and Scrutiny Committee reviewed and endorsed the Summary of Activities
report. 
(Reference:  Report by Chief Internal Auditor, dated 14 March 2024, submitted) 
5. INTERNAL AND EXTERNAL AUDIT REPORT FOLLOW UP 2023-24 
Consideration was given to a report which provided an update on all open actions as at 31
December 2023.  The report included information on actions where the agreed
implementation date had been rescheduled. 
Decision 
The Audit and Scrutiny Committee endorsed the contents of the report. 
(Reference:  Report by Chief Internal Auditor, dated 14 March 2024, submitted) 
6. INTERNAL AUDIT REPORTS TO AUDIT AND SCRUTINY COMMITTEE 2023/24 
Consideration was given to a report containing the action plans in relation to the following
three audits:- 
• Human Resources – Casual Workers
• Pupil and Public Transport
• Piers and Harbours 
Decision 
The Audit and Scrutiny Committee reviewed and endorsed the summary report and detail
within each individual report. 
(Reference: Report by Chief Internal Auditor, dated 14 March 2024, submitted) 
7. FLY-TIPPING SCRUTINY REVIEW 
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Having noted that the Fly-Tipping Scrutiny Review commenced as per the 2021/22
scrutiny plan and concluded as per the 2023/24 scrutiny plan, the Committee gave
consideration to a report which presented the draft Fly-Tipping Scrutiny Report.   
Decision 
The Audit and Scrutiny Committee:- 
1. agreed the draft Fly-Tipping Scrutiny Report; and 
2. agreed that the Fly-Tipping Scrutiny Report be presented to the Environment,
Development and Infrastructure Committee for consideration.   
(Reference:  Report by Chair of Scrutiny Panel, dated 14 March 2024, submitted) 
8. SCRUTINY - IDENITIFICATION OF A TOPIC 2024-25 
The Committee gave consideration to a report which provided an update on the recent
engagement on potential scrutiny options in order to identify a topic to take forward in the
context of the Scrutiny Manual and Framework as part of the Committee’s scrutiny role for
2024-25.   
Decision 
The Audit and Scrutiny Committee:- 
1. agreed that the topic for 2024-25 would be a review of the Council’s Complaints
process based on the responses provided to the Chief Internal Auditor as part of the
recent communications with the Committee and in accordance with the agreed process
of assessment which is detailed in the Scrutiny Framework and Manual; 
2. appointed Councillor Jim Lynch as the Panel Chair with the new Chair of the
Committee, Janice Wason Hall shadowing; and 
3. requested that the Chief Internal Auditor extend an invite to all Members of the
Committee seeking nominations for a further two members to form a Scrutiny Panel for
the review which will commence within financial year 2024-25.   
(Reference:  Report by Chief Internal Auditor, dated 14 March 2024, submitted) 
9. INTERNAL AUDIT PLAN 2024-25 
The Committee gave consideration to a report which introduced the Internal Audit Plan for
2024-25.   
Decision 
The Audit and Scrutiny Committee agreed and endorsed the Internal Audit Plan 2024/25,
as attached at Appendix 1 to the report. 
(Reference:  Report by Chief Internal Auditor, dated 14 March 2024, submitted)   
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10. REGULATION OF INVESTIGATORY POWERS (SCOTLAND) ACT 2000 (RIPSA)
ANNUAL REPORT 
Having noted the legal requirements placed on the Council in relation to covert
surveillance, the Committee gave consideration to a report which advised that between 1
January and 31 December 2023, the Council undertook no covert surveillance operations. 
Decision 
The Audit and Scrutiny Committee considered and noted the terms of the report.   
(Reference:  Report by Executive Director with responsibility for Legal and Regulatory
Support, dated 14 March 2024, submitted) 
Councillor Daniel Hampsey joined the meeting during discussions of agenda item 11
(2022-23 Audited Annual Accounts).
.
11. 2022-23 AUDITED ANNUAL ACCOUNTS 
(a) 2022-23 Draft Annual Audit Report 
The Committee gave consideration to a report and a short verbal update outlining
the unqualified opinion of the External Auditors, Mazars LLP, on the audit of the
financial statements.   
Decision 
The Audit and Scrutiny Committee agreed to note the findings of the report.   
(Reference:  Report by Mazars LLP, dated March 2024, submitted) 
(b) 2022-23 Argyll and Bute Council - ISA 580 Letter of Representation 
Consideration was given to the ISA 580 letter of representation on the audit of the
annual accounts of Argyll and Bute Council for the year ended 31 March 2023.   
Decision 
The Audit and Scrutiny Committee:- 
1. noted the contents of the ISA 580 letter of representation; and 
2. agreed to recommend to Council that the ISA 580 letter of representation be
approved for signing.   
(Reference:  ISA 580 Letter of Representation by Section 95 Officer, dated March
2024, submitted) 
(c) 2022-23 Audited Annual Accounts 
The Committee gave consideration to a report presenting the Audited Annual
Accounts of the Council for the year ended 31 March 2023.     
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The Chair took the opportunity to thank the Finance team for the provision of highly
informative management commentary and for their continued hard work in the
provision of the annual accounts. 
Decision 
The Audit and Scrutiny Committee:- 
1. noted that the audit is substantially complete and Mazars have advised the
Council that they are expecting to issue an unqualified opinion on the Council’s
Accounts for the year ended 31 March 2023; 
2. agreed to accept and endorse the set of Accounts as attached to the report and
refer them to the Council for approval; 
3. noted that if the Council receive a follow-up letter from Mazars confirming that
there are no material changes to the Accounts, there would be no impediment to
the Council signing off the Annual Accounts; 
4. noted that if the Council receive a follow-up letter from Mazars confirming there
was a material change, it would be a matter for the Council to take forward the
approval of the Accounts having regard to that.  It was further noted that in this
event, a further report would be submitted to the Audit and Scrutiny Committee
for their information; and 
5. noted that the Audit of the Charitable Trusts has still to be completed and the
Charitable Trust Accounts will be submitted to the most appropriate meeting of
the Council with a copy to the Audit and Scrutiny Committee for information.   
(Reference:  Report by Section 95 Officer, dated 7 March 2024, submitted) 
12. UNAUDITED ANNUAL ACCOUNTS 2023-24 
Consideration was given to a report which outlined the plans in place for financial year end
31 March 2023 and the preparation of the Council’s Unaudited Annual Accounts for 2023-
24.   
Decision 
The Audit and Scrutiny Committee noted that plans are in place to prepare the Council’s
Annual Accounts, consistent with the Accounting Code of Practice for submission to
Council prior to 30 June 2024. 
(Reference:  Report by Section 95 Officer, dated 21 February 2024, submitted) 
13. TREASURY MANAGEMENT STRATEGY AND ANNUAL INVESTMENT
STRATEGY 
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Consideration was given to a report which outlined the proposed Treasury Management
Strategy Statement and Annual Investment Strategy and set out the policy for the
repayment of loans fund advances for 2024-25.   
Decision 
The Audit and Scrutiny Committee:- 
1. agreed to endorse the proposed Treasury Management Strategy Statement and
Annual Investment Strategy and the indicators contained within; 
2. noted the continued use of the asset life method for the repayment of loan fund
advances using a 5.1% annuity interest rate, with the exception of spend to save
schemes where the funding/income profile method could be used; 
3. noted the proposed asset repayment periods as detailed within section 2.7 of the
Treasury Management Strategy Statement; and 
4. noted the ability to continue to use countries with a sovereign rating of AA- and above,
as recommended by the Council’s external treasury management advisors.   
(Reference:  Report by Head of Financial Services, dated 15 February 2024, submitted) 
14. CORPORATE IMPROVEMENT PLAN UPDATE 
The Committee gave consideration to a report which provided an update on the progress
of the new Corporate Improvement Plan (CIP) within the Performance Excellence Project
and highlighted completed work and upcoming activities to facilitate the development and
implementation of the new plan.   
Decision 
The Audit and Scrutiny Committee considered and noted the work undertaken to date on
the Corporate Improvement Plan and the activities planned to deliver and implement it. 
(Reference:  Report by Chief Executive, dated 12 February 2024, submitted) 
15. INTERNAL AUDIT CHARTER AND INTERNAL AUDIT MANUAL 
Consideration was given to a report which outlined the proposed changes to the Internal
Audit Charter and Internal Audit Manual. 
Decision 
The Audit and Scrutiny Committee:- 
1. approved the amended Internal Audit Charter, as attached at Appendix 1 to the report;
and 
2. approved the amended Internal Audit Manual, as attached at Appendix 2 to the report. 
(Reference:  Report by Chief Internal Auditor, dated 14 March 2024, submitted) 
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16. SCRUTINY FRAMEWORK AND MANUAL ANNUAL REVIEW 
The Committee gave consideration to a report which concluded the annual review to
determine whether any changes were required to the Council’s Scrutiny Framework and
Manual. 
Decision 
The Audit and Scrutiny Committee agreed to note the outcome of the annual review of the
Scrutiny Framework and Manual, as outlined in Appendices 1 and 2 of the report. 
(Reference:  Report by Chief Internal Auditor, dated 14 March 2024, submitted) 
17. LOCAL GOVERNMENT IN SCOTLAND - FINANCIAL BULLETIN 2022-23 
Consideration was given to a report which presented the main issues raised in the recent
Local Government Financial Bulletin 2022-23 report by the Accounts Commission and
highlighted relevant issues. 
Decision 
The Audit and Scrutiny Committee noted the contents of the Accounts Commission report. 
(Reference:  Report by Section 95 Officer, dated 20 February 2024, submitted)   
18. WORKPLAN 
In order to facilitate forward planning of reports to the Audit and Scrutiny Committee,
Members considered the outline Audit and Scrutiny workplan. 
Decision 
The Audit and Scrutiny Committee agreed to note the outline workplan.   
(Reference:  Audit and Scrutiny Workplan, dated 14 March 2024, submitted) 
On noting that this was his last meeting as Chair, Martin Caldwell took the opportunity to
thank the officers and Members of the Committee, past and present for their support and
assistance over the years.   
On behalf of the Internal Audit and Counter Fraud teams, the Chief Internal Auditor, Paul
MacAskill expressed gratitude to Mr Caldwell who in his role as Chair has steered the
Committee for over a decade.  Mr MacAskill also thanked Mr Caldwell for the support he
has provided to him in both a professional and personal capacity since he took up the
position of Chief Internal Auditor.   
Councillor Hardie, on behalf of the Committee, also took the opportunity to thank Mr
Caldwell for all his work in the role of Chair of the Audit and Scrutiny Committee over the
years, and wished him well for the future.    
.
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ARGYLL AND BUTE COUNCIL  AUDIT & SCRUTINY COMMITTEE   
FINANCIAL SERVICES  13 JUNE 2024  
INTERNAL AUDIT AND COUNTER FRAUD SUMMARY OF ACTIVITIES 
1. SUMMARY  
1.1 The objective of the report is to provide the Audit and Scrutiny Committee (the
Committee) with a summary of Internal Audit activity and progress during quarter
four of 2023/24.  
1.2 Core activities together with a progress update statement are shown below: 
• 2023/24 Audit Plan progress: The plan has now been completed and work
has commenced on the 2024/25 audit plan. 
• 2023/24 Individual Audits undertaken: six audits have been completed during
the period, 1 have been assessed as providing high assurance, 2 substantial
assurance and 2 reasonable assurance, with one to be confirmed. (Where
HSCP and LiveArgyll Audits are included, these are provided for
information only). 
• Scrutiny: Planned work for 2023/24 in relation to ‘Fly Tipping’ has been
completed following a meeting of the Scrutiny Panel in February 2024 and
reported and considered by the Audit and Scrutiny Committee in March 2024. 
• Counter Fraud: The Counter Fraud Team (CFT) is continuing to rebill council
tax accounts and recovery of funds is underway.  All other aspects and referrals
are being considered, investigated and evaluated and the Counter Fraud Team
remain vigilant to protect our public purse. The established CFT team member
is on secondment to Housing for career and personal development for a two
year period.  The CFT have obtained a member of staff, again on secondment
for the same time period. The team lead is currently progressing through year
2 of a Master in Accountancy course.   
• Continuous Monitoring Programme Testing: A number of auditable units are
subject to continuous testing. There have been no new issues which we have
identified this quarter. 
• Performance indicators: Current status is green / on track. 
2. RECOMMENDATIONS  
2.1 To review and endorse the Summary of Activities report.   
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3. DETAIL  
3.1 Six audits have been completed since the previous Committee in March 2024. 
Audits Completed 
• Freedom of Information (FOI)
• Client Funds Progress Review
• Financial Ledger 
• Scottish Social Services Council (SSSC) Registration
• Learning and Disability Care Packages
• Cloud Based Computer Services 
Audits in Planning / in Progress
reported to a future meeting of the Committee. 
• Education Maintenance Allowance
• SPT Annual Claim 
3.2 In addition to those already in progress, indicative audits planned for Q1 2024/25
are: 
• Community Education
• School Funds and Management of School Funds 
• Local Government Benchmarking Framework 
3.3 2023/24 Audit Plan 
• Work has been fully completed on the approved plan and outlined in
paragraphs 3.1.
• A request has been made by senior management to postpone the planned
review on Building Cleaning and similarly a review within the Education
service due to staff sickness and external inspections which are ongoing. We
will consider these areas in future plans and would note this as an amendment
to the current Plan for 2023/24.   
Scrutiny  
3.4 It was agreed in June 2023 that scrutiny work for 2023/24 will focus on the
outstanding review concerning ‘Fly Tipping’. Work had previously been postponed
until data became available to the Panel. Discussions have been ongoing with staff
within the Council to ensure data was made available in January for further
analysis and consideration at a meeting of the Panel to conclude on this review. In
February 2024 the Scrutiny Panel met, along with staff responsible for this area of
activity within the Council. The final report was prepared for consideration by the
Audit and Scrutiny Committee in March 2024. A subject area for scrutiny in
2024/25 was agreed by the Committee and which relates to complaints, a report
will be prepared for the September Committee to take forward this scrutiny review.  
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Counter Fraud  
3.5 The CFT is progressing well with both team members fully CIPFA accredited fraud
investigators. The current investigator has taken on a 2 year secondment to empty
homes for further skills development.  The investigators post was filled again on a
secondment basis.  The new member of staff will undertake the above CIPFA
accreditation and is booked onto this course commencing in the latter half of 2024.
Both team members will revert to substantive post circa sept 2025. 
Continued routine work is still progressing to track the full income recovered from
the team’s work, however, based on the amount of additional billing, even
accounting for a degree of non-recovery, the indications are that the team are still
exceeding their target. In addition, the team are raising awareness of the Council’s
zero tolerance to fraud and this will help act as a deterrent to fraud being
perpetrated in the first place. 
The team aimed to visit Mull, Tarbert and Lochgilphead in the next coming months
with a proactive aim to gather any new evidence due to ongoing investigations. 
A large number of referrals are having to be sent to the DAB Assessors due to the
nature of the information, and these will be followed up in due course.  There is still
a back log from Covid so there are delays. 
Helensburgh is still being reviewed and efforts are still being made to trace long
term investigations, Operational demands means this will likely continue toward the
end of 2024. 
Second homes review is beginning to play a larger role in the CFT team’s
investigations with several claims already adjusted. 
The CFT have also assisted debt recovery to trace persons and allow
communications between both parties. 
The team now have an established referral system in place from council tax teams
and the CFT have already liaised with this team going forward into 2024 for the
review of the second and holiday home tax changes.  The information already
shared in the short space of time has resulted in rebilling and adjustments of
accounts.  Together we aim to keep accurate records and update accounts where
error or missing information is held. This approach will continue as the method of
collaborative and interdepartmental working has been helpful. 
The CFT continue to work closely with the empty homes team to support each
other in our remits.  Work and communication between each department is key in
identifying and finding appropriate solutions to enable empty homes to return to
residency or open market. 
The NFI exercise continues to be a routine work area for the CFT.  Pending any
other data release from Cabinet Office, the 2022/23 exercise is coming to a close. 
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Since the inception of the CFT a total of £1,119,584 has been rebilled and
£796,759 has been recovered. A recovery percentage of 71% has been achieved
at the last review of the figures. 
Additional Updates from Quarter Four  
3.6 Staff continue to work from home or on a hybrid approach and this has proved to
be successful, where on-site visits have been required due to the specific nature of
the audit work, these have been undertaken.  
3.7 Year- end stock checks were reinstated in 2023/24, visits to yards and stores
took place across the Council area to verify stock quantities and values
presented to Financial Services for presentation in the annual accounts.  We
found that comprehensive instructions were issued to relevant employees, stock
was measured or counted at the arranged time close to year-end, items were
stored safely and securely, regular monitoring is in place to ensure adequate
supplies are available to meet demands throughout the year and year-end
values were submitted to financial services.  Testing identified some differences
in quantities and values presented to Financial Services but these were not
material.  Whilst it is difficult to measure salt for road treatment, the areas visited
employed the method of calculation inconsistently, this has been addressed by
issue of additional instructions. 
3.8 The Council has entered a ten-year programme to deliver the Rural Growth Deal
(RGD) for Argyll and Bute.  The Council, as the accountable body for this
programme is required to allocate and account for distribution of the funding to
partners, third parties and other bodies in accordance with the approved
governance arrangements.  The Council’s Chief Internal Auditor has been
appointed to coordinate audit activity throughout the programme, this will include
liaison with partner auditors to obtain annual confirmation of regular and planned
reviews of grant funded activities and a specific review of RGD within the
Council’s Annual Audit Plan at least every two years.  Discussions regarding the
audit input required have taken place and the first review will be included within
the 2025/26 Internal Audit Plan. 
3.9 As part of our work for the HSCP, audit plans for 2024/25 and indicative plans
covering 2025/26 and 2026/27 have also been prepared for presentation to the
Audit and Risk Committee of the HSCP. We have again, consulted with senior
managers of the HSCP in the preparation of this plan and have been approved so
these will be in place before the start of the new financial year. Work for 2023/24
has been fully completed.  
3.10 Internal Audit have been liaising with our colleagues in IT where we have been
closely monitoring the cyber incident at Comhairle nan Eilean Siar (Western Isles
Council) in order to glean any areas for learning or consideration. This incident has
had a significant effect on the Western Isles Council including, as reported,
unavailability to access their ‘back-up’ data. It also highlights the threats and
potential effects such incidents can have on public bodies and will continue to
monitor this incident for any learning and/or risk mitigation purposes.   
Continuous Monitoring  
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Our continuous monitoring programme is generally focused on transactional type
activity. Standard audit tests are applied which are relevant to each auditable unit.
Control design tests look at whether the controls in place adequately address the
potential risk event. There has been no new findings within the quarter that require
to be reported. 
Table 2: Continuous Monitoring Findings 
Auditable
Area
Areas Tested Issues Identified Management comment /
action  
No issues identified. 
3.11 A follow up process is in place whereby management are advised of continuous
monitoring findings and, where appropriate, requested to take remedial action. 
There are currently no outstanding follow-up points arising from previous testing. 
Due to the volume of continuous monitoring tests carried out the decision was
made to report by exception only.      
National Reports  
3.12 A follow up process for national reports is in place whereby management are
advised of national reports published and asked to confirm what, if any, action is
planned as a result of the report.  Table 2 details the national reports issued during
quarter four of 2023/24 and quarter one of 2024/25 due to be reported in quarter
one 2024/25.  
Table 3: National Reports 
National
Report
Issued
To
Detail Management response/ Action
taken
None   
National Fraud Initiative (NFI)  
3.13 NFI data matching involves comparing computer records held by one body against
other computer records held by the same or another body to identify potentially
fraudulent claims and payments to be identified.  Note though that the inclusion of
personal data within a data matching exercise does not mean that any specific
individual is under suspicion. Where a match is found it indicates that there may be
an inconsistency which requires further investigation. No assumption can be made
as to whether there is fraud, error or other explanation until an investigation is
carried out.  A reminder process is in place to ensure that matches are reviewed
on a timely basis.  NFI have provided new data throughout 2023/24 and these
have been matched and closed.
This exercise is now coming to a close.  
3.14 The current NFI exercise has been released after some technical delays from the
Cabinet Office.  This exercise is conducted throughout the year by officers and
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matches checked and closed accordingly.  NFI provided additional data releases
over the course of the exercise and matches are addressed when these become
available.  The current NFI matches are detailed below. The CFT are reviewing the
information received from the NFI matching service, work has commenced to
follow these up locally.  Existing users have been reviewed and new users added
where requested, all users have been informed that matches are available for
review and progress will be monitored monthly by the Counter Fraud team and
reported quarterly to the Audit and Scrutiny Committee.
New HMRC data has been uploaded and released back to us, and teams have
been contacted to start matching this data.   
Table 4: National Fraud Initiative Progress at 19/05/2024
Operational
Area
Total
Matches
Recommended/Very
High / High/Medium
Risk Matches
Matches
Complete 
*
WIP
Match Description
CT to Elect
Register 
2155 0 2155 0 CT records to Electoral
Register/ other data sets to
ensure discount awarded to
only those living alone
aged over 18, taking into
account disregarded
occupants.  (CT to other
Datasets will not be
progressed further due to
poor quality data)
CT rising
18s 
402 0 402 0
CT to HMRC
Household
Composition
935 0 38 2
Housing
Benefits
21  11 20  0 HB records to records in
other authorities / other
datasets including student
loans, payroll and pensions
to identify undeclared
income and capital.
Payroll 143 2 139 1 Payroll records to other
datasets including other
payrolls and pensions to
ensure employee is not
receiving additional
income.
Blue Badges 238 204 237 0 Blue badge records to
DWP data to identify
deceased claimant with
valid badge.
Housing
Waiting list
233 214 231 2 Housing waiting list
records to other
organisations HBCTR and
tenant data to identify
undisclosed changes in
circs or false info.
Council Tax
Reduction
307 157 278 0 CTR records with records
in other authorities / other
datasets including; student
loans, payroll and pensions
to identify undeclared
income and capital
Creditors 589 0 33 0 Analyses Creditors data to
identify possible duplicate
vendors and payments,
VAT errors or fraud and
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multiple vendors sharing a
bank account.
Procurement 38 0 38 0 Payroll records to
Companies House and
creditors’ data to identify
employees who appear to
have a personal interest in
a company that the
authority has traded with.
Business
Rates
214 0 135 0 Business rates records
within and between
authorities to identify those
fraudulently claiming small
business bonus scheme
and grants 
* Work in Progress 
Overall Summary of Matches 
Matches
Complete
Work In
Progress
Cleared Frauds Errors Total
Value 
£
Recovering Recovering
Value 
£ 
3706  5 3613 0 93 60,450 0 0 
Internal Audit Development  
3.15 The table below details progress against the action points in our Internal Audit
development plan.  
Table 5: Internal Audit Development Key Actions: updated 31/03/24. 
Area For
Improvement
Agreed Action Progress
Update
Timescale
Review Continuous
Monitoring
Programme
Continuous monitoring tests will be
reviewed following audit of Debt
recovery to assess value of existing
tests carried out. 
Consider adding test to review date
taken to process invoices from date of
receipt within the Council (not at
Creditors)
In progress October
2024
Update internal audit
report template to
include key audit
milestones.
A table will be added to the internal
audit report template to provide
readers with the planned and actual
reporting dates, this will allow better
monitoring of any delays in responses
which has been requested by DMT.
Completed and
will be used for
internal audit
reports issued
2024-25
onwards
June 2024 
3.16 Internal Audit scorecard data provided below are aligned to those for internal audit
in the Financial Services service plan.  All indicators are shown as currently being
on track.   
Table 6: Internal Audit Team Scorecard
Page 17

Page 18

Internal Audit Team Scorecard 2023– 24 – FQ4 23/24 (as at March 2024)
BO115 We Are Efficient and Cost Effective    
Internal Audit Level of Satisfaction
Actual  93% G 
Target 80%
Review of Strategic Risk register
Status Complete G 
Target Complete
Percentage of audit plan completed
Status 100% G 
Target 100%
Percentage of audit recommendations accepted by
management
Actual  100%
G
Target 100% 
4 CONCLUSION  
4.1 The 2023/24 audit plan is complete, the 2024/25 audit plan has commenced and
the Counter Fraud Team is continuing with visits and pro-active work throughout
Argyll and Bute.  
5 IMPLICATIONS
5.1 Policy – Internal Audit continues to adopt a risk based approach to activity
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 – None
5.8 Customer Service – None
5.9 The Rights of the Child (UNCRC) – None 
For further information please contact Internal Audit (01546 604108)
Paul Macaskill
Chief Internal Auditor
13 June 2024
Page 18

Page 19

ARGYLL AND BUTE COUNCIL  AUDIT AND SCRUTINY COMMITTEE                                                            
FINANCIAL SERVICES  13 June 2024 
INTERNAL AND EXTERNAL AUDIT REPORT FOLLOW UP 2023-24 
1.0 INTRODUCTION 
1.1 Internal and external audit reports include an action plan with a
management response establishing the agreed action, timescale and
responsible officer. Internal Audit record these in a database and, on a
monthly basis, follow them up to ensure they are being progressed. 
1.2 This report updates the committee on all open actions as at 31 March
2024 including information on actions where the agreed implementation
date has been rescheduled.   
2.0 RECOMMENDATIONS 
2.1 To endorse the contents of the report. 
3.0 DETAIL 
3.1 The two tables below provide a numerical summary of open audit actions
with a split between actions due by and due after 31 March 2024. 
3.2 Appendix 1 provides further detail on actions that have either been delayed
and rescheduled or superseded. 
Page 19 Agenda Item 5

Page 20

Table 1 - Actions Due by 31 March 2024 
SMT/Service
Complete
Delayed/
Rescheduled
Superseded
Evidence
Required
Total
Internal Audit
DH – Commercial Services 3 4 0 0 7
DH – Education Performance & Improvement 1 0 0 0 1
DH – Legal & Regulatory Support 1 0 0 0 1
KF – Customer Support Services 4 0 0 0 4
KF – Development & Economic Growth 0 4 0 0 4
KF – Financial Services 6 7 1 0 14
KF – Roads & Infrastructure Services 1 2 0 0 3
H&SCP (IJB) – Finance & Transformation 0 2 0 0 2
H&SCP (SW) – Adult Services (Mental Health Learning
Disability, Addictions & Lifelong Conditions)
0 2 0 0 2
External Audit
Nil     
TOTAL 16 21 1 0 38 
Table 2 - Actions due after 31 March 2024 
SMT/Service
Complete
Delayed/
Rescheduled
No Response
On Course
Evidence
Required
Total
Internal Audit
DH – Commercial Services 0 0 0 4 0 4
DH – Education Performance & Improvement 0 0 0 1 0 1
KF – Customer Support Services 1 1 0 1 0 3
KF – Development & Economic Growth 0 0 0 3 0 3
KF – Financial Services 0 4 0 0 0 4
KF – Roads & Infrastructure Services 1 0 0 16 0 17
H&SCP (IJB) – Finance & Transformation 0 0 0 2 0 2
H&SCP (IJB) – Strategic Planning & Performance 0 0 0 2 0 2
H&SCP (SW) – Adult Services (Mental Health Learning
Disability, Addictions & Lifelong Conditions)
2 0 0 0 0 2
External Audit
Nil      
TOTAL 4 5 0 29 0 38 
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Page 21

4.0 CONCLUSION 
4.1 Satisfactory progress continues to be made implementing audit actions. 
5.0 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 – None
5.8 Customer Service – None
5.9 The Rights of the Child (UNCRC) – None 
Paul MacAskill
Chief Internal Auditor
13 June 2024                                                  
For further information contact: Paul MacAskill, 01546 604108
Paul.macaskill@argyll-bute.gov.uk 
APPENDICES
Appendix 1 – Action Plan Points Delayed & Rescheduled and Superseded
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Appendix 1 - Action Plan Points Delayed & Rescheduled or with Superseded 
Action Plan Points Due by 31 March 2024 
LOW
COMMERCIAL SERVICES 
Compliance Review (Period Products) 
5. Monitoring of onsite provision 
The process for auditing of sites to ensure
products remain available in an equitable way
has still be developed. There are no
records/evidence to support that checks are
carried out to ensure  that products, adequate
storage and disposal facilities and branding  are
actually on site and available in one or more of,
unisex, male, females and disabled toilets in
Council establishments. 
Monitoring process will be
implemented with an
implementation date of March
2024. 
31/03/2024
30 Sep 2024 
Location survey was carried out
- any locations that identified as
low/no stock were sent stock.
Locations that required
branding packs were sent packs.
Link to location survey form -
My Tribe Period Product
Location Survey (jotform.com)
This is an annual process. 
Delayed and Rescheduled 
Project Lead – Period 
Products 
Medium
COMMERCIAL SERVICES 
Compliance Review (Period Products) 
6. Procedure Notes 
The Project Lead post is a temporary post, until
December 2023, and with the exception of a
draft stock ordering note, there are no
procedure notes. As a priority procedure notes
should be written for all key tasks, include
detailing what the monitoring, evaluation are
reporting requirements. 
Ongoing – implemented by January
2024 
31/01/2024
30 Sep 2024 
Due to changes within the
management team, the current
process are being reviewed.
The new post of Business
Support Officer will continue to
have responsibility for the
provision of free period
products within Argyll and Bute
with Admin team support for
processing orders. 
Delayed and Rescheduled 
Project Lead – Period 
Products 
Low
COMMERCIAL SERVICES 
Compliance Review (Period Products) 
7. Engagement 
Given this is new statutory requirement there
would be benefit to engaging internally with
Engagement is ongoing, informally
but will be formalised as part of the
new monitoring process as per
point 5. 
31/03/2024
30 Sep 2024 
Engagement with partners
carried out as per point 5. Public
consultation carried out 2023.
No evidence of internal
engagement. 
Delayed and Rescheduled
Project Lead – Period 
Products 
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Page 23

other services and staff involved in the various
processes to establish any issues arising and
ensure procedures are efficient. 
Medium
COMMERCIAL SERVICES 
Compliance Review (Period Products) 
8. Monitoring and evaluation  
Limited evidence of monitoring and evaluation
arrangements was provided during this review.
Management should undertake a review of the
monitoring and evaluation processes to ensure
that they are in line with the Scottish
Government Evaluation Strategy. 
Annex D on SGES – Procedure
notes will be considered to cover
how to gather data as per
document. 
31/03/2024
30 Sep 2024 
Review of Annex D carried out
in relation to types of questions
to ask:
Q1: How much does delivering
access to free period products
cost? - reviewed as part of the
bid-in fund application.
Q2: What level of demand is
there for period products? -
Reviewed within bid-in fund
application.
Q3: How is access to free period
products being provided by
local authorities and education
providers? - reviewed as part of
ongoing management and via
the guidance notes of the act.
Q4: Does delivery of access to
free period products meet user
needs? - Reviewed as part of
the 2023 consultation.
Q5: What impact did the
availability of free period
products have on users? –
option to add
comments/feedback as part of
ordering process. 
Delayed and Rescheduled 
Project Lead – Period 
Products 
Low
DEVELOPMENT & ECONOMIC GROWTH
PLANNING 
3. Customer Charter 
The framework document for
2022/23 stated “A review and
update of the Development
Management Customer Service
31/12/2023
31/03/2024
30 Jun 2024 
Delayed due to other
operational pressures on staff
time during FQ4 2023/24 - in
particular the replacement of
Development Manager 
Page 23

Page 24

Planning have in place a customer charter,
however it was last reviewed in 2012 and
requires to be updated as it does not reflect
current practice. 
Charter will also be undertaken
during 2023/24.” 
LDP with LDP2 in Feb 2024.
Delayed until end of FQ1 24/25. 
Delayed and Rescheduled 
Low
DEVELOPMENT & ECONOMIC GROWTH
PLANNING 
4. Service level Customer User Forums
Customer User Forums have previously been
held regularly however currently customer
forums are not being undertaken. 
The Planning Performance
Framework for 2022/23 states that
“it is intended to reinitiate Service
level Customer User Forums during
2023/24”. 
31/12/2023
31/03/2024
30 Jun 2024 
Delayed due to pressures from
operational commitments, in
particular the replacement of
LDP with LDP2 during Feb 2024.
Customer engagement has
however been undertaken
during March 2024 to establish
customer appetite for a User
Forum and to ascertain what
format this will be provided in
(online/hybrid/in person) and
the content of the forum. It is
expected that the forum will be
held during FQ1 24/25. 
Delayed and Rescheduled 
Development Manager 
Low
DEVELOPMENT & ECONOMIC GROWTH 
Private Sector Housing Grants & Adaptions
2. The Scheme of Assistance 
The Councils Scheme of Assistance (SoA) which
was introduced under the duties and powers set
out in the Housing (Scotland) Act 2006, and sets
out the strategy of support for owners to
address properties which are Below Tolerable
Standard (BTS) and in disrepair does not contain
up to date information and should be updated
after the outcome of the national policy review. 
As per Local Housing Strategy
2022-2027 Action Plan; The
Scheme of Assistance, will be
revised in 2023, after the outcome
of national policy review on
adaptions. 
31/12/2022
30/06/2023
31/03/2024
30 Sep 2024 
Over the last 3 months work has
continued with updating the
Scheme of Assistance. The
Housing Team have taken the
opportunity to benchmark with
other Scottish Local Authorities
and have also worked closely
with the HSCP to ensure that all
current legislation has been
addressed within the revised
document. 
The revised Scheme of
Assistance is now at final draft
stage and is currently
undergoing scrutiny by the
Housing Team and relevant
Team Lead - Housing 
operations 
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Page 25

HSCP partners prior to
progressing to committee cycle
for approval. I have updated the
revised completion date to
30/09/24 to allow time for the
Scheme of Assistance to
complete the approval cycle.   
Delayed and Rescheduled 
Low
DEVELOPMENT & ECONOMIC GROWTH 
Private Sector Housing Grants & Adaptions 
3. Procedure Notes and Shared Documents
While the vast majority of requirements are
included  there would be benefit to updating
these to reflect current  working practices,
which have evolved due to hybrid  working
arrangements and the digitalisation of records. 
Consideration should be given to creating a
checklist to ensure consistent application of
processes. 
Procedures and documents will be
reviewed and updated. Checklists
to be drawn up and introduced
when updating the procedures. 
31/12/2022
30/06/2023
31/03/2024
30 Sep 2024 
Housing Officers, HSCP and Care
and Repair have progressed on
updating policies and
procedures. The HSCP are in the
final stages of updating their
Criteria and Practice Guide and
the Housing Service is currently
updating the Scheme of
Assistance. In addition, the
Housing Service has taken the
opportunity to revise all internal
admin procedures relating to
Private Sector Housing Grants. A
meeting has been scheduled for
30th May 2024 to allow relevant
Housing, HSCP and Care and
Repair staff to meet and go
through the procedure
documents. As this action links
to the action relating to the
Scheme of Assistance review
this has also been updated to
September 2024. 
Delayed and Rescheduled
Team Lead – Housing
Operations
Medium FINANCIAL SERVICES 
CAPITAL MONITORING
Capital Planning and Management
Guide to be updated once the
Capital Strategy has been approved
31/03/2022
30/09/2022
The Guide has been updated
but requires consultation with
the Head of Commercial
Head of Commercial
Services/Finance
Manager
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Page 26

1. Capital Programme Planning & Management
Guide 
The Council’s Capital Guide has not been revised
since 2018 and requires a review to ensure it
reflects current working practices and provides
appropriate support to officers involved in the
capital monitoring process. The Council is
currently developing a new Capital Strategy
which is to be presented to the Policy and
Resources Committee in August 2021 and we
recognise that a review of the Guide should be
conducted after the Strategy has been finalised
to ensure the two documents complement each
other and. The Guide could also benefit from
being linked to, or referencing, other relevant
Council processes, in particular the Project
Management section on the Hub. 
to ensure the two are aligned and
provide clarity. 
31/12/2022
31/03/2023
30/09/2023
31/12/2023
31/03/2024
31 Mar 2025 
Services as it has a lot of
duplication with the new Capital
Investment Strategy and it may
be possible to streamline this
guide. 
A significant update is required
to the guide from not only
finance but other services of the
council with heavy involvement
from the Capital Investment
Board. With changes imminent
on the capital plan with new
groupings and a review of the
block allocations in the pipeline
this document will evolve over
the coming months. 
Delayed and Rescheduled 
Medium
FINANCIAL SERVICES 
MANAGEMENT OF DEBT/DEBT RECOVERY 
5. Debtors Procedure Manual and Processes
Finding:  There is insufficient evidence to
determine whether all Services receive details
of invoices being written off.  
Recommendation:  Services should be sent this
information. 
A thorough review of Sundry Debt
write-off procedure to be carried
out by the working group as part of
the overall update of the Sundry
Debt Procedures.  Reporting and
communication with stakeholders
is being reviewed by the working
group. It is anticipated that reports
of debt written off will be sent to
departments as part of a standard
suite of reporting for discussions at
quarterly meetings this will be
confirmed within the reviewed
Sundry Debt Procedure Manual. 
31/12/2023
31/03/2024
30 Sep 2024 
Departments get a list of debts
to be written off and are asked
for approval. A copy of the Q4
list 23/24 is attached and the
column on the right hand side
shows that the details are
shared. Where a debt has
prescribed as it hasn't been
collected for 5 years, we can no
longer legally pursue the
amount, departments are not
asked to approve write-off in
these circumstances because
the Council has no other option.
More evidence of the exchange
between legal services and
departments re the write-off list
can be supplied if required.
Quarter 4 is not complete as
Revenues and  Benefits
Manager 
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Page 27

yet, write off process still to be
completed. Departmental load
unforeseen. 
Delayed and Rescheduled 
Medium
FINANCIAL SERVICES 
MANAGEMENT OF DEBT/DEBT RECOVERY 
6. Debtors Procedure Manual and Processes
Finding: While there is a pdf version of the
authorisation and the spreadsheets containing
the individual invoices, there are concerns that
different sources of data are used during the
write off process as there is more than one
version of the write off spreadsheet.  
Recommendation:  Checks should be carried out
to ensure that Original Data is retained with
records kept of any alteration to the Source
Data. 
There must only be one version of
the write-off spreadsheet. This can
be shared between Finance and
Legal Services on MS Teams. 
Changes can be made to the
document by Legal or Finance
before it is presented to senior
management for final
consideration. 
31/12/2023
31/03/2024
30 Sep 2024 
We have been provided with
the only version of the write-off
spreadsheet. Once the
Executive Director has written
off the debt the spreadsheet
will be passed to Finance so that
the write-off can be keyed to
the Debtors system and the
departments will also get the
full list of debt written off.  Ok
to delay as per comments in
action number 5 above. 
Delayed and Rescheduled 
Revenues and  Benefits
Manager 
Medium
FINANCIAL SERVICES 
MANAGEMENT OF DEBT/DEBT RECOVERY 
11. Performance Monitoring and Reporting
Findings:  There are no performance measures
in place to monitor recovery of Sundry debt.
Quarterly meetings with Legal Services to
discuss recovery of Sundry Debtors were
postponed during the pandemic, these have not
been reinstated.  
Management information relating to Sundry
Debtors is not made widely available.  
Aged debtors reports are only sent to Services
who ask. 
Performance monitoring and
reporting will be a key part of the
Sundry Debt review undertaken by
the working group led by the Head
of Legal Services.  It is anticipated
that proposals for quarterly
meetings and the reporting suite
will be developed and
implemented by March 2024. 
31/10/2023
31/03/2024
30 Sep 2024 
Policy paper going to P&R
includes an appendix on role of
the Debt Champions covering
their duties and including
details of a data dashboard that
they will be receiving quarterly.
Once approved meetings will be
held quarterly from July 2024.
Delayed P&R and unforeseen
workload. 
Delayed and Rescheduled 
Revenues and  Benefits
Manager 
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Reporting is only to the Financial Services
Management Team via Highlight Reports. 
Recommendations:  Appropriate performance
measures should be put in place to monitor
recovery of Sundry Debt.  The meetings with
Legal Services should be re-instated and
consideration given to which committees and
meetings should receive reports regarding the
management and recovery of Sundry Debtors. 
Medium
FINANCIAL SERVICES 
MANAGEMENT OF DEBT/DEBT RECOVERY 
18. Debtors Procedure Manual and Processes
Finding: Management information, detailing
outstanding invoices, should be provided on a
monthly basis to a Single Point of Contact in
each Service. This is not happening, currently
only those Services who request the
information are being sent the reports. 
Recommendation:  Reports should be provided
to all Services. 
This working group review of
Sundry Debt will include the key
issue of reporting, this aspect of
the process will be vastly improved
in the future.  A suite of reports will
be developed, the identification
departmental debt champions
reinstated and quarterly meetings
setup for all relevant stakeholders. 
31/12/2023
31/07/2024
30 Sep 2024 
On course for completion, new
policy and procedures to be
considered by P&R in May, new
Debt Champions and meetings
in place for June/July.
Delayed due to revised P&R
dated and unforeseen
workload. 
Delayed and Rescheduled 
Revenues and  Benefits
Manager 
Medium
FINANCIAL SERVICES 
MANAGEMENT OF DEBT/DEBT RECOVERY 
20. Debtors Procedure Manual and Processes
Finding: Insufficient evidence to conclude
whether supporting back up evidence of
invoices being written off is retained, leading to
concerns that full records may not be retained. 
Recommendation:  
Checks should be carried out to ensure that
appropriate back up is retained. 
Back up evidence re write-off
should be retained, the write-off
lists and any backup
documentation held together in
MS Teams group for example. This
could be further enhanced if we
can use EDMS for storage of the
information. If we can move this
onto Civica’s Electronic Document
Management System (EDMS)
Comino this will make collation of
information, document retention
and disposal so much easier and
more efficient. Discuss with Civica,
30/09/2023
30/10/2023
30/06/2024
30 Sep 2024 
Checks have been carried out
relating to items being
proposed for write-off for
2023/2024. An area of Civica
W3 has been identified and will
be used as an area to store
write-off and backup from
2024/2025 onwards in line with
our stated retention dates in
our Information Asset Register. 
Delayed until system updated
by developer. 
Delayed and Rescheduled
Revenues and  Benefits
Manager 
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Page 29

re the use of the Electronic
Document Management System
for these purposes and overall case
management. Improve the file
structure within the network with
the supporting documentation. 
Expected timescales for progress -
Civica EDMS System Admin
Discussion with Supplier by May
2023 - NDR and Income Manager
to review the file structure on the
network - Revenues and Benefits
Manager Evaluation of options by
July 2023 then NDR and Income
Manager to review the file
structure on the network. Revs and
Bens Manager Development and
Implementation of Solution March
2024 
Medium
FINANCIAL SERVICES 
MANAGEMENT OF DEBT/DEBT RECOVERY 
21. Performance Monitoring and Reporting
Invoices are raised using Civica Debtors system
which does not interface with the Iken System
used by Legal Services. 
The process for the raising of and
the recovery Commercial Waste
debt and Residential Care debt will
be considered as part of the
Review of Sundry Debt.  There was
efforts made previously by staff in
D&I and Finance to integrate
Commercial Waste onto the Sundry
Debt system but it failed. 
30/06/2023
31/12/2023
31/03/2024
30 Sep 2024 
No interface can be developed
between Civica Debtors and
IKen. We have decided to create
a space in Civica W3 (Comino)
which will hold all of the
relevant information. Work has
commenced on this and should
be complete in June 2024. 
Delayed until system updated
by developer. 
Delayed and Rescheduled 
Head of Legal &
Regulatory Services. 
Medium
FINANCIAL SERVICES 
Payroll Processes 
3. Processes 
Using the above process flow 
completed for action 1, conduct a 
value chain analysis exercise to 
identify points of duplication and 
any other inefficiencies in the 
31/12/2023
31 Jul 2024 
This action has now been
superseded by the planned
move from ResourceLink to the
new iTrent HR and Payroll
System. The project team is
Payroll & Pension
Officer and Team
Leader - HR Service
Centre 
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Page 30

Whilst there are well understood processes and
procedures in place for the management of
payroll updates, the whole process is hugely
inefficient. A new HR and payroll system is
planned for the future to replace the existing
systems. 
current process. Redesign the
process to remove the
inefficiencies identified to optimise
the use of staff and speed the
process up. 
working on the processes for
the new system which will
incorporate workflow
functionality which was not
previously available in
ResourceLink. No further work
will be undertaken to review
the ResourceLink processes as
the system is planned to be
decommissioned over the next
4 months. A review would be
recommended when the new
system is set up. 
Superseded 
VFM
ROADS & INFRASTRUCTURE SERVICES 
External Hire 
3. External hires exceeding their expected
return date  
Of the 124 current ongoing hires 101 of these
have exceeded their expected return. In
addition 29 items were over the return date by
more than 1000 days. There is no document
available that explains the reasons why these
items have substantially exceeded their
expected return date. 
Roads and infrastructure services
are currently under a review of all
services and the recommendation
will be assessed as part of the
review. 
30/06/2023
31/12/2023
31/03/2024
31 Aug 2024 
The service will put in place an
action plan with the fleet
manager to reduce the hires
exceeding 24 months. A
reporting dashboard will be
developed with triggers to
remind the service to review
the list of ongoing hires and
advise of any items that should
be taken off hire and
information will be provided to
explain the reasons for any
external hires that are
substantially over their return
date. Given the nature of
Operations works, there will
always be a requirement for
external hires to ensure the
delivery of works programmes
such as the roads
reconstruction programme.
Operations Manager,
Roads and
Infrastructure Services 
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Delayed and Rescheduled 
VFM
ROADS & INFRASTRUCTURE SERVICES 
External Hire 
4. Evaluating whether long term hires should
be leased or purchased outright  
There is currently no mechanism that triggers
an exercise where “finance” considers whether
cheaper long term finance options are available
such as an operating lease or for the Council  to
purchase an item outright 
Roads and infrastructure services
are currently under a review of all
services and the recommendation
will be assessed as part of the
review. 
31/03/2024
31 Dec 2024 
This issue should be picked up
as part of the RIS review which
is currently being undertaken
and more time is required for
this action. 
Delayed and Rescheduled
Principal Accountant,
Roads and
Infrastructure Services 
High
ADULT SERVICES (MENTAL HEALTH LEARNING
DISABILITY, ADDICTIONS & LIFELONG
CONDITIONS/CSWO) 
Client Funds 
4. Safe 
Detail Restricted 
Detail Restricted  31/03/2023
30/06/2023
31/08/2023
31/10/2023
31/03/2024
30 Jun 2024 
Delayed and Rescheduled SW Admin Manager 
High
ADULT SERVICES (MENTAL HEALTH LEARNING
DISABILITY, ADDICTIONS & LIFELONG
CONDITIONS/CSWO) 
Client Funds 
6. Unaccounted Funds
Detail Restricted. 
Detail Restricted  30/06/2023
31/08/2023
31/12/2023
31/03/2024
30 Sep 2024 
Delayed and Rescheduled SW Admin Manager 
High
FINANCE/TRANSFORMATION 
Customer Service Centre - H&SCP
Provided by key officer HSCP
management will work with the
CET team to determine the best
way to approach the current
problem and implement the
30/06/2023
30/09/2023
31/03/2024
30 Jun 2024 
In progress updated external
sites and trialling approach with
a Dunoon based integrated
team to act as champions based
on excellent communication
Business Improvement 
Manager 
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1. Failure to ensure CET have up to date Service
information 
There is concern that some teams within HSPC
are not fully engaging with CSC, despite
repeated requests from Senior Managers to
review their information. In addition, the Duty
rotas and contact details on the HSPC
SharePoint are not always up to date. HSCP
must engage with CET to review the online and
offline information available to agents and
customers to ensure it is accurate, up to date
and reflects current team structures and duty
rotas. 
correct solution agreeable by HSCP
and CSC. 
between integrated teams.
Monitoring ongoing time
commitment due to regulated
responsibilities of responsible
officers to ensure we can
prescribe a reasonable time
period for input. 
Delayed and Rescheduled 
VFM
FINANCE/TRANSFORMATION 
Customer Service Centre - H&SCP 
6. Routing of calls to the appropriate channels
Calls for HSPC represent the highest volume of
both calls handled by CSC and transferred to the
Service. The data provided detailing the teams
the calls are transferred to indicates that it may
be more appropriate for properly trained staff
to handle and manage these calls. Contact
Centre and HSCP should analyse whether it is
more efficient to route certain call types on the
HSCP Golden Number directly to HSCP for them
to manage or that specific issues which require
more specialist or detailed knowledge are dealt
directly by HSCP. 
Provided by key officer The service
will engage in discussions with
CET’s Customer Engagement
Manager to ensure that suitable
arrangements are in place which
maximises efficiency and
effectiveness of the handling of
customer contacts and enquiries
via the HSCP Golden Number. 
30/06/2023
30/09/2023
31/03/2024
30 Jun 2024 
In progress updated external
sites and trialling approach with
a Dunoon based integrated
team to act as champions based
on excellent communication
between integrated teams.
Monitoring ongoing time
commitment due to regulated
responsibilities of responsible
officers to ensure we can
prescribe a reasonable time
period for input. Note this is an
ongoing working relationship. 
Delayed and Rescheduled 
Business Improvement 
Manager 
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Action Plan Points Due after 31 March 2024 
Service, Report, Plan no. & Finding Agreed Action Dates Comment Responsible
Officer
Medium
CUSTOMER SUPPORT SERVICES 
Equality and Socio-Economic Impact Assessment 
1. EqSEIA  
EqSEIAs are being undertaken, however, there are
inconsistencies in practice across the Council. A
review of papers submitted to committee and
papers as part of the budget setting process
indicate that a number of EqSEIAs had been
missed. It was noted that other Councils provide
online EqSEIA toolkits for managers to assist them
with the process of completing these. 
Present options for online
EqSEIA toolkit to ELT. 
30/06/2023
31/12/2023
31/03/2024
28 Jun 2024 
This is being worked on and a
proposal for the approach will be
completed by June 2024. 
Delayed and Rescheduled 
Head of Customer
Support  Services 
Medium
FINANCIAL SERVICES 
MANAGEMENT OF DEBT/DEBT RECOVERY 
1. Corporate Debt Policy  
The Document has not been updated since 2017
and does not reflect the current Council
Organisational Structure nor current working
practices. 
The Revenues and Benefits
Manager will review the
Corporate Debt Recovery Policy
and submit it to a working
group led by the Head of Legal
Services reviewing the Sundry
Debt process for consultation.
The final document will
proceed to October P&R via the
Head of Financial Services and
Executive Director Kirsty
Flanagan’s DMT. 
31/12/2023
31/05/2024
30 Sep 2024 
Document considered by Kirsty
Flanagan's DMT Monday 8 April,
now on way to SMT in advance
of P&R in May. This will now go
to August P&R. 
Delayed and Rescheduled 
Revenues and 
Benefits Manager 
Medium
FINANCIAL SERVICES 
MANAGEMENT OF DEBT/DEBT RECOVERY 
2. Debtors Procedure Manual and Processes
Finding:  The Debtors Procedure Manual has not
been reviewed since 2017 and does not reflect the
current Council Organisational Structure or current
working practices.  
A working group (“the working
group”), led by the Head of
Legal and Regulatory Services,
will review the Sundry Debt
Procedure Manual, processes
and procedures relating to the
management and recovery of
Sundry debt.  This document
will progress through the
31/12/2023,
31/05/2024
30 Sep 2024 
Procedures will be included in
P&R report for May 2024, should
be developed in full by end of
April 2024.  As per action 1, this
will now go to P&R in August. 
Delayed and Rescheduled 
Revenues and 
Benefits Manager 
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Service, Report, Plan no. & Finding Agreed Action Dates Comment Responsible
Officer
Recommendation:  A full review of the processes
and procedures for Sundry Debtors  relating to the
management, arrears, follow-ups and bad debt
write offs should be carried out., then the Debtors
Procedure Manual  should be updated.   
Finding: Management information, detailing
outstanding invoices, should be provided on a
monthly basis to a Single Point of Contact in each
Service. This is not happening, currently only those
Services who request the information are being
sent the reports.  
Recommendation:  Reports should be provided to
all Services.
Council’s DMT to SMT/ELT in a
similar timescale to the
Corporate Debt Recovery Policy
going to P&R (see action 1
above). 
Medium
FINANCIAL SERVICES 
MANAGEMENT OF DEBT/DEBT RECOVERY 
7. Debtors Procedure Manual and Processes
Finding: The Debtors Procedure Manual does not
mention that the keying of  the Sundry Debtors
Write Offs has two separate stages - first is the 
creating and approving of invoices as written off on
the Debtors  system and second is the manual
journals to be processed to  account for the VAT
element of the invoices written off. The journal
processed in February did not contain all of the
invoices that had been written off. This caused a
difference in the debtors’ element of the VAT
return. While this was a small value it raises
concerns as to whether there is appropriate
monitoring and oversight of the balancing of the
write off, back to the authorised invoices and
values.  
Recommendation:  Checks should be carried to
ensure that there is appropriate monitoring and
This can be added to the
revision of the procedure
manual which will be finalised
in December 2023. NDR and
Income Manager will ensure
the write-offs in the Debtors
system are fully reconciled with
the general ledger position
each quarter. 
31/12/2023
31/05/2024
30 Sep 2024 
Going to P&R in August 2024. 
Delayed and Rescheduled
Revenues and 
Benefits Manager  Page 34

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Service, Report, Plan no. & Finding Agreed Action Dates Comment Responsible
Officer
oversight of the balancing of the write off, back to
the authorised invoices and values.  The Debtors
Procedure Manual should be updated to reflect all
stages of the write off. 
Medium
FINANCIAL SERVICES 
MANAGEMENT OF DEBT/DEBT RECOVERY 
8. Raising of invoices and Recovery Routes  
Finding: Invoice inappropriately raised for the
drawdown of grant monies.  Legal Services confirm
this is not a one off.  
Recommendation:  Services should be reminded
that Debtors invoices should not be raised for the
drawdown of grant monies nor to recover income. 
These examples should be
collated and used to support
some internal training that will
be delivered to launch the new
Sundry Debt Procedure
Manual. Training will be
delivered by Finance and Legal
Services to all users of the
Sundry Debt System.
Consideration will be given to
the format of the training,
mandatory e-training for all
current users and new users or
something delivered via MS
Teams. Training to be delivered
to all users by June 2024. 
31/12/2023
31/05/2024
30 Sep 2024 
E-mail issued on 15 April 2024
Email linked to action number
18. New shared storage still to
be developed by supplier. 
Delayed and Rescheduled 
Revenue and Benefits
Manager/Legal
Manager 
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ARGYLL AND BUTE COUNCIL  AUDIT AND SCRUTINY COMMITTEE
FINANCIAL SERVICES 13 JUNE 2024 
INTERNAL AUDIT – ANNUAL REPORT  2023/24 
1.0 INTRODUCTION 
1.1 The purpose of this report is to advise the Audit and Scrutiny Committee
(the Committee) of the work undertaken by Internal Audit in respect of the
Annual Audit Plan 2023/24 and advise the Committee of the contents of
the Chief Internal Auditor’s (CIA) independent annual opinion on the
effectiveness of the Council’s risk management, internal control and
governance processes. 
1.2 The Public Sector Internal Audit Standards (PSIAS) became effective on 1st
April 2013 and as amended, require that: 
“The chief audit executive [ABC: Chief Internal Auditor] must deliver
an annual internal audit opinion and report that can be used by the
organisation to inform its governance statement. 
The annual internal audit opinion must conclude on the overall
adequacy and effectiveness of the organisation’s framework of
governance, risk management and control. 
The annual report must also include a statement on conformance
with the Public Sector Internal Audit Standards and the results of the
quality assurance and improvement programme.” 
1.3 Attached as appendices to this report are: 
• Appendix 1 – Internal Audit Annual Report and Summary of the audits
completed in 2023/24
• Appendix 2 – Internal Audit Opinion for 2023/24 
2.0 RECOMMENDATIONS 
2.1 The Audit and Scrutiny Committee endorses the content of this report 
and the associated annual opinion of the CIA. 
3.0 DETAIL 
3.1 Internal Audit is an independent and objective assurance function
designed to add value and improve the Council's operations. It helps the
Council accomplish its objectives by bringing a systematic, disciplined
approach to evaluate and improve the effectiveness of the Council's risk
management, internal control and governance processes.
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3.2 Internal Audit's purpose, authority and responsibilities are set out in
detail in the Internal Audit Charter, which was most recently approved by
the Committee in March 2024. Internal Audit reports its outputs regularly
throughout the year to the Committee. The Committee also approves
Internal Audit’s annual plan and monitors the performance of the
function. 
3.3 The risk based audits contained within the 2023/24 Internal Audit Annual
Plan are shown in the table included at Appendix 1 page 12.  This
shows the overall audit opinion for each audit and the number and
significance of agreed actions. 
3.4 Internal audit activity is planned to enable an independent annual
opinion to be given by the CIA on the adequacy and effectiveness of
internal controls within the authority, including the systems that achieve
the corporate objectives of the Council and those that manage the
material risks faced by the authority. It should be noted, however, that
the presence of an effective internal audit function contributes toward,
but is not a substitute for, effective control and it is primarily the
responsibility of line management to establish internal controls so that
the Council's activities are conducted in an efficient manner, to ensure
that management policies and directives are adhered to and that assets
and records are safeguarded. 
3.5 Internal Audit operated during financial year 2023/24 as part of the
Directorate of Kirsty Flanagan and whilst I report to the Council’s Head
of Financial Services on an administrative basis, I also have unrestricted
access to those charged with governance, specifically: Elected
Members; the Chief Executive; Executive Directors including the
Executive Director who is the Council’s Monitoring Officer. In addition,
Internal Audit staff have unrestricted access to all documents, systems
and information necessary to reach an opinion or view on any matter
under consideration.   
3.6 Internal Audit activity during the year was undertaken in accordance with
the revised Internal Audit Annual Plan. 
3.7 There were no substantial changes made to the 2023/24 audit plan. Two
reviews relating to ‘Stretch Aims’ and Building Cleaning were cancelled
due to staff availability/illness and resources within the service areas. 
3.8 I am pleased to report that, successful attempts have been made to
address the majority of outstanding historical recommendations which may
have been delayed due to Covid and more recently adverse weather
incidents. Council officers have continued to make progress in terms of
implementing agreed audit recommendations, despite competing
demands and finite resources.  Furthermore, there are robust follow up
procedures in place with reports taken to the SMT on a quarterly basis and
reported as a standing item on the Committee’s agenda. 
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3.9 There is a formal requirement for me to prepare an annual opinion on
the Council’s internal control system. The opinion is presented to
members of the Committee and is intended to provide independent and
objective assurance as to the adequacy and effectiveness of internal
controls within the Council. 
3.10  In addition to the work carried out by internal audit, my opinion is also
informed by: 
• the work of External Audit
• the work of other external inspection agencies who report on the
Council’s work 
• statements of assurances provided by the Chief Executive, Executive
Directors and Heads of Service providing their opinion on the
effectiveness of control, governance and risk management within their
areas of responsibility. 
3.11 My evaluation of the control environment is informed by these sources
and in bringing these together, consideration has been given to whether
there is evidence that any key controls are absent, inadequate or
ineffective and whether the existence of any weaknesses identified,
taken independently or with other findings, significantly impairs the
Council's overall systems of internal control. Wider issues relating to the
Council's corporate governance and risk management arrangements
have also been considered. 
3.12 The nature of individual audit assignments is such that most Internal
Audit reports identify some weaknesses or areas where scope for
improvement exists. However, I am pleased to report that, generally
across the Council, there continues to be a strong recognition amongst
management of the importance of proportionate but effective internal
controls. Senior management has also established an operating culture
where good standards of governance are seen as a key requirement in
the way in which the Council conducts its activities. 
3.13 During work undertaken in 2023/24 there have been instances where
the control environment was not strong enough or complied with
sufficiently to prevent risks to the organisation. In these cases, Internal
Audit has made recommendations to further improve the systems of
control and compliance. Although sometimes significant to the control
environment in place for the individual system or areas that have been
audited, I do not consider these weaknesses material enough to have a
significant impact on the overall opinion on the adequacy of the
Council's control environment at the year end. 
3.14 My formal annual Internal Audit opinion on the soundness of the
Council's internal control systems is presented in my Internal Audit
Annual Report in particular at Appendix 2. Overall, the results of the
work of Internal Audit in 2023/24 taken with other information available
to me did not lead me to conclude that the Council's overall systems of
internal control were significantly or materially impaired. 
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3.15 It has been a particularly busy year for the internal audit team as they have
supported the Chief Internal Auditor in the further development of our work
practices including working closely with the counter fraud team.  The team
have worked hard to deliver the internal audit plan, and in a backdrop of
the retirement of a qualified experience auditor, interim arrangements have
been made to address this vacancy and this will continue until training
plans are progressed and staff have developed experience along with
professional qualifications in order to improve resilience. It is my opinion
that the profile of Internal Audit continues to improve within the Council as
does the quality of the work it delivers and is evident in the feedback
received from post-audit surveys indicating a satisfaction rate of 93%. 
3.16 As required by the PSIAS a five-yearly external assessment took place in
2022-23 and the service was found to be fully compliant in all 14 areas of
review. Two minor housekeeping issues were identified and these have
now been fully implemented. All identified actions for improvement have
been tracked through our quality assurance improvement programme with
updates reported to Committee as part of a standard agenda item. 
3.17 On behalf of my team I would like to thank all Council staff who have
assisted Internal Audit during the course of our work throughout 2023/24
and to thank senior management and elected Members for the
consideration and due regard given to our work. It is important that good
relationships exist in order to promote and improve controls within the
Council and it is clear that such relationships are in place. 
4.0 CONCLUSION 
4.1 Subject to the matters listed in the Annual Governance Statement
reasonable/satisfactory assurance can be taken that the systems of
governance and internal control are operating effectively. Internal Audit
continues to develop and improve as a service. Our Internal Audit Annual
Report 2023/24 on page 10 provides a dashboard of our opinion in each
area of Governance, Risk Management and Internal Control. 
5.0 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 
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Page 41

Paul Macaskill
Chief Internal Auditor
13 June 2024 
For further information contact: 
Paul Macaskill, Chief Internal Auditor 
Tel: 01436 604108
Email:  paul.macaskill@argyll-bute.gov.uk 
APPENDICES
1. Internal Audit Annual Report 2023/24, Counter Fraud update and summary of
planned work in 2023/24
2. The Certificate of internal Audit Opinion 2023/24 
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ARGYLL AND BUTE COUNCIL
COMHAIRLE EARRA-GHÀIDHEAL AGUS BHÒID 
INTERNAL AUDIT ANNUAL REPORT 2023-24
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2 
Argyll and Bute Council – Internal Audit Annual Audit Report 2023/24
Contents 
Introduction ..................................................................................................................................................................................................................................... 1
Basis of opinion ............................................................................................................................................................................................................................... 2
Analysis of the Internal Audit Coverage and Performance ........................................................................................................................................................... 4
Quality Assurance and Improvement Programme ........................................................................................................................................................................ 5
Confirmation of Independence ....................................................................................................................................................................................................... 7
Counter Fraud Services ................................................................................................................................................................................................................... 8
Opinion, Conclusions and Observations ......................................................................................................................................................................................... 9
Appendix 1 – Summary of Internal Audit Plan 2023/24 .............................................................................................................................................................. 12
Appendix 2 – Certificate of Internal Audit Opinion 2023/24 ....................................................................................................................................................... 13 
Contact Details 
Chief Internal Auditor: Paul Macaskill
Telephone: 01546 604108
e-mail: paul.macaskill@argyll-bute.co.uk
www.argyll-bute.gov.uk
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Argyll and Bute Council – Internal Audit Annual Audit Report 2023/24
Introduction 
1. This report aims to provide the Audit & Scrutiny Committee with an evaluation of elements of Argyll and Bute Council’s internal control, risk
management and corporate governance systems based on our work during 2023/24 and to summarise the Internal Audit coverage in the year.
2. Corporate governance is the system by which local authorities direct and control their functions and relate to their communities. The three
fundamental principles of corporate governance are openness, integrity and accountability. A sound system of internal control must be
maintained to support Councils in operating effective corporate governance arrangements.
3. Good governance practice and internal control suggests that:-
• Council Members should set appropriate policies on internal control and seek regular assurance that the system of internal control is functioning
effectively;
• management should implement the Council’s policies on internal control and design, implement and monitor suitable systems; 
• a well-established and effective Audit and Scrutiny function should be in place within the Council;
• a local Code of Corporate Governance exists and is reviewed annually; and
• Internal Audit should provide an independent assessment of the adequacy of the system of internal control.
4. In Argyll and Bute Council a system of good governance is in existence and this is supported by a variety of policies, codes and guidance to promote
expected conduct of its business on a day to day basis. The national framework ‘Delivering Good Governance in Local government’ which was published
by the Chartered Institute of Public Finance and Accountancy (CIPFA) and the Society of Local Authority Chief Executives (SOLACE) in April 2016 aims to
assist authorities in reviewing and assessing their own governance arrangements. The Council has a ‘Local Code of Corporate Governance’ in place and
these arrangements are reviewed periodically and improvements required will be implemented, where necessary.
5. To support the governance statement the Council will need to carry out a review of the effectiveness of internal control, deriving evidence from a
variety of sources including Internal Audit, senior managers within the authority with responsibility for developing and maintaining internal control and
cognisance of external/internal audit recommendations along with recommendations of other regulatory bodies.
6. This report provides internal audit information in support of the assurance statements and covers the period from 1 April 2023 to 31 March 2024. The
attached Appendix reports the Internal Audit activity against the operational audit plan
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2 
Argyll and Bute Council – Internal Audit Annual Audit Report 2023/24
Basis of opinion 
7. We are able to provide assurance on the adequacy of internal controls and governance arrangements within the Council arising only from the results of
Internal Audit reviews we have completed during the period in accordance with the programme of Internal Audit work approved by the Audit and
Scrutiny Committee.  In this context, it is important to note that:
(a) it is Management’s responsibility to maintain internal control and good governance arrangements on an ongoing basis;
(b) the Internal Audit function forms part of the overall internal control and governance structure of the organisation;
(c) while we have planned our work so that we have a reasonable expectation of detecting significant control and governance weakness, internal
audit procedures alone do not prevent the possibility of poor judgement in decision making, human error, control processes being deliberately
circumvented by employees and others, management overriding controls and the occurrence of unforeseeable circumstances;
(d) a sound system of corporate governance and internal control provides reasonable but not absolute assurance that the Council will not be hindered
in achieving its objectives or in the orderly and legitimate conduct of its business by circumstances which may reasonably be foreseen. However,
a system of corporate governance and internal control cannot provide protection with certainty against any organisation failing to meet its
objectives or all material errors, losses, fraud or breaches of laws or regulations;
(e) it is the responsibility of Internal Audit to assess the adequacy of the internal control and governance processes as far as it is reasonably possible
by reviewing arrangements put in place by management and to perform testing to confirm whether those controls were operating for the period
under review; and
(f) reasonable expectations of senior management, the Audit and Scrutiny Committee and other stakeholders have been taken into account in terms
of our duty to report all matters which come to our attention for the period under review.
8. In our reports issued to date we have made recommendations, where appropriate, to improve internal controls and promote good governance. On the
basis of our sample testing of key controls, we concluded that these controls were generally operating as expected during the period under review, with
some exceptions that have been reported to management. Appropriate responses to the recommendations made in our reports have been obtained and,
if actioned, should provide management with additional comfort that the system of control operates as intended.
9. Summaries of the issues arising in relation to each system or activity covered by the internal audit work in 2023/24 have been reported to management
and the Audit and Scrutiny Committee throughout the year. We do not, therefore, propose to repeat the matters in this report. There have been no
significant issues which have come to our attention that have not been reported to management.
10. The services provided to the Council in 2023/24 by Internal Audit and Counter Fraud Services are summarised below:- 
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Argyll and Bute Council – Internal Audit Annual Audit Report 2023/24
INTERNAL AUDIT AND COUNTER FRAUD SERVICES 
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4 
Argyll and Bute Council – Internal Audit Annual Audit Report 2023/24
Analysis of the Internal Audit Coverage and Performance
11. In respect of 2023/24 the Internal Audit days planned and delivered can be summarised as follows: 
12. We have been able to achieve 100% of the agreed 2023/24 audit plan. In addition to the Council’s audit plan we have completed the agreed work for
the Health and Social Care Partnership (HSCP) contract and also that for LiveArgyll. The work demands on the service continue to be high and this is
expected to continue, therefore, our focus will remain on our high risk work and core continuous monitoring of our key financial systems.
Notwithstanding, the service remains focused on providing a high quality service and output supporting the Council to achieve its desired goals and
outcomes for the communities we serve.
13. We have worked with Council services and our appointed External Auditors, Mazars, to focus our work on those areas of the highest business risk to the
Council and those on which External Audit may wish to place reliance.
14. At Appendix 1, we provide details of the internal audit work undertaken in 2023/24.
15. In 2023/24, we issued 17 reports, which contained a variety of recommendations to improve the system of control, along with verification work in a
further 3 areas. Follow up internal audit work has been and will continue to be undertaken to establish if the more significant recommendations made
in those reports have been implemented as agreed. Two planned reviews were cancelled due to staff absences and unavailability of staff within the
service areas, these areas will be considered as part of future risk assessed internal audit planning processes, these were noted as amendments to the
0
20
40
60
80
100
2021/22 2022/23 2023/24
Percentage of Internal Audit
Plan Completed
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5 
Argyll and Bute Council – Internal Audit Annual Audit Report 2023/24
audit plan. During the year we undertook quarterly ‘follow up’ arrangements to report progress made by management in relation to previously agreed
recommendations. In addition, regular reporting of outstanding recommendations are considered by the Council’s Strategic Management Team (SMT)
on a regular basis to monitor progress and where appropriate seek that managers resolve any outstanding matters where these have gone beyond
agreed implementation dates; SMT are supportive in our work and this is helpful in our continued monitoring and progress assessments until such time
as our recommendations are fully implemented.
16. We also submitted formal progress reports to the Audit & Scrutiny Committee throughout the course of the year.
Quality Assurance and Improvement Programme
17. Internal Audit monitors its performance in a number of ways.  This allows us the opportunity to gauge the effectiveness of our service and may inform
future improvements. Principally, we monitor performance by the use of client questionnaires which are issued after each piece of work and allow
client departments to feedback contributions we have made to improve control, address any areas of value for money and raise any concerns. We are
pleased to report, from the questionnaires returned, that clients are generally very satisfied with our service. In addition, Internal Audit produce
quarterly and annual reports to the Audit and Scrutiny Committee allowing our progress to be monitored. 
18. CIPFA has issued a statement that sets out the role of the Head of Internal Audit in Local Government in 2019. The purpose of this statement is to
outline the core activities and behaviours that belong to the role of Head of Internal Audit and how these should influence and champion good
governance, risk management and internal control. The Council’s Internal Audit section conforms to the Statement.
19.  CIPFA and the Institute of Internal Auditors (IIA) have reviewed the guidance and made amendments in order to have a common set of standards
across the whole public sector. These changes are primarily based on the International Professional Practices Framework (IPPF). The new standards
termed Public Sector Internal Audit Standards (PSIAS) became effective in April 2013 and amended in 2017. It should, however, be noted that a
comprehensive review of the IPPF has been completed and a new set of standards called the ‘Global Internal Audit Standards’ will be implemented in
January 2025. A new and updated PSIAS reflecting these changes will be issued to public bodies in due course and a gap analysis will be undertaken to
identify any changes that Internal Audit may need to make to our documentation and processes.
20. A key requirement of the PSIAS is that Internal Audit sections are required to state whether or not they conform to these standards as part of their
annual reporting. In addition, they should outline the results of the quality assurance and improvement programme together with progress against any
improvements identified during this assessment.
21. In 2022/23 financial year, Internal Audit were subject to an external evaluation against the PSIAS, Local Government Application note and Quality
Assurance Improvement Programme. It is a requirement of the new standards that all public sector Internal Audit sections will require to be
independently assessed against these standards during a five year rolling period. The assessment found that in all 14 categories the Council’s Internal
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Argyll and Bute Council – Internal Audit Annual Audit Report 2023/24
Audit section were fully compliant. This is the highest level of standard attainable in the assessment and a report outlining the findings was presented
to the Council’s Audit and Scrutiny Committee in March 2023. Arrangements for the next review will be scheduled in for January 2028. The table below
outlines each of the 14 categories of assessment and the level of compliance/conformance achieved. 
Assessment Area Level of Conformance
External Independent EQA 2023
Level of Conformance Internal
Self-Assessment 2024
Mission of Internal Audit and Core Principles Fully Conforms Fully Conforms
Definition of Internal Auditing Fully Conforms Fully Conforms
Code of Ethics Fully Conforms Fully Conforms
Purpose, Authority and Responsibility Fully Conforms Fully Conforms
Independence and Objectivity Fully Conforms Fully Conforms
Proficiency and Due Professional Care Fully Conforms Fully Conforms
Quality Assurance and Improvement Programme Fully Conforms Fully Conforms
Managing the Internal Audit Activity Fully Conforms Fully Conforms
Nature of Work Fully Conforms Fully Conforms
Engagement Planning Fully Conforms Fully Conforms
Performing the Engagement Fully Conforms Fully Conforms
Communicating Results Fully Conforms Fully Conforms
Monitoring Progress Fully Conforms Fully Conforms
Communicating the Acceptance of Risks Fully Conforms Fully Conforms
Assessment Gradings: Fully
Conforms
Generally
Conforms
Partially
Conforms
Does Not
Conform 
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Argyll and Bute Council – Internal Audit Annual Audit Report 2023/24
22. In terms of the findings of the EQA a number of areas of good practice were identified:
• Full compliance with the PSIAS;
• Qualified Internal Auditors with extensive local authority experience;
• Internal Audit staff who are enthusiastic, experienced and focused on providing a good and professional service;
• Well defined procedures which ensures that the service provided is robust, reliable and efficient in carrying out audit activity; and
• The ability of External Audit to place reliance on the work of Internal Audit. 
The overall conclusion was that the Internal Audit Service Fully Conforms to the PSIAS. 
It was, however, noted that the two areas for improvement highlighted in the report are as follows:
• The need to undertake an annual review of the declarations of interest – this has now been implemented.
• Clearer referencing in the internal audit annual report to matters referenced in the Annual Governance Statement – this has now been
implemented.
As part of the annual process the Internal audit service undertakes a self-assessment against the PSIAS and this has concurred with the independent
assessment which was reported to the Council’s Audit and Scrutiny Committee in March 2023. A full copy of the EQA report can be accessed using the link
provided.
Confirmation of Independence 
23. Internal audit activity is planned to enable an independent annual opinion to be given by the CIA on the adequacy and effectiveness of internal controls
within the authority, including the systems that achieve the corporate objectives of the Council and those that manage the material risks faced by the
authority. It should be noted, however, that the presence of an effective internal audit function contributes toward, but is not a substitute for, effective
control and it is primarily the responsibility of line management to establish internal controls so that the Council's activities are conducted in an efficient
manner, to ensure that management policies and directives are adhered to and that assets and records are safeguarded.
24. Internal Audit operates as part of the Directorate of Kirsty Flanagan and reports to the Council’s Head of Financial Services on an administrative basis,
however, has unrestricted access to those charged with governance, specifically: Elected Members; the Chief Executive; Executive Directors including the
Executive Director who is also the Council’s Monitoring Officer.
25. Internal Audit operated without restriction and had unfettered access to all staff and documents both electronic and paper to allow full and effective
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Argyll and Bute Council – Internal Audit Annual Audit Report 2023/24
assessment of the work during 2023-24. We are therefore pleased to note that there are no matters which require to be drawn to the Audit and Scrutiny
Committee’s attention or wider senior management contained within this report regarding the independence of the Internal Audit service during 2023-
24.
Counter Fraud Services
26. The Counter Fraud Team (CFT) was established in September 2020 on a two year trial basis, during this period significant successes have been made in
identifying monies due to the Council and issuing bills for the rightful charges. In September 2022, on conclusion of the trial period and having
demonstrated a need for the service and its continued success, these arrangements were made permanent. The work of the CFT is wide in nature,
covering complaints of theft, fraud, dishonesty and irregularity to reviewing and proactively working to maximising the Council’s revenue streams by
reducing the amount of benefit fraud, not to mention educating and training staff on such issues. The Council also participates in the National Fraud
Initiative (NFI) which uses data analysis and matching to highlight potential irregularities that are reported back to each participating authority to
investigate.
27. The CFT consist of two full time staff who have formal qualifications in CIPFA Accredited Fraud investigators course. Indeed, both members of staff have
significant public sector experience in dealing with such matters and this has contributed to a successful approach. One member of staff is currently on
secondment until 2025 and the post is being backfilled during this period.
28. The table below summaries the total income recovered by the team to date. This has been broken down into reactive work through referrals, which can
also be quantified in terms of numbers, and proactive work such as large scale council tax reviews. The total funds recovered by the Fraud Team are:
Reactive Work Total Rebilled Value
Employee 7 0
Council Tax 41 34,443.79
Blue Badge 7 0
DWP 4 0
Grants 1 0
Other 13 0
Welfare Fund 0 0
Total 73 34,443.79
Proactive Work
Total combined work rebilled 1,039,939
Total combined work recovery 777,453
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Argyll and Bute Council – Internal Audit Annual Audit Report 2023/24
29. These figures represent the rolling total since the inception of the team to date and so far 74% of the income due that has been rebilled has been paid
to the Council. The rebilled accounts are routinely monitored and recovery is updated routinely.  It is not within the CFT’s remit to pursue rebilling as
that rests with the Debt Recovery teams.  The CFT will liaise with Debt Recovery for long term debts, work closely together to maximise the income for
the Council. The CFT monitor recovery for its own records.  The unquantifiable work carried out by the CFT also raises awareness of the potential for
suspicious activity toward the Council and information is passed nationally to other local authorities and Police Scotland.
30. Local visits throughout Argyll and Bute were undertaken in the year and this will form part of a rolling programme of visits going forward, focusing on
maximising the income due to the Council. In addition the CFT are raising awareness of the Council’s zero tolerance to fraud and this will help act as a
deterrent to fraud being perpetrated in the first place.
31. In addition to the above role the CFT undertake investigative work on complaints received regarding allegations against staff and where these require
to be looked at in terms of fraud, theft or other irregularity then a full examination of the facts will follow and be reported. This work can be and often
is time consuming and is fitted in to the overall demands of the role. The nature of this work is sensitive and confidential and reporting is therefore
restricted in terms of data protection and associated rights.
Opinion, Conclusions and Observations
32. We agreed a rolling programme of Internal Audit coverage based on an assessment of risk factors with Management and the Audit and Scrutiny
Committee. This programme related to the level of available resources, focusing on higher risks and areas identified by management as requiring audit
review within the Council. On the basis of the internal audit systems and work completed in respect of this year, we consider that the assessment of key
systems are noted below. A certificate of opinion is noted within Appendix 2 of this document reflecting our opinion.  
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Argyll and Bute Council – Internal Audit Annual Audit Report 2023/24
Governance     Risk Management      Internal Control                                                                                             
33. However, we would point out the following exceptions and/or observations:
• Across Scotland’s public sector significant pressures continue as a result of financial settlements and this has been particularly compounded as a
result of inflationary pressures and rising costs of fuel, gas and electricity, together with the risk of unfunded or partly funded pay settlements.
These pressures are likely to remain going into 2024/25 financial year and will continue to add an element of uncertainty in relation to the
overall financial picture affecting the Council. The Council continues to undertake appropriate medium to long term financial planning using a
scenario modelling approach which helps to provide Members with a thorough overview of the implications of funding and cost pressures.
• The Argyll and Bute HSCP is having to manage a number of challenges relating to financial pressures and staffing. This is resulting in increased
reliance upon agency and locum staff which does not provide for a stable and sustainable service model and in turn is placing increased
pressure on service budgets. The HSCP had provisionally identified a budget gap of approx. £12M for 2024/25 but have identified savings of 
Classification and Assessment 
Poor and Requiring Improvement – Does not meet any key areas of good practice or partially or fails to meet most key areas of good practice. 
Adequate and/or Improving - Attempting to meet or meets most key areas of good practice/ with effort being made to improve further. 
Reasonable/Satisfactory - Substantially meets all key areas of good practice.
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Argyll and Bute Council – Internal Audit Annual Audit Report 2023/24
£8.2M to date and are seeking to identify further savings to bridge this gap and manage its financial position. Such a position increases the risk
to parent bodies in terms of financial support being required.
• During our planned work for 2023/24, we found no significant reporting issues that have not already been drawn to the Audit and Scrutiny
Committee’s attention.
• The Work of our CFT continues to be supportive and preventative in approach and where there is evidence of error, fraud or complaint which
has a financial impact on the Council, every attempt will be made to actively recover monies due in order to maximise income and serve as a
deterrent.
• Our findings contained within this report should be considered in the preparation and reporting of the Council’s Annual Governance Statement
which can be found on the Council’s web page. 
34. Finally, we would also like to highlight our appreciation to the Council’s Audit & Scrutiny Committee for their strong support, together with the full co-
operation of the Council’s Management Team and ongoing working relationship with the appointed External Auditors, Mazars. 
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Argyll and Bute Council – Internal Audit 2023/24 Annual Audit Plan 
Appendix 1 – Summary of Internal Audit Plan 2023/24 
Appendix 1 - Summary of 2023/24 Internal Audit Plan 
No. of Recommendations
Report Title
Overall
Opinion High Medium Low VFM
Pupil Registration 
High 0 0 3 1
Freedom of Information 
High 0 0 4 0
Compliance Review – Period
Products Substantial 0 5 4 0
Financial Ledger 
Substantial 0 0 0 0
Risk Management 
High 0 0 1 0
Fleet Management 
Reasonable 0 0 1 4
Pupil and Public Transport 
Substantial 0 1 1 2
Piers and Harbours 
Reasonable 0 0 8 0
Oban Airport 
High 0 0 0 0
Planning 
Substantial 0 1 3 0
Human Resources 
Substantial 0 2 3 0
Cloud Based Computer Services 
Substantial 0 4 1 0
SSSC Registration 
Substantial 1 1 4 0
Client Funds 
Reasonable 0 0 0 0
Learning and Physical Disability
Care Packages Reasonable 0 7 0 0
Establishment Visits 
Substantial 0 0 0 0
LGBF 
n/a 0 0 0 0
Stores & Stock Control 
n/a 0 0 0 0
EMA
High 
0 0 0 0 
SPT Concessionary Fares n/a 0 0 0 0  
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Argyll and Bute Council – Internal Audit Annual Audit Report 2023/24
Appendix 2 – Certificate of Internal Audit Opinion 2023/24
To the Members of Argyll and Bute Council, the Chief Executive, other members of the Council’s
Senior Management Team including the Section 95 Officer 
As the Chief Internal Auditor of Argyll and Bute Council (the Council), I am pleased to present my
annual statement on the adequacy and effectiveness of the internal financial control system of the
Group Accounts prepared by the Council for the year ended 31 March 2024.
Respective responsibilities of management and internal auditors in relation to internal control
It is the responsibility of the Council’s senior management to establish an appropriate and sound
system of internal financial control and to monitor the continuing effectiveness of that system. It is
the responsibility of the Chief Internal Auditor to provide an annual overall assessment of the
robustness of the internal financial control system.
The Council’s framework of governance, risk management and internal control
The Council has a responsibility to ensure that its business is conducted in accordance with
legislation and proper standards. The governance framework comprises the systems and processes,
culture and values by which the Council is directed and controlled and how it accounts to
communities. It enables the Council to monitor the achievement of its strategic priorities and to
consider whether those objectives have led to the delivery of appropriate services and value for
money.
The main objectives of the Council’s internal control systems are to ensure: 
• adherence to management policies and directives in order to achieve the organisation’s
objectives 
• economic, efficient, effective and safe use of resources and assets 
• the relevance, reliability and integrity of information, so ensuring as far as possible the
completeness and accuracy of records 
• compliance with statutory requirements.
The system of internal control is a significant element of the governance framework. Any system of
control can only ever provide reasonable and not absolute assurance that control weaknesses or
irregularities do not exist or that there is no risk of material errors, losses, fraud, or breaches of laws
or regulations. Accordingly, the Council is continually seeking to improve the effectiveness of its
systems of internal control in order to identify and prioritise the risks that would prevent the
achievement of the Council’s strategic objectives.
The work of internal audit
Internal auditing is an independent, objective assurance and consulting activity designed to add
value and improve an organisation’s operations. It helps an organisation accomplish its objectives by
bringing a systematic, disciplined approach to evaluate and improve the effectiveness of risk
management, control and governance processes.
The Council’s Internal Audit Section operates in accordance with the Public Sector Internal Audit
Standards (PSIAS) which have been agreed to be adopted from 1 April 2013 by the relevant public
sector Internal Audit Standard setters. PSIAS applies the Institute of Internal Auditors International
Standards to the UK Public Sector. 
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PSIAS requires that a Quality Assurance and Improvement Programme (QAIP) is developed in order
to provide assurance that internal audit activity: 
• is conducted in accordance with an Internal Audit Charter 
• operates in an efficient and effective manner 
• is perceived to be adding value and improving operations.
PSIAS also requires, as outlined in Standard 1300 “QAIP”, that: 
“External assessments must be conducted at least once every five years by a qualified, independent
assessor or assessment team from outside the organisation. External assessments can be in the form
of a full external assessment or a self-assessment with independent external validation”.
To meet this requirement, a reciprocal arrangement to complete a programme of inspections has
been developed by the Scottish Local Authorities Chief Internal Auditors Group (SLACIAG). This
process identified East Dunbartonshire Council as the body to undertake the independent review of
the Council’s Internal Audit function’s level of compliance with PSIAS. This output of this review was
presented to the Audit and Scrutiny Committee in March 2023. It concluded that the internal audit
service demonstrates full compliance/conformance with PSIAS and identified many areas of strong
practice including the internal audit team is highly qualified, delivers a high quality service,  good
engagement and clear reporting lines and clear evidence of supervision and audit follow up.
Internal Audit undertakes an annual programme of work based on a risk assessment process which is
revised on an ongoing basis to reflect evolving risks and changes within the Council.
All Internal Audit reports identifying system weaknesses and / or non-compliance with expected
controls are brought to the attention of management and the Audit and Scrutiny Committee
together with appropriate recommendations and agreed action plans. It is management’s
responsibility to ensure that proper consideration is given to Internal Audit reports and that
appropriate action is taken on audit recommendations.
The internal auditor is required to ensure that appropriate arrangements are made to determine
whether action has been taken on internal audit recommendations or that management has
understood and assumed the risk of not taking action. A programme of follow-up on assignment
findings and recommendations provides assurance on the complete and timeous implementation of
internal audit recommendations.
Internal Audit staff regularly attended the following external user group meetings: 
• SLACIAG, the purpose of which is to develop and improve the practice of internal audit
activity with Scottish local authorities. It achieves this by meeting to discuss issues of
common concern, commissioning work to develop ideas, sharing good practice, working in
partnership with other professional / governing bodies and promoting SLACIAG as the
representative body for internal audit in local authorities. We have attended meetings of
SLACIAG during 2023/24. 
• SLACIAG Computer Audit sub group: a member of the audit team attends this forum and
contributes to outputs and communications that are regularly exchanged with the aim of
ensuring that audit teams are better equipped to perform technical information systems
audits.
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• The CIA also meets the Chief Internal Auditors of West Dunbartonshire Council, East
Dunbartonshire Council, West Lothian Council, Falkirk Council and Inverclyde Council on a
quarterly basis to discuss developments and share knowledge. In-between these meetings
we are in regular contact to share information which helps deliver audit plans more
efficiently including consistent use of benchmarking indicators.
Basis of Opinion
My evaluation of the control environment is informed by a number of sources: 
• the audit work undertaken by Internal Audit during the year to 31 March 2024, including risk
based audits, continuous monitoring and follow-up activity. 
• the assurance statements signed by the executive directors and heads of service on the
operation of the internal financial controls for the services for which they were responsible
during the year to 31 March 2024. 
• the assurance statement signed by the Chief Executive for the overall Council for the year
ended 31 March 2024. 
• reports issued by the Council’s external auditors, Mazars, and other external review
agencies.
• my knowledge of the Council’s governance, risk management and performance monitoring
arrangements.
Limitation to Resources or Scope of Internal Audit Work
I can report that Internal Audit operated throughout 2023/24 with no impairments or restrictions in
scope or independence.
There were sufficient resources available to deliver the amended programme of audit assignments
contained within the 2023/24 Internal Audit Plan and no significant threats emerged to the
independence of the internal audit activity such as inappropriate scope or resource limitations.
Opinion
It is my opinion, based on the above, that reasonable assurance can be placed upon the adequacy
and effectiveness of the Council’s systems of governance, risk management and internal control in
the year to 31 March 2024.
Signature: 
Paul Macaskill FCPFA CMIIA
Title: Chief Internal Auditor 
Date: 13 June 2024 
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Page 61

ARGYLL & BUTE COUNCIL
LEGAL AND REGULATORY 
SUPPORT
FINANCIAL SERVICES 
Audit and Scrutiny Committee 
13 June 2024      
STATEMENT OF GOVERNANCE AND INTERNAL CONTROL   
1. EXECUTIVE SUMMARY 
1.1. This report advises that the statement of governance and internal control for
2022/23 has been reviewed and updated which allows the Council to include
a statement of governance and internal control in the Annual Accounts for
2023/24. 
2. RECOMMENDATIONS        
2.1  The Committee consider and approve the draft statement of governance
and internal control for 2023/24. 
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ARGYLL & BUTE COUNCIL
LEGAL AND REGULATORY 
SUPPORT
FINANCIAL SERVICES 
Audit and Scrutiny Committee 
13 June 2024      
STATEMENT OF GOVERNANCE AND INTERNAL CONTROL    
1. HEADLINES  
1.1  This report advises that the statement of governance and internal
control for 2022/23 has been reviewed and updated which allows the
Council to include a statement of governance and internal control in the
Annual Accounts for 2023/24. 
2. RECOMMENDATIONS  
2.1 The Committee consider and approve the draft statement of governance
and internal control for 2023/24  
3. DETAIL  
3.1 CIPFA and SOLACE published a revised Framework for ‘Delivering
Good Governance in Local Government’ in 2016. The Framework was
defines seven core principles that should underpin the governance of
local authorities and provides a structure to assist authorities with
assessing their own approach to governance. 
3.2 
3.3 
3.4
The Council is required to prepare a statement of governance and
internal control confirming the Council’s position in regard to the seven
core principles for 2023/24. 
The draft document which is attached at Appendix 1 provides details of
the position for 2023/24 and includes an update on the ‘areas for further
development’ identified in the 2022/23 document. It has been approved
by ELT. 
Once approved the statement of governance and internal control is
included in the Council’s Annual Accounts for 2023/24 and identifies
areas within the Council where work to improve its governance
arrangements will be being undertaken in 2024/25.  
3.5 The seven principles contained in the local code are: 
1. Behaving with integrity, demonstrating strong commitment to
ethical values, and respecting the rule of law. 
2. Ensuring openness and comprehensive stakeholder
engagement.
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3. Defining outcomes in terms of sustainable economic, social and
environmental benefits. 
4. Determining the interventions necessary to optimise the
achievement of the intended outcomes. 
5. Developing the entity’s capacity, including the capability of its
leadership and the individuals within it. 
6. Managing risks and performance through robust internal control
and strong public financial management 
7. Implementing good practices in transparency, reporting, and
audit to deliver effective accountability  
3.6 The review of the effectiveness of the system of governance and
internal control is informed by the: 
• work of council officers 
• work of External and Internal Audit
• Statements of Governance or Internal Control provided by
external bodies
• external review and inspection reports
• recommendations from the Audit and Scrutiny Committee  
4. CONCLUSION  
4.1 This review gives assurance about the robustness of the Council’s
governance arrangements.  
5. IMPLICATIONS  
5.1 Policy – None 
5.2 Financial – None
5.3 Legal – None 
5.4 HR – None 
5.5 
5.6
Fairer Scotland Duty – None           
5.5.1 Equalities – Protected Characteristics 
5.5.2 Socio Economic Duty 
5.5.3 Islands
Climate Change – None 
5.7 Risk – None
5.8
5.9
Customer Service – None
The Rights of the Child (UNCRC) – None 
Douglas Hendry
Executive Director with responsibility for Legal and Regulatory Support 
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Kirsty Flanagan
Executive Director with responsibility for Internal Audit 
For further information please contact:
Iain Jackson, Governance, Risk and Safety Manager - 01546 604188
Paul MacAskill, Chief Internal Auditor - 01546 604108 
Appendices
Appendix 1 - Draft Statement of Governance and Internal Control 23/24   
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Appendix 1
Annual Governance Statement 
1. BACKGROUND AND SCOPE OF RESPONSIBILITY 
Argyll and Bute Council’s (the Council) governance framework includes the systems,
processes and culture by which the Council is controlled, engages with communities and
monitors the achievement of strategic objectives. The Council conducts its business in
accordance with the law and proper standards. The Council has a duty to make
arrangements to secure continuous improvement in the way in which its functions are
exercised, having regard to the economic, efficient and effective use of public money. 
The system of internal control is a key part of the framework and is designed to manage
risk to an acceptable level.   
In discharging these responsibilities, the Council has put in place proper arrangements
for the governance of its affairs and the stewardship of the resources at its disposal. The
Council has approved and adopted a Local Code of Corporate Governance (the Code)
which is consistent with the principles and requirements of the CIPFA/SOLACE revised
Framework for ‘Delivering Good Governance in Local Government. This Statement
explains how the Council has complied with the Code and meets the requirements of
current good practice. 
2. THE GOVERNANCE FRAMEWORK
The Code details how the Council will demonstrate compliance with the fundamental
principles of corporate governance for public sector bodies.  The seven key principles of
our governance arrangements in 2023/24 are described in the Code, along with our
supporting principles and key aspects of our arrangements to ensure compliance. 
1. Behaving with integrity, demonstrating strong commitment to ethical values,
and respecting the rule of law.
We have four values, which underpin all that we do and provide a sound basis to
achieve transformation to ensure we meet the challenges of the future and deliver
quality services. These values are that we have a workforce which is: 
Caring  Committed  Collaborative  Creative  
The Council has developed a change programme ‘Connect for Success’ with the seven
principles – One Council One Place Approach, Purpose and Mission Focus, Employee
Empowerment, Data and Evidence Driven Decision Making, Learning Council, Agile and
Maximise Opportunities that Technology Offers - Connect for Success 
We have developed and communicated an Ethical Framework within the Council's
Constitution, which defines standards of behaviour for Members and staff. Protocols for
Member/Officer relations are also detailed within the Constitution.   
The Councillors’ Code of Conduct is set out at a national level, applying to all members
in Scottish local authorities and is incorporated into the Council’s Constitution as part of
the ethical framework which also includes a protocol for the Monitoring Officer. A
Register of Members Interests is publically available for inspection. In addition, the
Constitution has a section on conduct at meetings and meeting agendas require
declarations of interest to be made where appropriate. Standing orders for meetings are
included within the Council’s constitution and training and support is provided to
members on their role in Council committees. 
Anti-fraud and whistleblowing policies are in place and the Council has adopted the
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Appendix 1
Annual Governance Statement 
Scottish Public Services Ombudsman’s (SPSO’s) Model Complaints Handling
Procedure.
The Council complies with CIPFA’s Statement on the Role of the Chief Financial Officer
in Local Government. 
In addition, Professional advice on the discharge of statutory social work duties is
provided to the Council by the Chief Social Work (CSWO). 
A structure of governance and framework across our day to day activities and which
supports accountability, control, risk management and appropriate overview of the
Council are outlined in the diagram below: 
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Appendix 1
Annual Governance Statement 
2. Ensuring openness and comprehensive stakeholder engagement.
We have established clear channels of communication with the community and other
stakeholders through our Communication Strategy.  Key mechanisms include:
Consultation Diary 
Decision Making /
Procedural
Council and
Committee Structure
Council and
Committee Terms of
Reference
Council and
Committee Standing
Orders
Scheme of Delegated
Functions
Standing Orders
Relating to Contracts
Councillor's Code of
Conduct
Corporate Governance
Executive Leadership
Team and Senior
Management Team
Risk Management
Integrity
HR and Individual
Capability
Strategic Planning
Performance
Management
Framework
Community Planning
and Empowerment
Stakeholder
Engagement
Financial Governance
Internal Control
ALEO Governance
Scheme of Delegation
ALEO Governance
Framework
Risk and Governance
Reporting
Financial and
Operational
Performance
ALEO Risk Register
Asset Governance
Corporate Asset
Management Strategy
Corporate Asset
Managment Plan and
Capital Plan
Records Management
Information
Management and
Security
Local Development
Plan
ICT and Digital
Strategy
Major
Programmes/Projects
Capital Investment
Programme
Conservation Area
Regeneration Scheme
(CARS) Projects
Campbeltown,
Helensburgh, Oban,
Rothesay & Dunoon
(CHORD) Projects
Marine Asset
Management Plan
Rural Growth Deal
Annual Status and
Options Report
External and Internal Audit and other regulatory inspections
Constitution, Governance, Risk Management and Accountability
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Appendix 1
Annual Governance Statement 
The Council has developed a consultation section on its website which hosts all consultations
run by the Council and includes a section which publicises the results and/or outcome of the
consultation and the resultant decisions that have been taken, showing how they were
informed by the consultation process. This is part of our commitment to You Said, We Did
information sharing for the public. Consultations provide communities with an opportunity to
get involved with wide ranging aspects of the council’s work and life in Argyll and Bute. 
These include for example, play park funding, active travel routes, primary school
consultations, and the council’s customer service strategy. 
Keep in the Loop Service  
Over 10,870 customers currently subscribe to receive notifications across the range of
services. 
'Myaccount' is a secure sign-in service for accessing online public services in Scotland. It
provides the ability to set up an online account and use it to access a growing range of
online public services, Scotland-wide, including Argyll and Bute Council. Currently 16,744
customers up from 15,399 last year have signed up to this service and it allows customers to
access and personalise their interaction with the Council on a range of services. 
Public Performance Reporting
The Council’s website makes all performance information available to the public. This
includes information on performance scorecards, budgets and other service related
information. This promotes open accountability to the public for its performance against
agreed policies and standards. As part of phase two of the performance excellence project a
review of the council's approach to public performance reporting is being undertaken.
Accessibility
In 2023/24 75% of 593,362 customer interactions through the council’s Customer
Engagement Team were made using digital self-service. This very high proportion is
because of the scope and quality of the digital services provided. In order to ensure
maximum accessibility for everyone and meet our equalities responsibilities, the Council’s
website was upgraded to the latest software version Drupal 10 and its content refreshed to
meet the new international WCAG2.2 standard. 
In March 2024 it scored 98% in the Uk Independent Silktide accessibility score, rating it the
37th highest ranking Council in the UK. In addition the Reachdeck supported access tool
was added to the website to give read aloud and translation help to users seeking such
additional assistance and our 24/7 automated telephone service was used 46,942 times by
those customers who struggle with online digital services.
Community Engagement 
To support strengthening communities, community empowerment and engagement the
council has in place: 
• An officer Community Engagement Strategy Group to oversee the development and
implementation of the council’s internal Engagement Strategy; advising on best practice
in engagement tools and techniques, supporting skills development and capacity within
the council to effectively engage with communities. On this group sit those officers with
expertise in engagement including those from Corporate Communications and the
Communities & Partnership Team. The Councils Communications Team has developed
an engagement app for services to use, and the council’s Communities & Partnership
Team has resources and expertise to support hard to reach groups, community
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Appendix 1
Annual Governance Statement 
organisations and remote communities to have a voice in decision making. 
• A Community Development service, with a focus on improving active citizenship and
capacity building through best practice in community development through a responsive
and effectively targeted programme of Community Development support internally to the
council and externally within communities across Argyll and Bute.
• A range of training and resources to help build the knowledge, skills and confidence of
community groups
• Funding support to help empower community organisations to take forward priority
projects and activities in their area: Monthly funding alert | Argyll and Bute Council
(argyll-bute.gov.uk)
• Resourcing community council liaison activities, including training and support activity,
which helps to build the capacity of community councils.  
The Council also has a statutory lead role to ensuring Community Learning and
Development provision in Argyll and Bute is set out in an Argyll and Bute Community
Learning and Development Strategic Plan, and this is delivered through its collaboration with
its Arms-length External Organisation (ALEO) partner Live Argyll.
The Council continues to promote the Community-led action plan toolkit (developed in
partnership with Scottish Community Development Centre) to help support communities
interested in developing a local Community-led Action Plan. The Council also provides
support for communities interested in development a Place Plan: Local Place Plans | Argyll
and Bute Council (argyll-bute.gov.uk)
The Council directly resources the management of the Community Planning Partnership
(CPP) to bring partners together, including community, to deliver on the Outcome
Improvement Plan. It actively seeks to ensure that young people are engaged in Community
Planning and has implemented the following:
• The 3 local Members of the Scottish Youth Parliament (MSYP's) attend the
Community Planning Partnership Management Committee meetings on a rotational
basis.  
• The Area Community Planning Groups (ACPG) invite members of local Youth Forums
to attend meetings when they are held in their local areas & information is passed on
to young people by Youth Workers who are kept updated on any developments. 
• The revised Scheme of Establishment for Community Councils outlines the
requirement to encourage young people to attend and participate in community
council meetings” and the age to become a Community Councillor was lowered to be
16 to encourage more young people to become involved.
Council/Committee Meetings
Meetings are always held in public, unless one of the statutory exemptions in the Local
Government (Scotland) Act 1973, schedule 7A applies to the content of the report. Agendas
for and minutes of meetings are detailed on the Council’s website. When schedule 7A applies
papers are adjusted to ensure that the maximum amount of content is in the public domain.
The Council’s Constitution defines the roles and responsibilities of the administration,
committees, scrutiny and officer functions, with clear delegation arrangements and protocols
for effective communication. 
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Appendix 1
Annual Governance Statement 
The Standards Commission Advice Note for Councillors on Distinguishing between their
Strategic Role and any Operational Work has previously been included in an Elected Member
Seminar and is hosted on the Members Resource page on the Hub for ease of reference.
3. Defining outcomes in terms of sustainable economic, social, and environmental
benefits.
Our Corporate plan sets out our, and our community planning partner’s, vision for Argyll and
Bute’s economic success to be built on a growing population. It also defines our mission “To
make Argyll and Bute a place people choose to live, learn, work and do business” and
establishes our outcomes, priorities and approach to delivering on our shared ambition with
our community partners.
We have a Performance Improvement Framework (PIF) that ensures performance is integral
to the work of the Council.  The PIF is focused not just on measuring what we do but on
measuring the difference we make in terms of our outcomes.   
Asset management planning and capital investment is structured to consider and balance the
combined economic, social and environmental impact of policies and plans when taking
decisions about service provision. The Council has put arrangements in place to comply with
key elements of the Community Empowerment Act.
In determining how services and other courses of action should be planned and delivered the
Council is increasingly engaging with internal and external stakeholders. Community benefit
is an important consideration in the procurement of goods and services.
The Council has acknowledges the effects of the ‘Cost of Living’ within Argyll and Bute and
during 2023/2024 client gain achieved by the Flexible food and Fuel fund  project reached
£3.8 million. This project, supporting the most vulnerable low income households and those
using foodbanks in our area to access short-term grants to cover the cost of food and fuel in
the short term. In the longer term support through the provision benefit maximisation, money
advice and energy advice services is provided by third sector partner agencies. 
In addition, this year the Council has issued 1,300 Scotland Loves Local Gift Cards to low
income households in the year ensuring the £110,000 loaded onto the gift cards is spent in
Island based local businesses in Argyll and Bute. The Council and the Third Sector Interface
is supporting the Poverty Alliance on a project entitled “Taking Action on Rural Poverty” which
is looking at new ways of addressing rural poverty in Argyll and Bute by reducing the rural
poverty premium.  
The Council has also provided a one-stop-shop webpage where individuals and families can
access energy advice, money advice and links to the services the Council provides in this
area and those provided by third sector partner organisations.
In 2022/23 Argyll & Bute Council recorded its lowest level of operational carbon emissions
since reporting commenced in 2015/16 via the Public Bodies Climate Change Duties. This
represents a reduction of 12,952 tCO2e (tonnes of carbon dioxide equivalent), approximately
33% against baseline figures. Work continues across Council services to reduce our
emissions and support our journey to net zero including the transition to energy efficient LED
streetlighting, moving to electric or hybrid fleet vehicles, and increasing diversion of waste
from landfill.
Integrated impact assessments as well as environmental, sustainability and island
implications are considered during the decision making process to promote fair access to
services.
4. Determining the interventions necessary to optimise the achievement of the
intended outcomes.
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Decision makers receive detailed information indicating how intended outcomes would be
achieved together with the implications associated with the proposals covering financial,
risks and mitigations, integrated impact assessment, acting sustainably, carbon
management, island proofing, and changes to schemes, by way of the compulsory sections
of the Committee report.
The Council’s Executive Leadership Team (ELT) meet regularly with the administration to
discuss their key priorities and requirements for decision making in addition there is regular
survey and feedback on their needs and a regular review of governance arrangements to
ensure that decision making is fully supported.
In determining how services and other courses of action should be planned and delivered
the Council is increasingly engaging with internal and external stakeholders. Community
benefit is an important consideration in the procurement of goods and services.
The Council fosters effective relationships, collaborative working and contractual
arrangements with other public, private, and voluntary organisations in delivering services
that meet the needs of the local community as stated in the Council’s Corporate Plan 
5. Developing the entity’s capacity, including the capability of its leadership and the
individuals within it.
Elected Member Development
The Council has signed up to the Improvement Service’s Continuing Professional
Development Framework for Elected Members. All Elected Members are provided with
opportunities to progress personal development plans so that individual training needs and
aspirations are identified and support provided as appropriate. This is complemented by a
comprehensive seminar and workshop programme which addresses a wide range of topics
and strategic issues. Additional training was undertaken by Elected Members in relation to
the technology, knowledge and skills necessary to support the transition to a virtual
environment including webcasting of strategic Committee meetings and the operation of
meetings on a hybrid basis, enabling a mixed attendance of members being physically or
virtually present.             
Officer Development
The Council supports officer development through a structured approach, driven by the values
set out in the Corporate Plan and a behavioural competency framework.
The Council has Argyll and Bute Manager and Leadership Programmes, which ensure that all
employees who have management responsibilities are knowledgeable and effective in
delivering services within the priority management policies and procedures of the Council,
including finance, performance and people management. The Leadership Programme
ensures that senior and aspiring leaders in the organisation have support to develop their
leadership behaviours and to improve their overall impact and performance across the
organisation. 
6. Managing risks and performance through robust internal control and strong
public financial management. 
Internal Financial Control
Our standing orders, financial instructions, scheme of delegation and supporting procedure
notes/manuals clearly define how decisions are taken and the processes and controls in place
to manage risks. These are reviewed and updated on an annual basis. We ensure compliance
with relevant laws and regulations, internal policies and procedures, and that expenditure is
lawful. The Council’s Monitoring Officer advises on compliance with our policy framework,
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Annual Governance Statement 
ensuring that decision making is lawful and fair. Furthermore the Council has a designated
Data Protection Officer and all services have Information Asset Registers along with
appropriate guidance on how data should be managed.
Our financial management arrangements conform to the CIPFA Statement on the Role of the
Chief Financial Officer and we ensure that our independent Audit and Scrutiny Committee
undertakes the core functions identified in CIPFA’s Audit Committees – Practical Guidance
for Local Authorities. 
The Council has a proactive, holistic approach to tackling fraud, theft, corruption and crime,
as an integral part of protecting public finances, safeguarding assets, and delivering services
effectively. It is based upon the national counter fraud standard CIPFA’s Code of Practice on
‘Managing the Risk of Fraud and Corruption’.
The Council has a system of internal financial control designed to manage risk to a reasonable
level. It is based on a framework of regular management information, financial regulations,
administrative procedures (including segregation of duties), management supervision, and a
system of delegation and accountability. 
Development and maintenance of the system is undertaken by officers within the Council and
the named bodies mentioned below. 
Internal Financial Controls and Prevention  Are these in Place?
Comprehensive budget systems 
Financial and budget monitoring systems 
Financial and Performance reporting systems 
Clearly defined Capital Expenditure guidelines 
Project Management processes and disciplines 
An effective Internal Audit Section 
An effective Counter Fraud Team 
Internal controls cannot eliminate risk of failure to achieve policies, aims and objectives and
can therefore only provide reasonable and not absolute assurance of effectiveness. 
This annual review also covers the other bodies whose activities are incorporated into our
Group Accounts and reliance is placed on the formal audit opinion contained in the financial
statements of each individual body.
• Dunbartonshire and Argyll and Bute Valuation Board
• Live Argyll
• Argyll and Bute Integration Joint Board
The Council’s risk management processes are well developed. In particular the:
• Strategic Risk Register is updated twice a year and approved by the SMT
• Chief Executive presents the Strategic Risk Register to the Audit and Scrutiny
Committee on an annual basis
• Operational Risk Registers are updated quarterly by departmental management
teams.
• Internal Audit will perform an audit of compliance with risk management arrangements
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every three years.
• The CIA performs an annual strategic risk assurance mapping exercise. 
7. Implementing good practices in transparency, reporting, and audit to deliver
effective accountability 
Internal Audit 
The Council and its Group bodies have internal audit functions, which operate to Public Sector
Internal Audit Standards. The work of internal audit is informed by an analysis of the risk to
which the Council and its Group bodies are exposed, with annual internal audit plans prepared
based on that analysis. The Council's Audit and Scrutiny Committee endorses the preparation
methodology and annual internal audit plan and monitors the performance of Internal Audit in
completing the plan. In addition, the Council has developed a hybrid meeting facility enabling
physical and virtual attendance at meetings with a public broadcast function so that members
of the public can see and hear meetings of the Council’s strategic committees’ live increasing
openness and transparency.
The Chief Internal Auditor (CIA) provides the Audit and Scrutiny Committee with an annual
report on internal audit activity in the Council and an opinion of the assurance can be taken
regarding the systems of governance and internal control and whether they are operating
effectively. This is an independent and objective opinion of the CIA based on work carried out
in conformance with the Public Sector Internal Audit Standards to fulfil statutory Internal Audit
provision.
Internal audit provides members and management of the Council with independent assurance
on risk management, internal control and corporate governance processes. External audit
has, and continues to, use the work of internal audit. 
The Annual Accounts and Report sets out the financial position in accordance with relevant
accounting regulations. 
Review of the Adequacy of Effectiveness of the Council’s Governance
Framework 
Work to deliver Argyll and Bute’s Covid Recovery Strategy and Action plan continued in
2023/24 with the same governance arrangements. Full details of the action plan is detailed in
the document “Recovery, Renew and Restart”, which was approved by Councils Economic,
Development and Infrastructure Committee.   
The Council has appropriate management and reporting arrangements to enable it to satisfy
itself that its approach to corporate governance is adequate and effective in practice. The
legislative framework of local government defines a number of posts which are primary to the
Council’s governance arrangements.  These include the Chief Executive, Pippa Milne fulfilling
the role of Head of Paid Service. As Monitoring Officer, the Executive Director Douglas
Hendry: 
• oversees the implementation of the Code and monitoring its operation
• reports annually to the Council on compliance with the Code and any changes
required to maintain it and ensure its effectiveness.
Specific responsibilities are assigned to the Executive Director Kirsty Flanagan as the
Council’s Chief Financial Officer (S95 Officer), to ensure that public funds are properly
accounted for.  In recognition of the significant role that the Chief Financial Officer has in
relation to financial performance and the financial control environment, CIPFA has set out key
principles that define the core activities and behaviours that belong to the role.  These include,
being a key member of the Leadership Team, being actively involved in and influencing
decision making, and leading the delivery of good financial management across the whole
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organisation. The Council have appointed a Data Protection Officer in line with the
requirements of the UK-General Data Protection Regulations and the Data Protection Act
2018.
Covid Recovery Progress Report 2023/24
The Argyll and Bute Overarching Recovery Group (formed to lead this process with specific
thematic groups focused on Council recovery, building back stronger communities, economic
and social recovery, infrastructure and transportation, financial management and public
health) continues to have an overview of the Councils Covid Recovery Strategy and critical
themes, although the majority of the actions have either been completed or been
mainstreamed into other strategic or operational plans. Key updates are as follows:
a) Economic and Social Recovery: Issues and actions are incorporated within the
Councils Economic Strategy
b) Building Back Stronger Communities. Issues and actions are incorporated within the
Corporate Community Planning priorities
c) Our Modern Workspaces program. The Council have established hybrid working
across its activities and Our Modern Workspace project aims to look at how we use
offices on a town by town basis and take into account the needs of employees and
members of the public, as well as any opportunities for working more closely with
partners. Good progress is being made to develop Hub buildings and reducing heating
and maintenance costs and our huge portfolio of buildings.
d) The Joint Health Protection Plan, agreed by Argyll and Bute Council, Highland Council
and NHS Highland, sets out the public health arrangements for the management and
control of public health incidents and outbreaks, together with detailing our collective
public health priorities for 2023-25. 
FINANCIAL SUSTAINABILITY 
It is anticipated the Scottish public sector will continue to face a very challenging short and
medium term financial outlook with uncertainty over the level of Scottish Government
funding. The one year financial settlements do not provide any degree of medium term
certainty and ring-fencing of monies and additional policy commitments which are not always
fully funded limit financial flexibility and create additional financial pressures. 
In June 2023 the Verity House agreement was signed by representatives from Scottish Local
Government and Scottish Government which signified a shared vision for a more
collaborative approach to delivering our Services. This agreement included a commitment to
improve engagement on budgetary matters and provide more flexibility to Local Authorities
by baselining specific grants to allow them to be utilised on local priorities. It has been
disappointing to note that very little has changed in light of this agreement with no
engagement with Local Authorities prior to the Council Tax freeze announcement for 2024-
25. 
The financial outlook continues to be impacted by higher levels of inflation than pre-COVID
which results in significant price increases as well as ongoing disruptions to the supply chain
and longer lead in times. Tender prices are substantially higher than in previous years
meaning a reduced level of Service can be provided for the same amount of money. 
The Council continues to provide financial estimates for future years with their medium term
financial outlook covering a five year window to provide a longer term view of the Council’s
estimated budget gap. Preparing any forward looking financial outlook is challenging due to
the levels of uncertainty however the assumptions are reviewed regularly and updated with
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the outlook prepared to reflect a best case, worst case and mid-range scenario. 
The Council has a strong track record in financial management as recognised by previous
year’s annual external audit reports and the Council’s Best Value report issued in May 2020.
The Best Value report also recognises that the Council’s medium to long term financial
strategy helps support financial planning arrangements. In addition to providing revenue and
capital projections the Strategy also sets out the position in relation to the Council’s general
fund reserve, the approach to managing the financial impact of inflationary pressures,
approach to Treasury Management and the strategy to address budget gaps. 
HEALTH AND SOCIAL CARE INTEGRATION
The Argyll and Bute IJB has been established as a separate legal entity from Argyll and Bute
Council and NHS Highland, with its own board of governance.  The IJB comprises eight voting
members with four Elected Members nominated by Argyll and Bute Council and four Board
members from NHS Highland.  In addition there are a number of non-voting appointees
representing other sectors and stakeholder groups, such as the Third Sector, Independent
Sector, Patients and Service Users, Carers and Staff.  
The arrangements for the operation, remit and governance of the IJB are set out in the Argyll
and Bute Integration Scheme which has been prepared and approved by Argyll and Bute
Council and NHS Highland. It has also been approved by the Scottish Government. The IJB,
via a process of delegation from the Health Board and Local Authority as outlined in the
Scheme of Integration has responsibility for the planning, resourcing and operational delivery
of all health and social care services within Argyll and Bute.
The Council places reliance on the IJB’s framework of internal controls and similarly the IJB
places reliance on the procedures, policies and operational systems of the Council and the
Health Board. The IJB operates within an established procedural framework. The roles and
responsibilities of board members and officers are defined within Standing Orders, the
Integration Scheme, Financial Regulations and Standing Financial Instructions.
The IJB has proportionate internal audit arrangements in place to provide independent
assurance on risk management, corporate governance and the system of internal control.   A
risk based internal audit plan developed and commissioned for 2023/24 and the IJB’s internal
auditor has issued a formal annual report providing their independent opinion on the
effectiveness of the IJB’s risk management, internal control and governance processes. The
overall conclusion of the Internal Auditor is to provide a satisfactory level of assurance on the
adequacy of internal controls and governance arrangements within the IJB. 
During 2023-24 the IJB has progressed a number of initiatives to develop its governance
arrangements including improving the use of Directions and the implementation of the
integrated performance management system. It has also focused upon re-mobilising services
following the pandemic, refreshing its service transformation program and progressing
strategic development projects. It has focused on taking action to manage strategic risks
during the year. However, it is acknowledged that budgetary challenges have resulted in
some key capital projects and business case development work being paused.
The financial position of the HSCP has also remained stable. It repaid all of the debt it owed
to the Council in 2021/22 and reported an underspend against its approved budget in
2023/24. The operating environment going forward is very challenging as funding allocations
have not kept pace with cost and demand increases. The impact of an increasing older
population with on-going recruitment constraints and workforce shortages is adding to the
challenge. The HSCP is working to address its workforce gaps throughout the area and
across many professions in a variety of ways. For example, it is seeking to address key worker
accommodation shortages in partnership with the Council, Shelter and the Social Housing
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Sector and is constantly trying new approaches to attract workers from outside Argyll & Bute.
The new Health and Care Staffing act will also be progressively implemented throughout
2024/25 which places additional duties upon the IJB to monitor, manage and report upon its
staffing levels and risks. These risks and challenges are particularly acute in many of our rural
and island communities which are experiencing increasing costs along with very small scale,
lifeline services which are become ever more difficult to sustain or operate in a financially
efficient way. 
The IJB approved a budget for 2024/25 which indicates that additional funding from NHS
Highland may be required, although it is likely that any actual gap can be funded by the
allocation of HSCP reserves. The budget is also dependent upon the allocation of non-
recurring pension fund savings held by Argyll & Bute Council. The management of longer-
term financial sustainability is a priority and service change and transformation plans aimed
at addressing this require to be developed, consulted upon and implemented during the
course of 2024/25 and 2025/26. The delivery of the short term savings plan is a priority for
the HSCP particularly as it seeks to manage down spend on expensive agency and locum
staff whilst maintaining the safety of services.
UPDATE ON AREAS FOR DEVELOPMENT IDENTIFIED IN PREVIOUS ANNUAL
GOVERNANCE STATEMENTS
The 2022/23 Annual Governance Statement identified a number of areas for further
development. A summary update for each area is provided in the table below.
Area 2023/24 Update
Continue to engage with the Scottish
Government, other local authorities
and our Waste PPP contractor to
determine the most efficient and
effective way of ensuring the Council
can provide a waste solution which
complies with the 2025 Bio-
degradable Municipal Waste Ban 
We continue to pursue Scottish Government for either a
derogation or financial contribution of circa £1.5M to
enable the Waste PPP contract to be accommodated
alongside the 2025 BMW ban. At the time of writing (30
April 2024) we are still awaiting final confirmation from
Scottish Government although given the passage of time
we are now working on the basis that a derogation will not
be approved and are progressing discussions with Renewi
for MBT plants to be converted to Waste Transfer Stations
for use from January 2026 onwards, earlier if practical.
Further enhance reporting of
workforce planning to the Strategic
Management Team 
Workforce planning conversations took place with
Managers during January - March and operational
workforce plans are now being finalised for reporting to
SMT. Absence data is being included in the workforce
planning risk matrix to improve reporting to SMT. Progress
against actions outlined within operational workforce plans
will now be reported through regular Health of the
Organisation reporting to Department Management Teams
and SMT. The council approved its revised People
Strategy and updated strategic workforce planning
priorities in February. All strategic workforce planning
actions will be included in the annual People Strategy
delivery plan.
Continue to Improve quality and
accuracy of asset information which
will benefit asset valuations,
calculations for utilities costs and
asset management 
A further 57 condition surveys (7 within the school estate
and 50 within the non-school estate) and in accordance
with the Scottish Government’s Core Fact of Condition
were commissioned in 2023/24 and output will be delivered
in 2024/25. Additionally records were updated through
inspections and measurements undertaken as part of the
ongoing rolling programme of asset valuations.
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Develop data/analytics business
intelligence tool 
The council is taking a two-pronged approach to building
its capacity for business intelligence, within the framework
of its new data strategy and action plan (2024-28)
approved by SMT in October 2023:
a) Microsoft PowerBI – PowerBI is one of the
products in the Microsoft 365 (M365) productivity
suite and includes some familiar aspects of
Microsoft Excel but with much greater capacity to
combine and visualise data from multiple sources.
Since the council has a long-term plan for the
adoption and utilisation of M365 it is the logical tool
for data visualisation and analysis. 
b) The data platform – The “minimum viable product”
(MVP) version of this was launched on 26/3/24
and is now available for staff to use. The Data
Platform will be essential to allowing
“democratised” access to data for use in PowerBI
report building by services themselves. The Data
Platform will also allow for access to datasets to be
controlled and managed by a robust permissions
framework; ensure consistent application of data
quality, ethics and standards; and enable the FAIR
Principles of making data Findable, Accessible,
Interoperable and Re-usable. 
Complete review of performance
management 
Phase one of the Performance Excellence Project is now
complete with the following deliverables:
- Reduced set of Corporate Outcome Indicators to review
and report on long term trends and progress against
targets
- Decommissioning of Pyramid and development of new
Area Scorecards using MS365. 
- Development of a new Corporate Plan and Business Plan
setting out elected members overall priorities and the
activities and projects that will deliver on these.
- Design and Pilot of a new approach to Self-Assessment
which has been piloted at team level and thematic level. 
Phase Two of the project has been scoped and is now
underway. Phase two of the project will involve redesign
the council Performance Improvement Framework with
workstreams covering planning, design of performance
dashboards and the council's approach to public
performance reporting.
Complete the External Quality
Assessment Framework 
The External Quality Assessment was undertaken and
reported to the Audit and Scrutiny Committee. The findings
were that the Internal Audit service are fully compliant with
the Public Sector Internal Audit Standards in all 14 areas of
assessment. Two minor recommendations were made and
have been fully actioned. 
ISSUES FOR FURTHER DEVELOPMENT 
The review of governance and internal control has identified the following areas for
consideration during 2024/25, particularly in the context of continuous improvement within the
Council:
• Preparation for the implementation of the Visitor Levy in 2026 - Work with the Digital
Office, improvement Service, City of Edinburgh and Highland Council on the
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development of a new digital platform for the billing and collection of the new levy.
(Head of Financial Services/Head of Development and Economic Growth – March
2025).
• Preparation for new processes being implemented including the practice around
Initial Referral Discussions relating to child protection, there will be a need to audit
and develop practice further and the development of an action plan based on the
findings will help improvement and the need to consider the staffing structures which
support this vital area of work. (Head of Children, Families and Justice – March
2025)
• Housing Emergency declared by the Council in June 2023 - Utilise outputs from the
Housing Summit held, to develop a multi-stakeholder Action Plan, and synthesise
the relative elements of this into a revised Local Housing Strategy Action
Programme. (Head of Development and Economic Growth – March 2025)
• The revaluation of properties for building insurances purposes - Estates will
undertake a revaluation programme for the general portfolio, together with a
programme of recorded inspections of vacant properties. (Head of Commercial
services March 2025)
• Publication of the Annual Procurement Report for the Council – This will promote our
obligations set out in the Procurement Regulations. (Head of Legal and Regulatory
Support – March 2025)
• The Licensing Board will undertake a review of its Licensing Policy statement as
required in terms of the Licensing (Scotland) Act 2005. (Head of Legal and
Regulatory Support – March 2025)
• The use of Cloud Storage – Following results of the Internal Audit, put in place
actions to ensure optimum, appropriate and secure use of cloud storage is applied
across all applications. (Head of Customer Support Services – March 2025)
• Further enhance school engagement with national programmes and community
partnership approaches supporting young people to build their confidence, increase
mental health awareness and promote diversity. (Head of Education, Performance &
Improvement – March 2025).
CONCLUSION 
The conclusion from the review activity outlined above and our opinion is that reasonable
assurance can be placed upon the adequacy and effectiveness of Argyll and Bute Council’s
systems of internal control and governance. Although areas for further improvement have
been identified, the annual review demonstrates sufficient evidence that the Council’s Local
Code of Corporate Governance is operating effectively and that the Council complies with
that Local Code in all significant respects. Systems are in place to regularly review and
improve governance and systems of internal control.
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Annual Audit Plan
Argyll and Bute Council
Year ending 31 March 2024
Page 79
Agenda Item
8

Page 80

Contents
01 Engagement and responsibilities summary
02 Your audit engagement team
03 Audit scope, approach and timeline
04 Significant risks and other key judgement areas
05 Wider scope and Best Value
06 Fees for audit and other services
07 Our commitment to independence
08 Materiality and misstatements
Appendix A – Key communication points
Appendix B - Current year updates, forthcoming accounting and other issues
This document is to be regarded as confidential to Argyll and Bute Council. It has been prepared for the sole use of the Audit and Scrutiny Committee as the appropriate sub-committee
charged with governance. No responsibility is accepted to any other person in respect of the whole or part of its contents. Our written consent must first be obtained before this
document, or any part of it, is disclosed to a third party.
2
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Mazars LLP
26 Mosley Street
Newcastle upon Tyne
NE1 1DF
Audit and Scrutiny Committee
Argyll and Bute Council
Lochgilphead
Argyll
PA31 8RT
24 May 2024
Dear Audit and Scrutiny Committee Members
Annual Audit Plan – Year ending 31 March 2024
We are pleased to present our Audit Strategy Memorandum for Argyll and Bute Council for
the year ending 31 March 2024. The purpose of this document is to summarise our audit
approach, highlight significant audit risks and areas of key judgements and provide you
with the details of our audit team. As it is a fundamental requirement that an auditor is, and
is seen to be, independent of its clients, section 7 of this document also summarises our
considerations and conclusions on our independence as auditors. We consider two-way
communication with you to be key to a successful audit and important in:
• reaching a mutual understanding of the scope of the audit and the responsibilities of
each of us;
• sharing information to assist each of us to fulfil our respective responsibilities;
• providing you with constructive observations arising from the audit process; and
• ensuring that we, as external auditors, gain an understanding of your attitude and views
in respect of the internal and external operational, financial, compliance and other risks
facing Argyll and Bute Council which may affect the audit, including the likelihood of
those risks materialising and how they are monitored and managed.
With that in mind, we see this document, which has been prepared following our initial
planning discussions with management, as being the basis for a discussion around our
audit approach, any questions, concerns or input you may have on our approach or role as
auditor. This document also contains an appendix that outlines our key communications
with you during the course of the audit and forthcoming accounting issues and other issues
that may be of interest to you.
Providing a high-quality service is extremely important to us and we strive to provide
technical excellence with the highest level of service quality, together with continuous
improvement to exceed your expectations. If you have any concerns or comments about
this report or our audit approach, please contact me on 0191 383 6339.
Yours faithfully
Mark Outterside (Director)
Mazars LLP
Mazars LLP –  26 Mosley Street – Newcastle upon Tyne – NE1 1DF
Tel: 0191 383 6339 – www.mazars.co.uk
Mazars LLP is the UK firm of Mazars, an integrated international advisory and accountancy organisation. Mazars LLP is a limited liability partnership registered in England and Wales with registered number
OC308299 and with its registered office at 30 Old Bailey, London EC4M 7AU.
We are registered to carry on audit work in the UK by the Institute of Chartered Accountants in England and Wales. Details about our audit registration can be viewed at www.auditregister.org.uk under
reference number C001139861. VAT number: 839 8356 73
Annual Audit Plan – Year ending 31 March 2024
3
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Section 01:
Engagement and
responsibilities summary
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1. Engagement and responsibilities summary
Overview of engagement
We are appointed to perform the external audit of Argyll and Bute Council for the year to 31 March 2024. The scope of our engagement is set out in the Code of Audit Practice, issued by
the Auditor General and the Accounts Commission available from the Audit Scotland website: Code of audit practice | Audit Scotland (audit-scotland.gov.uk). Our responsibilities are
principally derived from the Local Government (Scotland) Act 1973 (the 1973 Act) and the Code of Audit Practice, as outlined below and overleaf.
Blank cell Engagement
area Responsibilities
Audit opinion
We are responsible for forming and expressing an independent opinion on whether the financial statements are prepared, in all material respects, in
accordance with all applicable statutory requirements. Our audit does not relieve management or the Audit and Scrutiny Committee, as Those Charged
With Governance, of their responsibilities.
The Section 95 Officer is responsible for the assessment of whether is it appropriate for the Council to prepare its accounts on a going concern basis. As
auditors, we are required to obtain sufficient appropriate audit evidence regarding, and conclude on:
a) whether a material uncertainty related to going concern exists; and
b) consider the appropriateness of the Section 95 Officer’s use of the going concern basis of accounting in the preparation of the financial statements.
Internal
control
Management is responsible for such internal control as management determines is necessary to enable the preparation of financial statements that are
free from material misstatement, whether due to fraud or error.
We are responsible for obtaining an understanding of internal control relevant to our audit and the preparation of the financial statements to design audit
procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the Council’s internal
control.
5
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1. Engagement and responsibilities summary
Overview of engagement (continued)
Blank cell Engagement
area Responsibilities
Fraud
The responsibility for safeguarding assets and for the prevention and detection of fraud, error and non-compliance with law or regulations rests with both
Those Charged With Governance and management. This includes establishing and maintaining internal controls over compliance with relevant laws and
regulations, and the reliability of financial reporting.
As part of our audit procedures in relation to fraud we are required to enquire of those charged with governance, including key management and internal
audit as to their knowledge of instances of fraud, the risk of fraud and their views on internal controls that mitigate the fraud risks. In accordance with
International Standards on Auditing (UK), we plan and perform our audit so as to obtain reasonable assurance that the financial statements taken as a
whole are free from material misstatement, whether caused by fraud or error. However, our audit should not be relied upon to identify all such
misstatements.
Wider
reporting
We report to the National Audit Office on the consistency of the Council’s financial statements with its Whole of Government Accounts (WGA)
submission. The level of auditor assurance required depends on monetary thresholds set by HM Treasury.
Wider scope
and Best
Value
We are also responsible for reviewing and reporting on the wider scope arrangements that the Council has in place and its arrangements to secure Best
Value.  We discuss our approach to wider scope and Best Value work further in section 5 of this report.
6
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Section 02:
Your audit engagement team
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mark.outterside@mazars.co.uk
07824 086 593
gregory.oduor@mazars.co.uk
07974 124 461
2. Your audit engagement team
Below is your audit engagement team and their contact details.
Mark Outterside
Engagement Leader
Gregory Oduor
Engagement Manager
alfred.mugani@mazars.co.uk
0781 569 0995
We will utilise Mazars experts on this engagement in the following area: valuation of property, plant and equipment.
8
Team Leader
Alfred Mugani
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Section 03:
Audit scope, approach and timeline
9
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3. Audit scope, approach and timeline
Audit scope
Our audit approach is designed to provide an audit that complies with all professional requirements.
Our audit of the financial statements will be conducted in accordance with International Standards on Auditing (UK), relevant ethical and professional standards, our own audit approach
and in accordance with the terms of our engagement. Our work is focused on those aspects of your activities which we consider to have a higher risk of material misstatement, such as
those impacted by management judgement and estimation, application of new accounting standards, changes of accounting policy, changes to operations or areas which have been found
to contain material errors in the past.
Audit approach
Our audit approach is risk-based, and the nature, extent, and timing of our audit procedures are primarily driven by the areas of the financial statements we consider to be more susceptible
to material misstatement. Following our risk assessment where we assess the inherent risk factors (subjectivity, complexity, uncertainty, change and susceptibility to misstatement due to
management bias or fraud) to aid in our risk assessment, we develop our audit strategy and design audit procedures to respond to the risks we have identified.
If we conclude that appropriately designed controls are in place, we may plan to test and rely on those controls. If we decide controls are not appropriately designed, or we decide that it
would be more efficient to do so, we may take a wholly substantive approach to our audit testing where, in our professional judgement, substantive procedures alone will provide sufficient
appropriate audit evidence. Substantive procedures are audit procedures designed to detect material misstatements at the assertion level and comprise tests of detail (of classes of
transaction, account balances, and disclosures), and substantive analytical procedures. Irrespective of our assessed risks of material misstatement, which takes account of our evaluation
of the operating effectiveness of controls, we are required to design and perform substantive procedures for each material class of transaction, account balance, and disclosure.
Our audit will be planned and performed so as to provide reasonable assurance that the financial statements are free from material misstatement and give a true and fair view. The concept
of materiality and how we define a misstatement is explained in more detail in section 8.
The diagram on the next page outlines the procedures we perform at the different stages of the audit.
10
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11
3. Audit scope, approach and timeline
Planning and Risk Assessment (April to May 2024)
• Planning visit and developing our understanding of the Council
• Initial opinion and wider scope risk assessments
• Risk identification and assessment
• Considering proposed accounting treatments and accounting
policies
• Developing the audit strategy and planning the audit work to
be performed
• Agreeing timetable and deadlines
• Risk assessment analytical procedures
• Determination of materiality
Interim (June to July 2024)
• Documenting systems and controls
• Performing walkthroughs
• Testing of IT general controls
• Reassessment of audit plan and revision if necessary
Fieldwork (July to October 2024)
• Receiving and reviewing draft financial statements
• Delivering our audit strategy starting with significant risks
and high-risk areas including detailed testing of
transactions, account balances and disclosures
• Communicating progress and issues
• Clearance meeting
Completion (December 2024)
• Final review and disclosure checklist of financial
statements
• Final director review
• Agreeing content of letter of representation
• Reporting to the Audit and Scrutiny Committee
• Reviewing subsequent events
• Signing the independent auditor’s report
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12
3. Audit scope, approach and timeline
Reliance on internal audit
We will meet with internal audit to discuss their work and findings, to inform our
understanding of the Council’s key business processes and to update our risk assessment. 
If appropriate, we will seek to place reliance on internal audit’s work on the Council's key
business processes and will perform our own procedures to determine its adequacy for our
audit.  During the audit, we will meet with internal audit to discuss the progress and findings
of their work prior to the commencement of our controls’ evaluation procedures.
Service organisations
International Auditing Standards (UK) (ISAs) define service organisations as third-party
organisations that provide services to the Council that are part of its information systems
relevant to financial reporting.  We are required to obtain an understanding of the services
provided by service organisations as well as evaluating the design and implementation of
controls over those services. We have not identified any relevant service organisations.
Management’s and our experts
Management makes use of experts in specific areas when preparing the Council’s financial
statements.  We also use experts to assist us to obtain sufficient appropriate audit evidence
on specific items of account.
Item of account Management’s
expert Our expert
Defined benefit
liability/Asset
Hymans Robertson
(Strathclyde
Pension
Fund)
We make use of PWC actuarial services
who
are commissioned by the NAO to review the
national analysis of pension trends and
assumptions of the various LGPS actuaries
Property, plant and
equipment
valuation
Council’s in-house
Valuer
We will review the analysis of property
valuation movements available from third
parties and consider the outcome of the
Council’s valuations in comparison with
these, challenging conclusions as
appropriate.
We have also engaged the
Mazars Property Valuation team to assist in
our valuations work, including a review the
Council’s DRC valuation methodology.
Financial
instrument
disclosures
Link Asset Services
(formerly Capita) No expert required.
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13
3. Audit scope, approach and timeline
Group audit approach 
The scope of our audit is based on an analysis of the risks we have identified at the group level. When scoping our audit, we have considered quantitative criteria (the contribution of the
group’s consolidated components to the group financial statements) and qualitative criteria (risks of material misstatement that consolidated components may present individually). A
further analysis will be performed on the other entities to verify they do not present any other risks. Where necessary, we will include some of these subsidiaries in our audit scope.
Our review of the group boundary is not complete; however, the nature and extent of audit work we expect to perform on the consolidated components is set out below:
Entity Identifier % Group
Expenditure Location Auditor Scope
Argyll and Bute
Council (parent) Parent – local authority 98.6% Kilmory, Lochgilphead,
Argyll, PA31 8RT Mazars LLP Full
Argyll and Bute
Integration Joint Board
Joint venture between the Council and NHS
Highland with responsibility for health and social
care functions.
0.3% Campbeltown PA28 6LE Mazars LLP Full
Dunbartonshire and
Argyll & Bute Valuation
Joint Board
Joint Board responsible for the maintenance of the
electoral, council tax and non-domestic rates
registers for Argyll and Bute, West Dunbartonshire
and East Dunbartonshire Councils.
0.3%
Kilbrannan House,
Bolgam St, Campbeltown
PA28 6JY
Mazars LLP Full
Live Argyll
100% owned subsidiary of the Council, which
provides a wide range of services within the area
including libraries, leisure facilities, halls, sports
development and community centres.
0.8%
Campbeltown
Aqualibrium. Kinloch
Road, Campbeltown,
Argyll PA28 6EG
Mazars LLP Specific
Common Good
Accounts
The Council administers the Common Good
Accounts for several former Burghs. -
Kilmory, Lochgilphead,
Argyll, PA31 8RT N/A N/A
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14
3. Audit scope, approach and timeline
Audit of trusts registered as Scottish charities
The Charities Accounts (Scotland) Regulations 2006 outline the accounting and auditing requirements for charitable bodies. The 2006 Regulations require charities to prepare annual
accounts and an auditor to prepare a report to the charity trustees where any legislation requires an audit.
The Local Government (Scotland) Act 1973 specifies the audit requirements for any trust fund where some or all members of a Council are the sole trustees. Therefore, a full and separate
audit and independent auditor’s report is required for each registered charity where members of the Council are sole trustees.
Members of the Council are the sole trustees for 7 trusts registered as Scottish charities, with total assets of circa £800,000. The preparation and audit of financial statements of registered
charities is regulated by the Charities and Trustee Investment (Scotland) Act 2005 and the Charities Accounts (Scotland) Regulations 2006.
We have not identified any significant risks, other than the risk of management override of controls which we have also identified as a risk for the Council’s annual accounts, for the financial
statements of the Council’s charitable trusts. Page 92

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Section 04:
Significant risks and other key
judgement areas
15
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4. Significant risks and other key judgement areas
Following the risk assessment approach discussed in section 3 of this document, we have
identified risks relevant to the audit of financial statements. The risks that we identify are
categorised as significant, enhanced or standard. The definitions of the level of risk rating
are given below:
Significant risk
A risk that is assessed as being at or close to the upper end of the spectrum of inherent risk,
based on a combination of the likelihood of a misstatement occurring and the magnitude of
any potential misstatement. A fraud risk is always assessed as a significant risk (as required
by auditing standards), including management override of controls and revenue recognition.
Enhanced risk
An area with an elevated risk of material misstatement at the assertion level, other than a
significant risk, based on factors/ information inherent to that area. Enhanced risks require
additional consideration but do not rise to the level of a significant risk. These include but
are not limited to:
• Key areas of management judgement and estimation uncertainty, including accounting
estimates related to material classes of transaction, account balances, and disclosures
but which are not considered to give rise to a significant risk of material misstatement;
and
• Risks relating to other assertions and arising from significant events or transactions that
occurred during the period.
Standard risk
A risk related to assertions over classes of transaction, account balances, and disclosures
that are relatively routine, non-complex, tend to be subject to systematic processing, and
require little or no management judgement/ estimation. Although it is considered that there is
a risk of material misstatement, there are no elevated or special factors related to the nature
of the financial statement area, the likely magnitude of potential misstatements, or the
likelihood of a risk occurring.
16
Summary risk assessment
The summary risk assessment, illustrated in the table below, highlights those risks which we
deem to be significant and other enhanced risks in respect of the Council.  We have
summarised our audit response to these risks on the next page.
Key:            Significant risk       Enhanced risk / significant management judgement
3
2
1
4
High
HighLow
Low
Likelihood
Financial
impact
1.  Management override of controls
2. Valuation of the net defined benefit
liability/Asset
3.  Valuation of property, plant and
equipment
4. Accounting for PFI and PPP contracts
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4. Significant risks and other key judgement areas
Specific identified audit risks and planned testing strategy
We have presented below in more detail the reasons for the risk assessment highlighted above, and also our testing approach with respect to significant risks. An audit is a dynamic
process, should we change our view of risk or approach to address the identified risks during the course of our audit, we will report this to the Audit and Scrutiny Committee.
Significant risks
Blank
cell Description Fraud Error Judgement Planned response
1 Management override of controls
This is a mandatory significant risk on all audits due to
the unpredictable way in which such override could
occur.
Management at various levels within an organisation
are in a unique position to perpetrate fraud because of
their ability to manipulate accounting records and
prepare fraudulent financial statements by overriding
controls that otherwise appear to be operating
effectively. Due to the unpredictable way in which such
override could occur there is a risk of material
misstatement due to fraud on
all audits.
We plan to address the management override of controls risk
through performing audit work over accounting estimates,
journal entries and significant transactions outside the normal
course of business or otherwise unusual.
We will address the risk through performing audit procedures
covering a range of areas including (but not limited to):
• accounting estimates included in the financial statements for
evidence of management bias;
• any significant transactions outside the normal course of
business; and
• journals and other adjustments recorded in the general
ledger in preparing the financial statements.
17
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4. Significant risks and other key judgement areas
18
Significant risks (continued)
Blank
cell Description Fraud Error Judgement Planned response
2 Valuation of the net defined benefit
(liability)/surplus
As at 31 March 2023, the net defined benefit surplus
was £139m (2022/23 - 4.6 Million). The valuation of the
Council’s net liabilities/assets includes use of discount
rates, inflation rates, mortality rates etc., all of which
should reflect the profile of the Council’s employees and
other appropriate data.
Due to the high degree of estimation uncertainty
associated with the valuations, we have determined
there is a significant risk in this area.
We will address this risk by reviewing the controls that the
Council has in place over the information sent to the Scheme
Actuary by the fund administrators (Strathclyde Pension Fund).
We will :
• challenge the reasonableness of the Actuary’s assumptions
that underpin the relevant entries made in the financial
statements;
• critically assess the competency, objectivity and
independence of the Actuary;
• liaise with the auditors of the Pension Fund to gain
assurance that the overall IAS19 procedures and controls in
place at the Pension Fund are operating effectively;
• compare assumptions to expected ranges; and
• agree data in the Actuary’s valuation report for accounting
purposes to the relevant accounting entries and disclosures
in the Council’s financial statements.
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4. Significant risks and other key judgement areas
19
Significant risks (continued)
Blank
cell Description Fraud Error Judgement Planned response
3 Valuation of property, plant and
equipment
The Council held land and buildings
(including council dwellings) with a net
book value of £451 million at 31 March
2023. The Council has adopted a rolling
revaluation model which sees other land
and buildings revalued over a five-year
cycle. This may result in individual assets
not being revalued for several years. This
creates a risk that the carrying value of
those assets that have been revalued in
year is materially different from the year
end fair value.
Valuations are based on specialist and
management assumptions and changes in
these can result in material changes to
valuations. Due to the high degree of
estimation uncertainty associated with
valuations, we have determined there is a
significant risk in this area.
We will address this risk through:
• assessing the scope and terms of engagement with the in-house Valuer;
• assessing the competence, skills and objectivity of the in-house Valuer;
• assessing how management use the in-house Valuer’s report to value land and
buildings included in the financial statements;
• testing the accuracy of the data used in valuations;
• challenging the Council and in-house Valuer’s assumptions and judgements
applied in the valuations;
• reviewing the valuation methodology used, including the appropriateness of the
valuation basis;
• considering the reasonableness of the valuation by comparing the valuation output
with market intelligence;
• testing a sample of revaluations in the year, by agreeing the revaluations recorded
in the Annual Accounts to the in-house valuer’s reports. As part of this testing, we
will check whether the movements have been accounted for in accordance with
the Code;
• challenging management’s assessment for those assets not subject to valuation in
the year;
• For those valued on Existing Use Value on a market comparable basis, we will
check market movements to assess the materiality of potential movement for
2023/24; and
• For those valued on a Depreciated Replacement Cost basis, which would be
impacted by changes in build costs during the year, we will test management’s
analysis of changes in the Build Costs Information Service (BCIS) index and
assess any decisions management make this regard.
We will engage the Mazars Real Estate Valuation Team to assist us with the above.
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4. Significant risks and other key judgement areas
Other key areas of management judgement and enhanced risks
Key areas of management judgement include accounting estimates which are material but are not considered to give rise to a significant risk of material misstatement. These areas of
management judgement represent other areas of audit emphasis.
20
Description Fraud Error Judgement Planned response
4 Accounting for PFI and PPP contracts
The Council currently operates three Private Finance Initiative
(PFI), or similar, contracts which are accounted for as Service
Concession arrangements under IFRIC12 – Service Concession
Arrangements.
The Council has determined that in the case of the Schools NPDO
contract and the new Schools DBFM contract, the Council has
control over the services provided through use of the schools and
that a qualifying asset has been created. Therefore, the assets are
included on the Council’s Balance Sheet along with a finance
lease liability.
The Council also operates a Waste Management PPP contract. In
this case the Council determined that a “qualifying asset” has not
been created and that the Council does not have significant
control over the services being provided. Therefore, the asset has
not been included on the Council’s Balance Sheet and payments
to the contractor are charged to the appropriate service line within
the Comprehensive Income and Expenditure Account.
The method of accounting for PFI and PP assets can be complex
and involves management judgement as set out in Note 3 to the
financial statements. Therefore, there is a potential risk of material
misstatement if the Council fails to appropriately account for these
assets.
We will:
• review the Council’s adopted approach for accounting
for its PFI arrangements;
• review any changes from prior years to the long-term
financial model used;
• critically review the assumptions made by
management; and
• assess the completeness and accuracy of disclosures.
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Section 05:
Wider scope and Best Value
21
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22
5. Wider scope and Best Value
The framework for wider scope work
The Code of Audit Practice sets out the four areas that frame the wider scope of public sector audit. We are required to form a view on the adequacy of the Council’s arrangements in four
areas:
1. Financial management
2. Financial sustainability
3. Vision, leadership, and governance
4. Use of resources to improve outcomes.
Financial
management
Financial management means having sound budgetary
processes. Audited bodies require the ability to understand
the financial environment and whether internal controls are
operating effectively.
Auditors consider whether the body has effective
arrangements to secure sound financial management.
Financial
sustainability
Financial sustainability means being able to meet the needs
of the present without compromising the ability of future
generations to meet their own needs.
Auditors consider the extent to which audited bodies have
shown regard to financial sustainability. They look ahead to
the medium term (two to five years) and longer term (over five
years) to consider whether the body is planning effectively so
that it can continue to deliver services.
Vision,
leadership and
governance
Audited bodies must have a clear vision and strategy and set
priorities for improvement within this vision and strategy. They
work together with partners and communities to improve
outcomes and foster a culture of innovation.
Auditors consider the clarity of plans to implement the vision,
strategy and priorities adopted by the leaders of the audited body.
They also consider the effectiveness of governance arrangements
for delivery.
Use of resources
to improve
outcomes
Audited bodies need to make best use of their resources to meet
stated outcomes and improvement objectives, through effective
planning and working with strategic partners and communities.
Auditors consider the clarity of the arrangements in place to
ensure that resources are deployed to improve strategic
outcomes, meet the needs of service users taking account of
equalities, and deliver continuous improvements in priority
services.
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23
5. Wider scope and Best Value
Our approach
Our planned audit work against the four wider scope areas is risk based and proportionate. We need to gather sufficient evidence to support our commentary on the Council’s
arrangements and to identify and report on any significant weaknesses. We will carry out more detailed work where we identify significant risks. Where significant weaknesses are
identified we will report these to the Council and make recommendations for improvement. In addition to local risks, we consider challenges that are affecting the public sector as a whole.
Best Value
Under the Code of Audit Practice, the audit of Best Value in councils is fully integrated within our annual audit work. Best Value at the Council will be assessed over the period of the audit
appointment. We will also follow up previously reported Best Value findings to assess the pace and depth of improvement. This work will be integrated into our audit approach, including
our work on the wider scope areas.
We will also conduct thematic reviews as directed by the Accounts Commission. In 2023/24 this will be on workforce innovation. We will prepare a separate management report to
document the findings of this work.
At least once every five years, the Controller of Audit will report to the Accounts Commission on the Council’s performance in meeting its Best Value duties. The Council is included in the
second year of the programme which runs from October 2024 to August 2025.
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24
5. Wider scope and Best Value
Wider scope risks
The Code of Audit Practice requires us to consider the significant audit risks in areas defined in the Code as the wider scope audit. 
Although we have not fully completed our planning and risk assessment work, the table below outlines the wider scope audit risks that we have identified to date.  We will report any
further identified risks to the Audit and Scrutiny Committee on completion of our planning and risk identification work.  
Bla
nk
cell Description Financial
management
Financial
sustainability
Vision,
leadership
and
governance
Use of
resources
to improve
outcomes
Planned procedures
1 Financial Sustainability
The 2024/25 budget highlighted a balanced
budget after measures to address the initial in-
year budget gap of £10.167m. However,  that
budget also highlighted a gap of £4.734m in
2025/26  rising to a cumulative budget gap of
£50.084m by the end of 2028/29 based upon a
‘midrange’ scenario. The Council’s ‘worst case’
scenario highlights a potential £187.840m
cumulative budget gap by the end of 2028/29.
There are also anticipated pressures on capital
planning, with a total gap in the capital
programme of £29.843m.
This represents a risk in relation to financial
sustainability, impacting on the future provision
of services in the Council’s area.
As part of our audit we will review the Council’s:
medium to long term financial strategy;
• financial position and track record in delivering
planned recurrent and non-recurrent savings in
2023/24;
• financial performance in 2024/25 and updates to its
financial planning during the year, including the
implications for general reserves balances;
• regular reporting to Members on financial
performance, savings plans and financial risks;
• progress in developing plans to address future years
budget gaps; and
• plans to address the gaps in the capital programme.
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Section 06:
Fees for audit and other services
25
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Fees for work as the Council’s appointed auditor
At this stage of the audit, we are not planning any divergence from the expected fees set
by Audit Scotland, which is available on the Audit Scotland website: Audit Scotland
expected fees for 2023/24 audits.
The impact of the non-audit services and the associated fees has been assessed as part
of our independence considerations (refer to section 7 of this report). OR We have not
provided any non-audit services to XXX during the year.
We will agree separately with the Council on the Fee for the Charitable Trusts for the
2023/24 audit (prior year £6,500). We have not provided any non-audit services to the
Charitable Trusts in 2023/24.
Services provided to other entities within the Council's group
In addition, to auditing the Council’s 7 charitable trusts, we are providing audit services to
the following entities in the Council's group:
• Argyll and Bute Integration Joint Board (total fee of £33,360)
• Dunbartonshire and Argyll & Bute Valuation Joint Board (total fee of £9,320).
• Live Argyll (estimated total fee for 2023/24 of £18,200).
6. Fees for audit and other services
Fees for audit and other services
Our fees for the audit of the Council’s financial statements for the year ended 31 March 2024 are outlined below.
Blank cell 2023/24 Proposed
Fee 2022/23 Actual Fee
Auditor remuneration £251,690 £237,440
Pooled costs £9,170 £0
Contribution to PABV costs £63,850 £57,770
Audit support costs £0 £9,000
Sectoral cap adjustment (£110) (£2,030)
Additional testing required to reflect the
transition to a new ledger in 202/23 0 £4,225
Total fee £324,600 £310,465
26
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Section 07:
Our commitment to independence
27
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7. Our commitment to independence
28
Requirements
We comply with the International Code of Ethics for Professional Accountants, including International Independence Standards issued by the
International Ethics Standards Board for Accountants together with the ethical requirements that are relevant to our audit of the financial statements in
the UK reflected in the ICAEW Code of Ethics and the FRC Ethical Standard 2019.
Compliance
We are not aware of any relationship between Mazars and Argyll and Bute Council Argyll and Bute Council that, in our professional judgement, may
reasonably be thought to impair our independence.
We are independent of Argyll and Bute Council and have fulfilled our independence and ethical responsibilities in accordance with the requirements
applicable to our audit.
Non-audit and
Audit fees
We have set out a summary any non-audit services provided by Mazars (with related fees) to Argyll and Bute Council in Section 6, together with our audit
fees and independence assessment.
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7. Our commitment to independence
We are committed to independence and confirm that we comply with the FRC’s Ethical Standard. In addition, we have set out in this section any matters or relationships we believe may
have a bearing on our independence or the objectivity of our audit team.
Based on the information provided by you and our own internal procedures to safeguard our independence as auditors, we confirm that in our professional judgement there are no
relationships between us and any of our related or subsidiary entities, and you and your related entities, that create any unacceptable threats to our independence within the regulatory or
professional requirements governing us as your auditors.
We have policies and procedures in place that are designed to ensure that we carry out our work with integrity, objectivity, and independence. These policies include:
• All partners and staff are required to complete an annual independence declaration.
• All new partners and staff are required to complete an independence confirmation and complete annual ethical training.
• Rotation policies covering audit engagement partners and other key members of the audit team.
• Use by managers and partners of our client and engagement acceptance system, which requires all non-audit services to be approved in advance by the audit engagement partner.
We confirm, as at the date of this report, that the engagement team and others in the firm as appropriate, Mazars LLP are independent and comply with relevant ethical requirements.
However, if at any time you have concerns or questions about our integrity, objectivity or independence, please discuss these with Mark Outterside in the first instance.
Prior to the provision of any non-audit services, Mark Outterside will undertake appropriate procedures to consider and fully assess the impact that providing the service may have on our
independence as auditor.
Principal threats to our independence and the associated safeguards we have identified and/ or put in place are set out in Framework Agreement issued by Audit Scotland available from
the Audit Scotland website: Audit Scotland Framework Agreement (audit-scotland.gov.uk). Any emerging independence threats and associated identified safeguards will be communicated
in our Annual Audit Report.
29
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Section 08:
Materiality and misstatements
30
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8. Materiality and misstatements
31
Definitions
Materiality is an expression of the relative significance or importance of a particular matter
in the context of the  financial statements as a whole.
Misstatements in the financial statements are considered to be material if they could,
individually or in aggregate, reasonably be expected to influence the economic decisions of
users based on the financial statements.
Materiality
We determine materiality for the financial statements as a whole (overall materiality) using
a benchmark that, in our professional judgement, is most appropriate to entity. We also
determine an amount less than materiality (performance materiality), which is applied when
we carry out our audit procedures and is designed to reduce to an appropriately low level
the probability that the aggregate of uncorrected and undetected misstatements exceeds
overall materiality. Further, we set a threshold above which all misstatements we identify
during our audit (adjusted and unadjusted) will be reported to the Audit and Scrutiny
Committee.
Judgements on materiality are made in light of surrounding circumstances and are affected
by the size and nature of a misstatement, or a combination of both. Judgements about
materiality are based on a consideration of the common financial information needs of
users as a group and not on specific individual users.
An assessment of what is material is a matter of professional judgement and is affected by
our perception of the financial information needs of the users of the financial statements. In
making our assessment we assume that users:
• Have a reasonable knowledge of business, economic activities, and accounts;
• Have a willingness to study the information in the financial statements with reasonable
diligence;
• Understand that financial statements are prepared, presented, and audited to levels of
materiality;
• Recognise the uncertainties inherent in the measurement of amounts based on the use
of estimates, judgement, and consideration of future events; and
• Will make reasonable economic decisions based on the information in the financial
statements.
We consider overall materiality and performance materiality while planning and performing
our audit based on quantitative and qualitative factors.
When planning our audit, we make judgements about the size of misstatements we consider to
be material. This provide a basis for our risk assessment procedures, including identifying and
assessing the risks of material misstatement, and determining the nature, timing and extent of
our responses to those risks.
The overall materiality and performance materiality that we determine does not necessarily
mean that uncorrected misstatements that are below materiality, individually or in
aggregate, will be considered immaterial.
We revise materiality as our audit progresses should we become aware of information that
would have caused us to determine a different amount had we been aware of that
information at the planning stage.
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8. Materiality and misstatements
Materiality (continued)
For the consolidated and parent financial statements, we consider that gross revenue
expenditure at surplus/deficit level is the key focus of users of the financial statements and, as
such, we base our materiality levels around this benchmark.
We expect to set a materiality threshold of 2% of gross revenue expenditure at surplus/deficit
level for the consolidated financial statements, and a materiality threshold of 2% of gross
revenue expenditure at surplus/deficit level for the parent company.
As set out in the tables alongside, based on currently available information, being the prior
period signed financial statements we anticipate overall materiality for the year ended 31 March
2024 to be in the region of £9.665 (£9.665m in the prior year), and performance materiality to
be in the region of £6,766m (£5.799m in the prior year).
For the Council, we anticipate overall materiality for the year ended 31 March 2024 to be in the
region of £9.529m (£9.529m in the prior year), and performance materiality to be in the region of
£6.670m (£5.717m in the prior year).
As set out in the tables overleaf, for Argyll and Bute Charitable Trusts, we anticipate overall
materiality for the year ended 31 March 2024 to be in the region of £15,359 (£15,359 in the prior
year), and performance materiality to be in the region of £10,751 (£9,215 in the prior year).
We will continue to monitor materiality throughout our audit to ensure it is set at an appropriate
level.
Consolidated financial statements
Blank cell 2023/24
£’000s
2022/23
£’000s
Overall materiality £9,665 £9,665
Performance
materiality £6,766 £5,799
Clearly trivial £290 £250
Specific
Materiality:
Remuneration
Report
£1 for senior councillors and senior
employees’ remuneration and pensions
benefits
1 banding for Employees’ remuneration
1 banding for exit packages
Council financial statements
Blank cell 2023/24
£’000s
2022/23
£’000s
Overall materiality £9,529 £9,529
Performance materiality £6,670 £5,717
Clearly trivial £286 £250
Specific Materiality:
Remuneration Report
£1 for senior councillors and senior
employees’ remuneration and pensions
benefits
1 banding for Employees’ remuneration
1 banding for exit packages
32
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8. Materiality and misstatements
Materiality (continued)
Argyll and Bute Charitable Trusts statements
Blank cell 2023/24 2022/23
Overall materiality £15,359 £15,359
Performance materiality £10,751 £9,215
Clearly trivial £461 £461
Specific Materiality: Remuneration
Report
£1 for senior councillors and senior
employees’ remuneration and pensions
benefits
1 banding for Employees’ remuneration
1 banding for exit packages
33
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8. Materiality and misstatements
Misstatements
We will accumulate misstatements identified during our audit that are above our determined
clearly trivial threshold. 
We have set a clearly trivial threshold for individual misstatements we identify (a reporting
threshold) for reporting to the Audit and Scrutiny Committee and management that is
consistent with a threshold where misstatements below that amount would not need to be
accumulated because we expect that the accumulation of such amounts would not have a
material effect on the financial statements. 
Based on our preliminary assessment of overall materiality, our proposed clearly trivial
threshold is £290k for the Group and £286k for the Council, based on 3% of overall
materiality. If you have any queries about this, please raise these with Mark Outterside.
Each misstatement above the reporting threshold that we identify will be classified as:
• Adjusted: Those misstatements that we identify and are corrected by management.
• Unadjusted: Those misstatements that we identify that are not corrected by
management.
We will report all misstatements above the reporting threshold to management and request
that they are corrected. If they are not corrected, we will report each misstatement to the
Audit and Scrutiny Committee as unadjusted misstatements and, if they remain
uncorrected, we will communicate the effect that they may have individually, or in
aggregate, on our audit opinion.
Misstatements also cover quantitative misstatements, including those relating to the notes
of the financial statements.
Reporting
In summary, we will categorise and report misstatements above the reporting threshold to
the Audit and Scrutiny Committee as follows:
• Adjusted misstatements;
• Unadjusted misstatements; and
• Disclosure misstatements (adjusted and unadjusted).
34
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A
35
Appendices
A: Key communication points
B: Current year updates, forthcoming accounting & other issues
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Appendix A: Key communication points
36
We value communication with Those Charged With Governance as a two way feedback
process at the heart of our client service commitment. ISA 260 (UK) ‘Communication with
Those Charged with Governance’ and ISA 265 (UK) ‘Communicating Deficiencies In
Internal Control To Those Charged With Governance And Management’ specifically require
us to communicate a number of points with you.
Relevant points that need to be communicated with you at each stage of the audit are
outlined below.
Form, timing and content of our communications
We will present the following reports:
• Our Annual Audit Plan; and
• Our Annual Audit Report.
These documents will be discussed with management prior to being presented to
yourselves and their comments will be incorporated as appropriate.
Key communication points at the planning stage as included in
this Annual Audit Plan
Our responsibilities in relation to the audit of the financial statements;
• The planned scope and timing of the audit;
• Significant audit risks and areas of management judgement;
• Our commitment to independence;
• Responsibilities for preventing and detecting errors;
• Materiality and misstatements; and
• Fees for audit and other services.
Key communication points at the completion stage to be included
in our Annual Audit Report
• Significant deficiencies in internal control;
• Significant findings from the audit;
• Significant matters discussed with management;
• Significant difficulties, if any, encountered during the audit;
• Qualitative aspects of the entity’s accounting practices, including accounting policies,
accounting estimates and financial statement disclosures;
• Our conclusions on the significant audit risks and areas of
management judgement;
• Summary of misstatements;
• Management representation letter;
• Our proposed draft audit report; and
• Independence.
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37
Appendix A: Key communication points
ISA (UK) 260 ‘Communication with Those Charged with Governance’, ISA (UK) 265 ‘Communicating Deficiencies In Internal Control To Those Charged With Governance And
Management’ and other ISAs (UK) specifically require us to communicate the following:
Required communication Where addressed
Our responsibilities in relation to the financial statement audit and those of management
and those charged with governance.
Annual Audit Plan
The planned scope and timing of the audit including any limitations, specifically including
with respect to significant risks.
Annual Audit Plan
With respect to misstatements:
• uncorrected misstatements and their effect on our audit opinion;
• the effect of uncorrected misstatements related to prior periods;
• a request that any uncorrected misstatement is corrected; and
• in writing, corrected misstatements that are significant.
Annual Audit Report
With respect to fraud communications:
• enquiries of the Audit and Scrutiny Committee to determine whether they have a
knowledge of any actual, suspected or alleged fraud affecting the entity;
• any fraud that we have identified or information we have obtained that indicates that
fraud may exist; and
• a discussion of any other matters related to fraud.
Annual Audit Report and discussion at Audit and Scrutiny Committee
Audit Planning and Clearance meetings
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38
Appendix A: Key communication points
Required communication Where addressed
Significant matters arising during the audit in connection with the entity’s related parties including,
when applicable:
• non-disclosure by management;
• inappropriate authorisation and approval of transactions;
• disagreement over disclosures;
• non-compliance with laws and regulations; and
• difficulty in identifying the party that ultimately controls the entity.
Annual Audit Report
Significant findings from the audit including:
• our view about the significant qualitative aspects of accounting practices including accounting
policies, accounting estimates and financial statement disclosures;
• significant difficulties, if any, encountered during the audit;
• significant matters, if any, arising from the audit that were discussed with management or were
the subject of correspondence with management;
• written representations that we are seeking;
• expected modifications to the audit report; and
• other matters, if any, significant to the oversight of the financial reporting process or otherwise
identified in the course of the audit that we believe will be relevant to the Council or the Audit and
Scrutiny Committee in the context of fulfilling their responsibilities.
Annual Audit Report
Significant deficiencies in internal controls identified during the audit. Annual Audit Report
Where relevant, any issues identified with respect to authority to obtain external confirmations or
inability to obtain relevant and reliable audit evidence from other procedures.
Annual Audit Report
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39
Appendix A: Key communication points
Required communication Where addressed
Audit findings regarding non-compliance with laws and regulations where the non-compliance is material and believed to be intentional
(subject to compliance with legislation on tipping off) and enquiry of the Audit and Scrutiny Committee into possible instances of non-
compliance with laws and regulations that may have a material effect on the financial statements and that the Audit and Scrutiny
Committee may be aware of.
Annual Audit Report and the Audit and
Scrutiny Committee meetings
With respect to going concern, events or conditions identified that may cast significant doubt on the entity’s ability to continue as a going
concern, including:
• whether the events or conditions constitute a material uncertainty;
• whether the use of the going concern assumption is appropriate in the preparation and presentation of the financial statements; and
• the adequacy of related disclosures in the financial statements.
Annual Audit Report
Reporting on the valuation methods applied to the various items in the annual Council and Group financial statements including any
impact of changes of such methods
Annual Audit Report
Communication regarding our system of quality management, compliant with ISQM 1, developed to support the consistent performance
of quality audit engagements. To address the requirements of ISQM (UK) 1, the firm’s ISQM 1 team completes, as part of an ongoing and
iterative process, a number of key steps to assess and conclude on the firm’s System of Quality Management:
• Ensure there is an appropriate assignment of responsibilities under ISQM1 and across Leadership
• Establish and review quality objectives each year, ensuring ISQM (UK) 1 objectives align with the firm's strategies and priorities
• Identify, review and update quality risks each quarter, taking into consideration of number of input sources (such as FRC / ICAEW
review findings, AQT findings, RCA findings, etc.)
• Identify, design and implement responses as part of the process to strengthen the firm's internal control environment and overall
quality
• Evaluate responses to identify and remediation process / control gaps
We perform an evaluation of our system of quality management on an annual basis. Our first evaluation was performed as of 31 August
2023. Details of that assessment and our conclusion are set out in our 2022/2023 Transparency Report, which is available on our
website here.
Annual Audit Plan
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40
Appendix A: Key communication points
Required communication Where addressed
Explanation of the scope of consolidation and the exclusion criteria applied by the entity to
the non-consolidated entities, if any, and whether those criteria applied are in accordance
with the relevant financial reporting framework.
Annual Audit Plan and/or Annual Audit Report as appropriate
Where applicable, identification of any audit work performed by component auditors in
relation to the audit of the consolidated financial statements other than by Mazars’ member
firms.
Annual Audit Plan and/or Annual Audit Report as appropriate
Indication of whether all requested explanations and documents were provided by the entity Annual Audit Report
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41
Appendix B: Current year updates, forthcoming accounting & other issues
Applicable for IFRS Reporters
Current and forthcoming accounting issue (continued)
New standards and amendments (continued)
Effective for accounting periods beginning on or after 1 January 2023
Amendments to IAS 1 Presentation of Financial Statements and IFRS Practice
Statement 2 Making Materiality Judgements: Disclosure of Accounting Policies
(Issued February 2021)
• The amendments set out new requirements for material accounting policy information to
be disclosed, rather than significant accounting policies. Immaterial accounting policy
information should not be disclosed as accounting policy information taken in isolation is
unlikely to be material, but it is when the information is considered together with other
information in the financial statements that may make it material.
Amendments to IAS 8 Accounting Policies, Changes in Accounting Estimates and
Errors: Definition of Accounting Estimates (Issued February 2021)
• The amendment introduces a new definition for accounting estimates and clarifies how
entities should distinguish changes in accounting policies from changes in accounting
estimates. The distinction is important because changes in accounting estimates are
applied prospectively only to future transactions and other future events, but changes in
accounting policies are generally applied retrospectively to past transactions and other
past events.
IFRS 17 Insurance Contracts (issued May 2017) and Amendments to IFRS 17
Insurance Contracts (Issued June 2020)
• IFRS 17 is a new standard that will replace IFRS 4 Insurance Contracts (IFRS 4). The
standard sets out the principles for the recognition, measurement, presentation and
disclosure about  insurance contracts issued, and reinsurance contracts held, by
entities.
Amendments to IFRS 17 Insurance Contracts: Initial Application of IFRS 17 and IFRS
9  Financial Instruments (Issued December 2021)
• The amendments address potential mismatches between the measurement of financial
assets and insurance liabilities in the comparative period because of different
transitional requirements in IFRS 9 and IFRS 17. The amendments introduce a
classification overlay under which a financial asset is permitted to be presented in the
comparative period as if the classification and measurement requirements of IFRS 9 had
been applied to that financial asset in the comparative period. The classification overlay
can be applied on an instrument-by-instrument basis.
IFRS 17 Insurance Contracts has not yet been adopted by the FReM. Adoption in the
FReM is expected to be from April 2025; early adoption is not permitted.
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42
Appendix B: Current year updates, forthcoming accounting & other issues
Applicable for IFRS Reporters
Current and forthcoming accounting issue (continued)
New standards and amendments (continued)
Effective for accounting periods beginning on or after 1 January 2024
The information detailed on this slide is for wider IFRS information only. They will be
subject to inclusion within the FReM and Code as determined by FRAB.
Amendments to IAS 1 Presentation of Financial Statements: Classification of
Liabilities as Current or Non-current (Issued January 2020), Deferral of Effective Date
(Issued July 2020) and Non-current Liabilities with Covenants (Issued October 2022)
• The January 2020 amendments clarify the requirements for classifying liabilities as
current or non-current in IAS 1 by providing clarification surrounding: when to assess
classification; understanding what is an ‘unconditional right’; whether to determine
classification based on an entity’s right versus discretion and expectation; and dealing
with settlements after the reporting date.
The October 2022 amendments specify how covenants should be taken into account in
the classification of a liability as current or non-current. Only covenants with which an
entity is required to comply with by the reporting date affect the classification as current
or non-current. Classification is not therefore affected if the right to defer settlement of a
liability for at least 12 months is subject to compliance with covenants at a date after the
reporting date. These amendments also clarify the disclosures about the nature of
covenants, so that users of financial statements can assess the risk that non-current
debts accompanied by covenants may become repayable within 12 months.
Amendments to IAS 16 Leases: Lease Liability in Sale and Leaseback (Issued
September 2022)
• The amendments include additional requirements to explain how to subsequently
measure the lease liability in a sale and leaseback transaction, specifically how to
include variable lease payments.
For further information, please refer to our blog article: Amendments to IFRS 16 Leases –
Lease Liability in a Sale and Leaseback
Amendments to IAS 7 Statement of Cash Flows and IFRS 7 Financial Instruments:
Disclosures: Supplier Finance Arrangements (Issued May 2023)
• The amendments introduce changes to the disclosure requirements around supplier
finance arrangements with the intention of providing more detailed information to help
users analyse and understand the effects of such arrangements.
The amendments provide an overarching disclosure objective to ensure that users of
financial statements are able to assess the effects of such arrangements on an entity’s
liabilities and cash flows, as well as some additional disclosure requirements relating to
the specific terms and conditions of the arrangement, quantitative information about
changes in financial liabilities that are part of the supplier financing arrangement, and
about an entity’s exposure to liquidity risk.
For further information, please refer to our blog article: IASB publishes final amendments
on supplier finance arrangements
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Mazars
Mazars is an internationally integrated partnership, specialising in audit, accountancy, advisory, tax
and legal services*. Operating in over 90 countries and territories around the world, we draw on the
expertise of 40,400 professionals – 24,400 in Mazars’ integrated partnership and 16,000 via the
Mazars North America Alliance – to assist clients of all sizes at every stage in their development.
*where permitted under applicable country laws.
Mark Outterside (Audit Director)
26 Mosley Street
Newcastle upon Tyne
NE1 1DF
Follow us:
LinkedIn:
www.linkedin.com/company/Mazars
Twitter:
www.twitter.com/MazarsGroup
Facebook:
www.facebook.com/MazarsGroup
Instagram:
www.instagram.com/MazarsGroup
WeChat:
ID: Mazars
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Page 123

ARGYLL AND BUTE COUNCIL     AUDIT AND SCRUTINY COMMITTEE 
CUSTOMER SUPPORT SERVICES     13 June 2024 
LOCAL GOVERNMENT BENCHMARKING FRAMEWORK (LGBF): 2022/23 
1.  INTRODUCTION
1.1 This report provides a high-level summary of Argyll and Bute’s performance as
reported in the Local Government Benchmarking Framework data.
1.2 The report also outlines work currently underway with regard to the LGBF and
how we may wish to use the data most effectively in the future. This work is
being carried out as part of the wider Performance Excellence Project. 
2. RECOMMENDATIONS
It is recommended that the Audit and Scrutiny Committee:
2.1 Considers the contents of this report and notes the trend of net improvement
across the council’s functions.
2.2 Notes the ongoing work being carried out as part of the wider Performance
Excellence Project. 
3. DETAIL
3.1 All Scottish Councils engage with the Local Government Benchmarking
Framework (LGBF), which is managed by the Improvement Service. The
purpose of the LGBF is to enable local authorities to improve their performance
through benchmarking and the sharing of good practice.
3.2 In an effort to produce more timely data, the Improvement Service has recently
made changes to its publication schedule. Its ambition is to improve the
timeliness of the LGBF data. Six indicators are now being updated monthly.
However, for the purposes of this report, data for the most recent full year for
which data is available (2022/23) has been used, with comparisons being made
with previous years.
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3.3 The number of indicators within the LGBF has grown over time from 55 in
2010/11 to the current 108 (see Appendix 1). The breadth of areas covered by
the indicators has also expanded and now encompasses the following service
areas.
• Corporate services
• Social Work services
• Culture and Leisure
• Environmental Services
• Housing Services. (Argyll and Bute does not submit any data in this
area.)
• Corporate Assets / property
• Economic Development
• Financial Sustainability
• Tackling Climate Change
3.4 The geography and demography of our area impact on indicators in a variety of
ways. For some indicators, we recognise we cannot improve our performance
relative to other councils (for example the cost of providing pre-school, primary,
and secondary education per pupil, and indicators relating to roads conditions,
where we consistently perform toward the bottom of the fourth quartile.)
3.5 Despite the caveats around our population profile and geography, the proportion
of indicators in the bottom performance quartile has been decreasing over time.
3.6 Figures 1 and 2 show an overall pattern of relative improvement in recent years,
with the percentage of our indicators in quartile 4 halving over the last five years.
The use of quartiles allows us to compare our performance with the other
Scottish local authorities.
3.7 The data needs to be treated with a degree of caution as it does not show
continuous improvement by individual indicators. Performance of a single
indicator may fluctuate from year to year; also the number of indicators reported
varies from year to year. Rather, the figures show the percentage of indicators
within each performance quartile to give a high-level overview of the council’s
performance relative to other local authorities. This profile of indicators has
shifted to suggest a pattern of relative improvement. Where our performance
falls within the quartiles 1 and 2, our performance is above the Scottish average.  
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Figure 1: Performance by quartile (2021/22 and 2022/23). 
Figure 2: Percentage of indicators in each LGBF performance quartile over the past
five years. 
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3.8 A comparison of the data for the years 2021/22 and 2022/23 shows that, for the
97 indicators for which comparison can be made:
• 34 indicators moved to a higher quartile, suggesting improved relative
performance.
• 34 indicators stayed within the same quartile.
• 29 indicators moved to a lower quartile, suggesting worsening relative
performance.
• Notably, 15 indicators moved out of quartile four, compared with 6
moving into that quartile, a net upwards movement of 9 indicators. (12
indicators were in quartile 4 in both years. These included the previously
mentioned indicators relating to cost of pre-school, primary and
secondary education per pupil and roads conditions.)
3.9 For further information about how councils are collectively performing across
Scotland, and how challenges facing local authorities have impacted on
performance, see the National Benchmarking Overview Report 2022-23.
3.10 For further information about performance for individual indicators and
comparisons with our ‘family groups’ of councils, see the Improvement Service’s
Local Government Benchmarking Framework Dashboard.
3.11  As part of the Performance Excellence Project, we have carried out a survey
with managers to understand how they use the LGBF. We are following this up
by considering how the LGBF may be used more effectively and efficiently, and
in conjunction with other benchmarking activity. This work will shape the
project’s final proposals around performance management arrangements.
3.12 To ensure future benchmarking activity aligns with the new administration’s
corporate plan and updated set of corporate outcomes/priorities, we need to
understand better which indicators are important to the council, and how these
can best be used. The need to focus on the indicators which are most
important to us is compounded by the increasing number of indicators within
the LGBF dataset.
3.13 We are mindful of the longstanding concerns around the sample size and
representativeness of satisfaction measures included in the LGBF. To address
these issues, we are developing our own survey which will enhance our
understanding of satisfaction with council services and allow for monitoring over
time. 
4.0 CONCLUSION
4.1 This report has outlined our performance position relative to other Scottish local
authorities as revealed by the Local Government Benchmarking Framework
data. Overall, the picture is a positive one, suggesting net overall improvements
in performance.
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4.2 Work to improve the effectiveness and efficiency of how we use the Local
Government Benchmarking Framework data as part of our wider benchmarking
activity will continue as part of the Performance Excellence Project. 
5.0 IMPLICATIONS
5.1 Policy: none arising directly from this report. 
5.2 Financial: none arising directly from this report.
5.3  Legal: none arising directly from this report.
5.4  HR: none arising directly from this report.
5.5  Fairer Scotland Duty: 
5.5.1   Equalities - protected characteristics: none arising from this report. An
EqSEIA is not required for performance reporting. 
5.5.2   Socio-economic Duty: none arising from this report. An EqSEIA is not
required for performance reporting. 
5.5.3  Islands none arising from this report. An EqSEIA is not required for
performance reporting.
5.6 Climate Change: none arising from this report.
5.7 Risk: none arising from this report.
5.8  Customer Service: none arising from this report.
5.9 The Rights of the Child (UNCRC): none arising from this report. 
Kirsty Flanagan
Executive Director with responsibility for Customer Support Services. 
Cllr Mark Irvine
Policy Lead for Community Planning and Corporate Services 
Report prepared: 17 May 2024 
For further information contact: 
Jane Fowler, Head of Customer Support Services
Chris Carr, OD Project Officer
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APPENDICES
Appendix 1: List of Local Government Benchmarking Framework indicators  
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Appendix 1: List of Local Government Benchmarking Framework indicators.
Indicator
Code Indicator Title Service Area
C&L01 Cost per attendance at Sports facilities Culture & Leisure Services
C&L02 Cost per Library Visit Culture & Leisure Services
C&L03 Cost per Museum Visit Culture & Leisure Services
C&L04 Cost of Parks & Open Spaces per 1,000 Population Culture & Leisure Services
C&L05a Proportion of adults satisfied with libraries Culture & Leisure Services
C&L05b Proportion of adults satisfied with parks and open spaces Culture & Leisure Services
C&L05c Proportion of adults satisfied with museums and galleries Culture & Leisure Services
C&L05d Proportion of adults satisfied with leisure facilities Culture & Leisure Services
CHN01 Cost per Primary School Pupil Children's Services
CHN02 Cost per Secondary School Pupil Children's Services
CHN03 Cost per Pre-School Education place Children's Services
CHN04 % of Pupils Gaining 5+ Awards at Level 5 Children's Services
CHN05 % of Pupils Gaining 5+ Awards at Level 6 Children's Services
CHN06
% of Pupils from 20% most Deprived Areas Gaining 5+ Awards
at Level 5 Children's Services
CHN07
% of Pupils from 20% most Deprived Areas Gaining 5+ Awards
at Level 6 Children's Services
CHN08a
Gross Costs of 'Children Looked After' in residential-based
services per child per week Children's Services
CHN08b
Gross Cost of "Children Looked After" in a community setting
per child per Week Children's Services
CHN09 Proportion of children being looked after in the community Children's Services
CHN10 Proportion of adults satisfied with local schools Children's Services
CHN11 Proportion of pupils entering positive destinations Children's Services
CHN12a Overall Average Total Tariff Children's Services
CHN12b Average Total Tariff SIMD Quintile 1 Children's Services
CHN12c Average Total Tariff SIMD Quintile 2 Children's Services
CHN12d Average Total Tariff SIMD Quintile 3 Children's Services
CHN12e Average Total Tariff SIMD Quintile 4 Children's Services
CHN12f Average Total Tariff SIMD Quintile 5 Children's Services
CHN13a
% of P1, P4 and P7 pupils achieving expected CFE level in
Literacy Children's Services
CHN13b
% of P1, P4 and P7 pupils achieving expected CFE level in
Numeracy Children's Services
CHN14a Literacy Attainment Gap (P1,4,7 Combined) Children's Services
CHN14b Numeracy Attainment Gap (P1,4,7 Combined) Children's Services
CHN17 Proportion of Children meeting developmental milestones Children's Services
CHN18
Proportion of funded early years provision which is graded
good/better Children's Services
CHN19a School attendance rates (per 100 pupils) Children's Services
CHN19b School attendance rates (per 100 'looked after pupils') Children's Services
CHN20a School exclusions rates (per 1,000 pupils) Children's Services
CHN20b School exclusions rates (per 1,000 'looked after pupils') Children's Services
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Indicator
Code Indicator Title Service Area
CHN21 Participation rate for 16-19 year olds (%) Children's Services
CHN22
Proportion of Child Protection re-registrations within 18
months Children's Services
CHN23 Proportion of LAC with more than 1 placement in the last year Children's Services
CHN24 Proportion of children living in poverty (after housing costs) Children's Services
CLIM01 CO2 emissions area wide per capita Tackling Climate Change
CLIM02
CO2 emissions area wide: emissions within scope of LA per
capita Tackling Climate Change
CLIM03 CO2 emissions from Transport per capita Tackling Climate Change
CLIM04 CO2 emissions from Electricity per capita Tackling Climate Change
CLIM05 CO2 emissions from Natural Gas per capita Tackling Climate Change
CORP01 Support services as a percentage of Total Gross expenditure Corporate Services
CORP03b
Proportion of the highest paid 5% of employees who are
women Corporate Services
CORP03c Gender pay gap (%) Corporate Services
CORP04 Cost per dwelling of collecting Council Tax Corporate Services
CORP06a Sickness absence days per teacher Corporate Services
CORP06b Sickness absence days per employee (non-teacher) Corporate Services
CORP07
Percentage of income due from Council Tax received by the
end of the year Corporate Services
CORP08 Percentage of invoices sampled that were paid within 30 days Corporate Services
CORP09 Proportion of SWF Crisis Grant decisions within 1 day Corporate Services
CORP10
Proportion of SWF Community Care Grant decisions within 15
days Corporate Services
CORP11 Proportion of SWF budget spent Corporate Services
CORP12 Proportion of DHP funding spent Corporate Services
CORP-
ASSET01
% of operational buildings that are suitable for their current
use Corporate Services
CORP-
ASSET02
% of internal floor area of operational buildings in satisfactory
condition Corporate Services
ECON01
Percentage of Unemployed People Assisted into work from
Council Programmes Economic Development
ECON02 Cost of Planning & Building Standards per planning application Economic Development
ECON03
Average time per business and industry planning application
(weeks) Economic Development
ECON04 Proportion of procurement spent on local enterprises Economic Development
ECON05 No of business gateway start-ups per 10,000 population Economic Development
ECON06
Investment in Economic Development & Tourism per 1,000
population Economic Development
ECON07 Proportion of people earning less than the living wage Economic Development
ECON08 Proportion of properties receiving Superfast Broadband Economic Development
ECON09 Town Vacancy Rates Economic Development
ECON10
Immediate available employment land as a % of total land
allocated for employment purposes Economic Development
ECON11 Gross Value Added (GVA) per capita Economic Development
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Indicator
Code Indicator Title Service Area
ECON12a Claimant Count as a % of Working Age Population Economic Development
ECON12b Claimant Count as % of 16-24 Population Economic Development
ENV01a Net cost per Waste collection per premises Environmental Services
ENV02a Net cost per Waste disposal per premises Environmental Services
ENV03a Net cost of street cleaning per 1,000 population Environmental Services
ENV03c Street Cleanliness Score Environmental Services
ENV04a Cost of roads per kilometre Environmental Services
ENV04b
Percentage of A class roads considered for maintenance
treatment Environmental Services
ENV04c
Percentage of B class roads considered for maintenance
treatment Environmental Services
ENV04d
Percentage of C class roads considered for maintenance
treatment Environmental Services
ENV04e
Percentage of unclassified roads considered for maintenance
treatment Environmental Services
ENV05
Cost of Trading Standards and environmental health per 1,000
population Environmental Services
ENV05a
Cost of Trading Standards, Money Advice & Citizens Advice
per 1,000 population Environmental Services
ENV05b Cost of environmental health per 1,000 population Environmental Services
ENV06 Proportion of total household waste arising that is recycled Environmental Services
ENV07a Proportion of adults satisfied with refuse collection Environmental Services
ENV07b Proportion of adults satisfied with street cleaning Environmental Services
FINSUS01
Total useable reserves as a % of council annual budgeted
revenue Financial Sustainability
FINSUS02
Uncommitted General Fund Balance as a % of annual
budgeted net revenue Financial Sustainability
FINSUS03
Ratio of Financing Costs to Net Revenue Stream - General
Fund Financial Sustainability
FINSUS04
Ratio of Financing Costs to Net Revenue Stream - Housing
Revenue Account Financial Sustainability
FINSUS05 Actual outturn as a percentage of budgeted expenditure Financial Sustainability
HSN01b
Gross rent arrears (all tenants) as a percentage of rent due for
the year Housing Services
HSN02 Proportion of rent due in the year that was lost due to voids Housing Services
HSN03
Proportion of council dwellings meeting Scottish Housing
Quality Standards Housing Services
HSN04b
Average number of days taken to complete non-emergency
repairs Housing Services
HSN05a Proportion of council dwellings that are energy efficient Housing Services
SW01 Home care costs per hour for people aged 65 or over Adult Social Care Services
SW02
SDS (DP + MPB) spend on adults as a % of total adult social
work spend  Adult Social Care Services
SW03a
% of people 65+ with long-term care needs who are receiving
personal care at home Adult Social Care Services
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Indicator
Code Indicator Title Service Area
SW04b
% of adults supported at home who agree that their services
and support had an impact in improving or maintaining their
quality of life Adult Social Care Services
SW04c
% of adults supported at home who agree that they are
supported to live as independently as possible Adult Social Care Services
SW04d
% of adults supported at home who agree that they had a say
in how their help, care or support was provided Adult Social Care Services
SW04e % of carers who feel supported to continue in their caring role Adult Social Care Services
SW05
Residential costs per week per resident for people aged 65 or
over Adult Social Care Services
SW06
Rate of readmission to hospital within 28 days per 1,000
discharges Adult Social Care Services
SW07 Proportion of adult care services graded good or better Adult Social Care Services
SW08
Number of days people spend in hospital when they are ready
to be discharged, per 1,000 population (75+) Adult Social Care Services 
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Audit & Scrutiny Committee Work Plan 2022 – 2023 
This is an outline plan to facilitate forward planning of reports to the Audit & Scrutiny Committee 
Report  Lead Service Regularity
13 June 2024 Reports to Committee Services by 20 May 2024
Internal Audit and Counter Fraud Summary of Activities Chief Internal Auditor Quarterly
Internal Audit Report Follow Up Chief Internal Auditor Quarterly
Internal Audit Reports to Audit and Scrutiny Committee  Chief Internal Auditor Quarterly 
Verbal Update by Chair(s) of Scrutiny Panel Chair and Vice Chair of Audit & Scrutiny
Committee  
Quarterly
Internal Audit 2024-25 Annual Report  Chief Internal Auditor Annual
Review of Code of Corporate Governance Governance, Risk and Safety Manager Annual
External Audit – 2024/25 Annual Plan Mazars Annual
Audit Strategy Memorandum Mazars Annual
Local Government Benchmarking Framework Report Head of Customer Support Services/HR & OD
Manager
Annual
Unaudited Financial Accounts Head of Financial Services Annual
Statement of Governance and Internal Control Governance, Risk and Safety Manager Annual
5 September 2024 Reports to Committee Services by 12 August 2024
Internal Audit and Counter Fraud Summary of Activities Chief Internal Auditor Quarterly
Internal Audit Report Follow Up Chief Internal Auditor Quarterly
Internal Audit Reports to Audit and Scrutiny Committee  Chief Internal Auditor Quarterly
External Audit Update  Mazars Quarterly
Verbal Update by Chair(s) of Scrutiny Panel Chair and Vice Chair of Audit & Scrutiny
Committee  
Quarterly
PSIAS Self-Assessment  Chief Internal Auditor Annual
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Agenda Item
11

Page 134

Audit & Scrutiny Committee Work Plan 2022 – 2023 
Corporate Complaints Annual Report 2024-25  Governance, Risk and Safety Manager Annual
Freedom of Information Annual Report 2024-25  Governance, Risk and Safety Manager Annual
Local Government in Scotland – Overview 2024 Audit Scotland (Lynsey to see if available and
download for agenda pack – see agenda June
2023)
Annual 
Audit & Scrutiny Committee 2024/25 Annual Report  Audit & Scrutiny Committee Chair Annual
Strategic Risk Register – Assurance Mapping Chief Internal Auditor Annual
Strategic Risk Register Update  Chief Executive Annual
External Audit 2024/25 Management Report Mazars Annual
Proposed Approach to Consultations Scrutiny Review Chief Internal Auditor One-off
Audit Scotland Digital Exclusion National Performance Audit Head of Customer Support Services (Audit
Scotland/Mazars)
One-off
17 December 2024 Reports to Committee Services by 22 November 2024
Internal Audit and Counter Fraud Summary of Activities Chief Internal Auditor Quarterly
Internal Audit Report Follow Up Chief Internal Auditor Quarterly
Internal Audit Reports to Audit and Scrutiny Committee  Chief Internal Auditor Quarterly
Audit Progress Report Mazars Quarterly
Verbal Update by Chair(s) of Scrutiny Panel Chair and Vice Chair of Audit & Scrutiny
Committee  
Quarterly
Performance Reporting Update (to include reference to LGBF) Chief Executive/Head of Customer Support
Services/HR & OD Manager
Quarterly
Council Annual Report 2024/25 Head of Customer Support Services Annual
13 March 2025 Reports to Committee Services by 17 February 2025
Internal Audit and Counter Fraud Summary of Activities Chief Internal Auditor Quarterly
Internal Audit Report Follow Up Chief Internal Auditor Quarterly
Internal Audit Reports to Audit and Scrutiny Committee 2024/25 Chief Internal Auditor Quarterly
Verbal Update by Chair(s) of Scrutiny Panel Chair and Vice Chair of Audit & Scrutiny
Committee  
Quarterly
RIPSA Annual Report Governance and Risk Manager Annual
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Audit & Scrutiny Committee Work Plan 2022 – 2023 
Internal Audit 2025/26 Plan Chief Internal Auditor Annual
2024/25 Unaudited Annual Accounts Preparation Plan and Timetable Head of Financial Services Annual
Treasury Management Strategy and Annual Investment Strategy Head of Financial Services Annual
Progress against Best Value Action Plan Update Chief Executive/Head of Customer Support
Services/HR&OD Manager
Annual
Internal Audit Charter and Internal Audit Manual Chief Internal Auditor Annual
Scrutiny Manual and Framework Update Chief Internal Auditor Annual
Audit Scotland Report – Financial Overview 2024/25  Head of Financial Services Annual 
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Page 137

ARGYLL AND BUTE COUNCIL  AUDIT AND SCRUTINY COMMITTEE 
FINANCIAL SERVICES  13 JUNE 2024 
INTERNAL AUDIT REPORTS TO AUDIT AND SCRUTINY COMMITTEE 2023/2024 
1. EXECUTIVE SUMMARY 
1.1 There are six 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
Financial Ledger Substantial 0 0 0 0
Learning and Physical Disability Care
Packages Reasonable 0 7 0 0
Scottish Social Services Council
(SSSC) Registration Substantial 1 1 4 0
Freedom of Information (FOI) High 0 0 4 0
Cloud Based Computer Services Substantial 0 4 1 0
Client Funds – Progress Review
(EXEMPT) Reasonable 0 3 0 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:   
Financial Ledger: 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. After
the initial delay of the start date, Fusion became operational in June 2022. Whilst
fully operational it is recognised that some functionality has been lost which was
previously available in Oracle EBS 12.1 resulting in the requirement to use
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manual interventions. However, it is reported that the manual interventions are
functioning well and in relation to time do not add significant additional work. All
feeder systems within the Financial Ledger are operating effectively. Interface
feeder system reports are run by the system administration team.  Cash and
debtors interface reports are produced every day, however, others are
generated when staff members process them – for example payroll (around the
same timings every month). OTBI (Oracle Transactional Business Intelligence)
Self Service is the replacement for Discoverer viewer. There is now no longer a
need to build reports as a standard set of reports are available for users,
although a number of users have full licences to allow them to write reports. 
Users of Fusion reported a more user friendly reporting tool, however,
commented that there had been a loss of some functionality which was available
in Discoverer Viewer. The work around for the loss of functionality now requires
manual processes. It was reported that whist it does create additional work, this
is not a time consuming job.   
Learning and Physical Disability Care Packages: this audit provided a
reasonable level of assurance. 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. Care Assessment policies and procedures are in place with a number of
key documents provided for review, although these may not refer current
practice and refer to Carefirst.  Assessment and Care Planning Procedures’ (V1)
details that the purpose of the policy, procedures and practice guidance is to
improve outcomes for service users and carers by providing clear guidance for
social work staff about assessment and planning with individuals. Case reviews
are undertaken when there are significant changes to the client’s care needs.
Children with Learning Disabilities are provided with a full care assessment
when they move to Adult Services.  We reviewed a 9% sample size of Learning
Disability high value care packages. Clients are assigned a case manager,
although heavy reliance is placed on the care providers reporting and updating
the case manager on a regularly basis. Where case managers were not
assigned, this was due to the allocated Social Worker moving on to different
positions and the case was assigned to the specific team for Learning Disability. 
Case notes are maintained on Eclipse, the replacement client database for
Carefirst.  It was noted that case notes were not always maintained and up to
date. A previous audit report highlighted the fact that client records were stored
in multiple locations, including on the Council’s network drive.  A Resource
Allocation framework is in place based on a prioritisation of needs process.  The
prioritisation of all referrals is based primarily on the information received at the
time of referral including any relevant background information held on
CareFirst/Eclipse and is prioritised according to risk. Roles and Responsibilities
are outlined in the various policies and procedures. The “Assessment and Care
Planning procedures” outlines the roles and responsibilities for each of the staff
categories. 
Scottish Social Services Council (SSSC) Registration: 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.  Policies, procedures and guidance are available to
support employees in their roles, however, some of these are overdue for review
or lack version control.  Recruitment follows a robust and consistent corporate
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process with a comprehensive induction programme in place, this includes
provision of guidance on expected conduct of employees in undertaking their
duties, there is no documentation regarding expected conduct of service users
towards employees.  SSSC registration status is regularly monitored by
managers and centrally by the Council’s HR team to identify any issues to be
addressed.  Training needs, SVQ progress and continuous professional
learning requirements are identified and discussed between managers and
employees and overseen by the Social Work Training Board, additionally,
feedback is gathered from service-users and employees to inform both
individual and service level improvement plans.   The supervision policy requires
a significant time commitment from all involved, is applied inconsistently across
care homes and contains no evidence of review since creation in 2011.  
Concerns raised regarding an employee’s fitness to practice are managed in
accordance with the SSSC Codes of Practice and Council policies with support
provided by the Council’s HR Officers. 
Freedom of Information: 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. The Council has
an overarching procedure note for the collection and response to Information
requests, this is published on the Council’s Intranet but is not up to date and
does not reflect current working practices. Mandatory training for all staff is
available on the LEON system, which also records and monitors completion.
Additional training is provided to designated Service FOI representatives, who
are responsible for ensuring that actions and correspondence in relation to the
request are logged on the tracking database. There is a Teams Channel where
FOI Service reps can access training and other materials. Key contact details,
on the Hub, for staff involved in the collection and response to Information
requests are not up to date. A review of the Council’s Publication scheme should
be undertaken, including checking that any links to information are still working.
The Compliance and Regulatory team provide monthly updates to the Chief
Executive, the Chief Officer, Directors, Heads of Service and the departmental
FOI reps. Quarterly reports are provided to all DMTs and on an annual basis to
the Audit and Scrutiny Committee. The information in the reports is clear and
relevant.  The recent addition of a second tab provides Senior Managers with a
detailed breakdown of the late responses and the reasons for such which further
highlight specific areas for improvement. To highlight the number of marginally
late responses, consideration should be given to including a more detailed
summary in reports to DMT/other relevant meetings.   
Cloud Based Computer Services:  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.  ICT and procurement teams assist services implement new systems
following robust due diligence processes.  Contracts and supporting
documentation reviewed contained details of arrangements for business
continuity, data recovery, change management and performance targets and
appropriate oversight takes place.  The ICT contracts application did not,
however, contain records pertaining to all systems contained on a list provided. 
Cloud service providers have measures in place to protect the Council’s data in
transit and at rest from unauthorised access, however multi-factor
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authentication (MFA) was not utilised for two systems reviewed, new users were
not appropriately authorised in three instances and leavers are not always
promptly notified to systems administrators.  Whilst the cloud service providers
have arrangements in place to ensure ongoing availability of services and
customer data, the Council also has responsibilities and as such has a
comprehensive overarching cyber-incident response plan in place.  Specific
cloud service disaster recovery plans/run books require to be prepared, updated
and/or finalised and tested. 
Client Funds – Progress Review (EXEMPT): 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 scope of the
audit was to undertake a high level review of the agreed actions for the
introduction and implementation of client fund accounts held on behalf of clients
who lack capacity, noting progress and providing a revised action plan and
dates for completion. The February 2023 report highlighted 8 high priority and
2 medium priority recommendations where there was scope to strengthen the
control and governance environment. There have been significant resources
deployed to enable the good progress so far, with 8 of the 10 recommendations
now complete, and the 2 delayed and rescheduled actions rely on input from
other services before they can be completed. There are 3 medium
recommendations arising from this review. Argyll and Bute Health and Social
Care Partnership (HSCP) have developed the Managing Service User’s Money
Policy which sets out detailed processes and underlying operational procedures
to ensure the management of client funds, however, these are not yet fully
operational. Amendments have been added to the contracts of 3rd party
providers of services in the community, recognising the need for providers to
maintain appropriate financial records for clients and create the right for the
Council to carry out independent reviews of records. A schedule for internal and
external independent reviews is being developed. There is now a SharePoint
site, which has been created to store information and records relating to the
financial management of clients’ funds in one location. 
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
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5.9 The Rights of the Child (UNCRC) – None 
Paul Macaskill
Chief Internal Auditor
13 June 2024 
For further information contact: 
Paul Macaskill, Chief Internal Auditor
Tel:  01546 604108
Email: paul.macaskill@argyll-bute.gov.uk 
APPENDICES 
1. Financial Ledger 
2. Learning and Physical Disability Care Packages 
3. Scottish Social Services Council (SSSC) Registration
4. Freedom of Information Requests
5. Cloud Based Computer Services – To Follow
6. Client Funds – High Level Progress Review 
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Argyll and Bute Council
Internal Audit Report
April 2024
FINAL 
High Medium Low VFM
Number of
Findings
0 0 0 0 
Financial Ledger
Audit Opinion: Substantial 
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2 
Argyll and Bute Council – Internal Audit Report – Financial Ledger, April 2024 
Contents 
1. Executive Summary ........................................................................................................................ 3
Introduction ............................................................................................................................................ 3
Background ............................................................................................................................................. 3
Scope ....................................................................................................................................................... 4
Risks ........................................................................................................................................................ 4
Audit Opinion ......................................................................................................................................... 4
Recommendations ................................................................................................................................. 4
2. Objectives and Summary Assessment ........................................................................................... 4
3. Detailed Findings ............................................................................................................................ 6
Appendix 1 – Audit Opinion ................................................................................................................. 10 
Contact Details 
Internal Auditor: Moira Weatherstone 
Telephone:  01546 604146 
e-mail:   moira.weatherstone@argyll-bute.gov.uk 
www.argyll-bute.gov.uk
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3 
Argyll and Bute Council – Internal Audit Report – Financial Ledger, April 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 the Financial Ledger. 
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 main purpose of a general ledger system is to record the financial activity of the council and
to produce financial and management reports to help council employees make decisions. Oracle
Fusion General Ledger enables its users to: 
 Record and review accounting information
 Enter journals to record actual entries directly into the General Ledger
 Review account balances online or through reports using OTBI and OTBI Self Service
 Analyse, correct, and adjust accounting information
 Use Oracle Fusion ADFDI (Application Development Framework Desktop Integration) to
upload journals 
5. The main system used by Financial Services to manage the General Ledger and Accounts Payable
functions was Oracle EBS 12.1.  Oracle ended support for this version of EBS in December 2021. 
For reasons of PSN and Cyber Essentials Plus compliance, and also broader cyber-security
protection of a business critical system the council depends on, it was not practical for Finance
to use this system beyond the end of June 2022. 
6. The new solution (Fusion) and consultancy were procured following the Councils Procurement
rules with Procurement being involved in the project from the start with contracts let with
Oracle for the solution and Evosys for the implementation services. 
7. OTBI (Oracle Transactional Business Intelligence) Self Service is the replacement for Discoverer
viewer. OTBI is accessed through the Fusion system which is the replacement for Oracle. 
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4 
Argyll and Bute Council – Internal Audit Report – Financial Ledger, April 2024
Scope 
8. The scope of the audit is a post implementation review to determine how the system is
operating paying particular attention to feeder systems, reporting functionality, procedures and
training as outlined in the Terms of Reference agreed with the Head of Financial Services on 15
December 2023. 
Risks 
9.  The risks considered throughout the audit were: 
 Audit Risk 1: Failure to ensure systems are operating effectively
 Audit Risk 2: Failure to ensure feeder systems are working effectively
 Audit Risk 3: failure to ensure that procedures are in place and staff are fully trained in
systems 
Audit Opinion 
10. 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 1 to this report. 
11. 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 
12. There are no recommendations as a result of this audit. 
13. 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 
14. 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 Fusion and
associated systems
are fully operational
Audit Risk 1:  Substantial Oracle ended support for EBS 12.1, the
General Ledger and Accounts Payable
system in December 2021.  For reasons
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5 
Argyll and Bute Council – Internal Audit Report – Financial Ledger, April 2024
with post
implementation
reviews being
undertaken
of PSN and Cyber Essentials Plus
compliance, and also broader cyber-
security protection of a business
critical system the council depends on,
it was not practical for Finance to use
this system beyond the end of June
2022 and therefore Fusion, the
replacement had to be in place and
fully operating by that date.  After the
initial delay of the start date, Fusion
became operational in June 2022.
Whilst fully operational it is recognised
that some functionality has been lost
which was previously available in
Oracle EBS 12.1 resulting in the
requirement to use manual
interventions. However, it is reported
that the manual interventions are
functioning well and in relation to time
do not add significant additional work.
2 Feeder systems
within the Financial
Ledger are operating
effectively and in a
timely manner
Audit Risk 2  Substantial All feeder systems within the Financial
Ledger are operating effectively.
Interface feeder system reports are
run by the system administration
team.  Cash and debtors interface
reports are produced every day,
however, others are generated when
staff members process them – for
example payroll (around the same
timings every month). Reports are
checked by the system administration
team to ensure that they are
successful.  Payables is checked by the
Creditors Supervisor.  
3 Reporting systems
within the Financial
Ledger are
functioning
effectively
Audit Risk 1 Substantial OTBI (Oracle Transactional Business
Intelligence) Self Service is the
replacement for Discoverer viewer.
OTBI is accessed through the Fusion
system. Running reports on OBTI is
very different to Discoverer Viewer.
There is now no longer a need to build
reports as a standard set of reports are
available for users, although a number
of users have full licences to allow
them to write reports.  Users of Fusion
reported a more user friendly
reporting tool. However, commented
that there had been a loss of some
functionality which was available in
Discoverer Viewer. The work around
for the loss of functionality now
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Argyll and Bute Council – Internal Audit Report – Financial Ledger, April 2024
requires manual processes. The main
report run is year to date budget v
actual. Although not as simple as
Discoverer Viewer in terms of the
ability to produce a report that shows
controllable costs only, it still is
considered an effective reporting tool.
4 Procedures are in
place and relevant
training has been
provided to staff
Audit Risk 3 High Training sessions were delivered by
Evosys. Further training was provided
through peer support as required. In
addition training was backed up by
manuals/guides provided by Evosys,
however these have been amended to
make them more focussed for Council
staff to use.   
15. Further details of our conclusions against each control objective can be found in Section 3 of this
report.   
3. Detailed Findings 
Fusion and associated systems are fully operational with post implementation reviews being
undertaken 
16. Oracle ended support for EBS 12.1, the General Ledger and Accounts Payable system in
December 2021.  For reasons of PSN and Cyber Essentials Plus compliance, and also broader
cyber-security protection of a business critical system the council depends on, it was not
practical for finance to use this system beyond the end of June 2022 and therefore Fusion, the
replacement had to be in place and fully operating by that date.  After an initial delay in the start
date, Fusion became operational in June 2022. 
17. All functions have been moved over to Oracle Fusion, a supported platform which receives
quarterly updates. All interfaces were in place, after being tested when Fusion went live in June
2022. Some issues were found after go live, but these have been resolved. All usual regular
processes have been checked, including monthly processes. 
18. Whilst the system is functioning well and users continue to adapt to Fusion it has not fully
delivered on the expectations the users may have had in terms of delivering efficiencies.  A small
number of the processes that could previously be undertaken by Oracle EBS 12.1 are no longer
supported on Fusion resulting in additional work through manual interventions.   
19. Fusion doesn’t allow staff to build the Council’s support service model based on Budgets, this
now requires manual intervention with the use of spreadsheets to run the model. It is noted that
at present Fusion cannot be adjusted to run the support service model and that the manual
interventions are reported to be working well.   
20. Fusion has all appropriate accounts payable processes in place and is able to pay all due
accounts.  However, it was highlighted that there were ongoing issues with recurring payments
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Argyll and Bute Council – Internal Audit Report – Financial Ledger, April 2024
and whereby Oracle EBS 12.1 was able to process these, Fusion requires monthly intervention to
complete the process.  This functionality is currently being reviewed in order to find appropriate
solutions. 
21. During the course of the audit we met with users of the system from various sections in Financial
Services, including Creditors staff.  It was highlighted by staff that there were a number of issues
identified due to the fact that Fusion does not work the same way Oracle EBS 12.1. However, all
reported satisfactory work around solutions.   
22. An end of project report was issued in November 2022, by the Project Leaders to the Project
Board.  This report highlighted what went well with project, how the project performed against
the PID, including the planned budget costs, schedule and any defined tolerances. It also covered
any changes which were agreed during the life of the project. In addition there were identified
follow-up action points and lessons learned.  It was noted that there were a few action points
still to be concluded. 
Feeder systems within the Financial Ledger are operating effectively and in a timely manner 
23. All feeder systems within the Financial Ledger are operating effectively, interface feeder system
reports are run by the system administration team.  Cash and debtors interface reports are
produced every day, however, others are generated when staff members process them – for
example payroll (around the same timings every month). Reports are checked by the system
administration team to ensure that they are successful.  Payables is checked by the Creditors
Supervisor. 
24. Work on Fusion is undertaken as part of the continuous monitoring programme and reliance is
placed on this with reports being reviewed as part of this audit. 
Reporting systems within the Financial Ledger are functioning effectively 
25. OTBI (Oracle Transactional Business Intelligence) Self Service is the replacement for Discoverer
viewer. OTBI is accessed through the Fusion system. Running reports on OBTI is very different to
Discoverer Viewer. There is now no longer a need to build reports due to the fact that there are
a standard set of reports are available for users, although a number of users have full licences to
allow them to write reports.  Users of Fusion reported a more user friendly reporting tool. 
26. The main report run is year to date budget v actual. Although not as simple as Discoverer Viewer
in terms of the ability to produce a report that shows controllable costs only, it still is considered
an effective reporting tool.  Reports written using the hierarchies were originally written by
EVOSYS and adapted by the Council’s internal IT and present staff do not have the ability to
write new ones at this point in time. It may be possible in the future to get a report written
which only shows controllable costs however as it stands at the current time this would require
IT resource and is not a priority at this time. OTBI reports don’t allow us to report on the
hierarchies. With the lack of ability to run a report showing only the controllable costs the
reports now require ‘lookups’ and pivot tables. It was reported that whist it does create
additional work, this is not a time consuming job.   
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Procedures are in place and relevant training has been provided to staff 
27. A procurement exercise was undertaken to then find an implementation partner to support the
process during the setup, go live and post go live. The contract being awarded to Evosys.
Training sessions were delivered by Evosys. Further training was provided through peer support
as required.  Additionally, training for users was provided by internal staff. 
28. Training was backed up by manuals / guides provided by Evosys, however these have been
amended to make them more focussed for Council staff to use.
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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 1 – 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. 
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Argyll and Bute Council
Internal Audit Report
April 2024
FINAL 
High Medium Low VFM
Number of
Findings
0 7 0 0 
Learning and Physical
Disability Care Packages 
Audit Opinion: (Reasonable) 
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Contents 
1. Executive Summary ........................................................................................................................ 3
Introduction ............................................................................................................................................ 3
Background ............................................................................................................................................. 3
Scope ....................................................................................................................................................... 4
Risks ........................................................................................................................................................ 4
Audit Opinion ......................................................................................................................................... 4
Recommendations ................................................................................................................................. 5
2. Objectives and Summary Assessment ........................................................................................... 5
3. Detailed Findings ............................................................................................................................ 7
Appendix 1 – Action Plan ..................................................................................................................... 12
Appendix 2 – Audit Opinion ................................................................................................................. 16 
Contact Details 
Internal Auditor: Moira Weatherstone 
Telephone:  01546 604146 
e-mail:   moira.weatherstone@argyll-bute.gov.uk 
www.argyll-bute.gov.uk
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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 Learning and Physical Disability Care Packages. 
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. Learning Disability services provide essential person centred support for individuals by helping
people with learning disabilities and complex conditions to access and continue education and
development, paid employment opportunities, life skills development and meaningful activities,
achieve their desired outcomes and become more involved in their communities. They also
promote and support independent living skills. 
5. Providing effective support for people with learning in ways that address their personal
outcomes is a priority for the HSCP.  However, with a shrinking population, recruitment and
retention of health and social care staff and rurality of Argyll and Bute, this presents many
challenges to the delivery of services. Whenever possible, the HSCP support people to live
healthily and well within their local communities, with their families and friends.   
6. Care Management is a term applied to an approach to intervention whereby a professionally
qualified social work officer undertakes assessment, planning, monitoring and reviewing activity.
The assessment process for services involves engaging and communicating with individuals to
identify their strengths, needs, risks, capacity and aspirations with a view to determining how
social work intervention could assist in meeting desired outcomes. Central to the process is the
collation, analysis and interpretation of information. This approach has a strong focus on
managing risk, the use of specific interventions and /or significant complexity will exist e.g. legal
matters. It is only applicable to people who are most vulnerable, have complex or frequently
changing needs or who present public protection concerns.   
7. There are approximately 377 Adults living with a learning disability and/or autism spectrum
diagnosis known to Argyll & Bute Health and Social Care Partnership (HSCP) within Argyll and
Bute. Both nationally and locally the number of people with learning disabilities living into older
age is increasing, with many presenting with a diverse range of complex and multiple
interrelated health conditions. This growing population with complex health needs brings about
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new challenges for health professionals and social care services. The planning and provision of
quality health and social care is crucial to improving the health and quality of life of people with
learning and physical disabilities across Argyll and Bute.  In addition the Council faces challenges,
particularly in more rural locations due to the limited number of care providers who are able to
provide the required services. 
8. A defined amount of money is set aside in the budget for the provision of care services and
resources are allocated according to a priority of needs.  There are currently 63 Learning
Disability/Physical Disability and Mental Health packages in excess of £100k per year and for the
financial year ended 31 March 2023 this amounted to approximately £9.190m, just under half of
the overall £20.206m spent on care packages in 2022/23. 
9. There are currently 50 individuals placed out with Argyll and Bute with care packages totalling
approximately £5 million per annum.  Compared to a number of other local authorities there is
likely to be a higher number of out of area placements due to the lack of service provision across
the Council’s remote and rural geographic area.   
Scope 
10. The scope of the audit was to review of the management and governance of learning disability
high cost packages as outlined in the Terms of Reference agreed with the Head of Adult Services
(Mental Health, Acute and Complex Care) on 30 August 2023. 
Risks 
11.  The risks considered throughout the audit were: 
 SRR07:  Failure of the HSCP to deliver on its Strategic Priorities results in deteriorating
health and wellbeing outcomes for the population and / or reduced access to appropriate
health and social care services. This could also result in financial and reputational risk to
the Council
 Audit Risk 1: Failure to meet our statutory requirements
 Audit Risk 2: Failure to provide an effective assessment and review process
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 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. 
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Recommendations 
14. We have highlighted 7 medium priority recommendations where we believe there is scope to
strengthen the control and governance environment. These are summarised below:
 Policies and procedures should be reviewed to ensure they are up to date, relevant and
reflect the new practices within Eclipse;
 An induction pack is in the process of being developed and this will include an
introduction to policies and procedures. The induction pack should be completed and
circulated to all new staff;
 Staff should be reminded of the importance of keeping case notes and contact notes up
to date;
 Client records should be maintained in a consistent way across the Council, minimising
the number of locations where records are maintained. The Business Case for the roll
out of the client record keeping project onto CIVICA, with links provided in Eclipse
should be implemented;
 Robust measures should be put in place for the decision making processes for allocating
resources for Learning Disability Care packages, including processes for recording those
decisions;
 Systems, processes and commissioning contracts must be put in place to ensure the
equity of access to personal care services for Learning Disability Services;
 A robust system of identifying and recording unmet needs with regards to Learning
Disability clients should be put in place. 
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 Care Assessment
policies and
procedures are in
place
SRR07
Audit Risk 1
Audit Risk 2
Reasonable Care Assessment policies and
procedures are in place with a number
of key documents provided for review,
although these may not refer current
practice and refer to Carefirst. 
Assessment and Care Planning
Procedures’ (V1) details that the
purpose of the policy, procedures and
practice guidance is to improve
outcomes for service users and carers
by providing clear guidance for social
work staff about assessment and
planning with individuals. This
guidance applies to community
services service users and is applicable
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across all settings. An induction pack is
in the process of being developed and
this will include an introduction to
policies and procedures.
2 All cases have been
assigned a Case
Manager and case
reviews are being
undertaken in
accordance with
policies and
procedures
Audit Risk 2 Reasonable High value care packages generally
relate to those who require lifelong
support either in a residential setting
or supported within their communities,
therefore there is very little change to
their care packages. Both nationally
and locally the number of people with
learning disabilities living into older
age is increasing, with many presenting
with a diverse range of complex and
multiple interrelated health conditions.  
Case reviews are undertaken when
there is significant changes to the
client’s care needs. Children with
Learning Disabilities are provided with
a full care assessment when they move
to Adult Services.  We reviewed a 9%
sample size of Learning Disability high
value care packages. Clients are
assigned a case manager, although
heavy reliance is placed on the care
providers reporting and updating the
case manager on a regularly basis.   
Where case managers were not
assigned, this was due to the allocated
Social Worker moving on to different
positions and the case was assigned to
the specific team for Learning
Disability.  Case notes are maintained
on Eclipse, the replacement client
database for Carefirst.  It was noted
that case notes were not always
maintained and up to date. A previous
audit report highlighted the fact that
client records were stored in multiple
locations, including on the Council’s
network drive.  Evidence obtained
during the audit suggests that client
records are still being maintained on
the network drive with historical
records stored in orange client files. A
pilot project in the Mid Argyll area was
undertaken to scan records onto
CIVICA, which would have links from
Carefirst (now Eclipse). 
3 Resources are
allocated in
SRR07
Audit Risk 1
Reasonable A Resource Allocation framework is in
place based on a prioritisation of needs
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accordance with
policies and
procedures and
reviewed on a
regular basis
process.  The prioritisation of all
referrals is based primarily on the
information received at the time of
referral including any relevant
background information held on
CareFirst/Eclipse and is prioritised
according to risk. We were provided
with a Terms of Reference for the
“Adult Care Allocation Group (ACAG)”.
The main objective for the group is to
review and approve total cost
packages for both existing and new
cases over 29 hours per week.
However, we were advised that this
group has been suspended as it was
felt there was no added value to
having a single ACAG as the majority of
Learning Disability care packages were
already over the threshold, and the
wider ACAG members had no expertise
or input in Learning Disability. In
addition, how and where the decisions
on resource allocations are taken and
recorded has not yet been confirmed.
Due to the pressures commissioning,
Learning Disability have requested that
a small number of packages be placed
on the unmet need/waiting list for
Care at Home services where they
require personal care only. This has not
yet been agreed by management and
at present there is no overview of the
total unmet need and available
resources across each of the localities,
we have been advised that services are
working in silos.
4 Roles and
responsibilities have
been documented
and assigned
Audit Risk 2 Substantial Roles and Responsibilities are outlined
in the various policies and procedures.
The “Assessment and Care Planning
procedures” outlines the roles and
responsibilities for each of the staff
categories. 
17. Further details of our conclusions against each control objective can be found in Section 3 of this
report.   
3. Detailed Findings
Care Assessment policies and procedures are in place 
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18. Care Assessment policies and procedures are in place with a number of key documents provided
for review, however, these may not refer current practice and make reference to Carefirst (the
Council’s client record management system), which has now been replaced by Eclipse. 
19. Assessment and Care Planning Procedures’ (V1) details that the purpose of the policy,
procedures and practice guidance is to improve outcomes for service users and carers by
providing clear guidance for social work staff about assessment and planning with individuals.
This guidance applies to community services service users and is applicable across all settings. It
states that it should be adopted by all staff. 
20. The Assessment and Care Planning Procedures (V1) covers a broad range of information from
descriptions of terminology, explanations of care management and what it should achieve,
approaches to monitoring and review, team review, service co-ordination.  It documents the
procedures to be followed from the referral stage in the process. It advises what information
should be recorded and how it should be recorded on Carefirst, including how ongoing records
are maintained. An additional policy: Recording & Reflective Practice Policy, Procedures &
Standards was available to review. The aim of this document is to provide clear and concise
information which outlines the approach to recording and reflective practice by the Social Work
service. 
21. A further policy entitled “Funding High Cost Care at Home Packages Procedural Guidance for
Staff and Managers” was available for review.  This is Version 2, dated December 2021. It details
that the eligibility criteria for service is based on the identified needs of the assessment matched
to the prioritisation framework.     
Action Plan 1 
22. Staff have access to relevant policies and procedures, including access to relevant training. All
staff have a session with the Carefirst/Eclipse support team to learn to navigate their way
through the systems. There are guidance notes available on SharePoint and a generic email
address for any requests for support staff may have. The Learning Disability Day Services/
Resource Centres redesign resulted in an action plan being drawn up, this included a training
plan being identified. 
23. We were advised that over the years, the finance team have provided advice and guidance on
the management of budgets for packages, mainly for Team Managers.  From a Social Work
perspective, training on Self Directed Support has been delivered and this is as and when
required. This focuses on outcomes for individuals and how those outcomes are being met. 
24. An induction pack is in the process of being developed and this will include an introduction to
policies and procedures. There is an expectation that trained staff will know the theories behind
assessment, review and legislation, however, the induction process will assist new staff
members to understand the systems and processes within the Council. 
Action Point 2
All cases have been assigned a Case Manager and case reviews are being undertaken in
accordance with policies and procedures 
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25. High value care packages generally relate to those who require lifelong support either in a
residential setting or supported within their communities, therefore there is very little change to
their care packages. Both nationally and locally the number of people with learning disabilities
living into older age is increasing, with many presenting with a diverse range of complex and
multiple interrelated health conditions.   Case reviews are undertaken when there is significant
changes to the client’s care needs. Children with Learning Disabilities are provided with a full
care assessment when they move to Adult Services.   
26. We reviewed a 9% sample size of Learning Disability high value care packages, this included
cases within residential settings, placed out with the authority and cases looked after within the
community in Argyll & Bute. Clients are assigned a case manager, although heavy reliance is
placed on the care providers reporting and updating the case manager on a regularly basis.   
Where case managers were not assigned, this was due to the allocated Social Worker moving on
to different positions and the case was assigned to the specific team for Learning Disability
rather than a named case manager.  Care providers are advised to allow regular contact and
updates to be provided. During testing we were advised that some providers will update on a
weekly basis, even if this is just to advise that all is well. 
27. Regular contact is maintained with care providers and where the placement is out with the
authority, 6 monthly reviews are undertaken with the Social Worker travelling to the residential
unit to undertake the review.   
28. Case notes are maintained on Eclipse, the replacement client database for Carefirst.  It was
noted that case notes were not always maintained and up to date. However, reassurance was
provided that this was due to capacity and that although not updated regarding contact notes,
regular contact was maintained with providers.              
Action Plan 3 
29. A previous audit report highlighted the fact that client records were stored in multiple locations,
including on the Council’s network drive.  Evidence obtained during the audit suggests that client
records are still being maintained in multiple locations, including on the network drive with
historical records stored in orange client files. A pilot project in the Mid Argyll area was
undertaken to scan records onto CIVICA (the Council’s document management system), which in
turn would link to CareFirst – now Eclipse. This project was considered to be a success and there
is a strong opinion that it should be rolled out to the rest of the Council areas. A proposal has
been submitted requesting funding in order to roll this project out, firstly across Social Work
Services, then when completed across Health. 
Action Plan 4
Resources are allocated in accordance with policies and procedures and reviewed on a regular
basis 
30. A Resource Allocation framework is in place based on a prioritisation of needs process.  The
prioritisation of all referrals is based primarily on the information received at the time of referral
including any relevant background information held on CareFirst/Eclipse and is prioritised
according to risk. 
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31. We were provided with a Terms of Reference for the “Adult Care Allocation Group (ACAG)”. The
main objective for the group is to review and approve total cost packages for both existing and
new cases over 29 hours per week and above for any cases falling into one of the following
categories: 
 Adult Social Care (includes all Self Directed Support options and residential care for
under 65’s)
 NHS Complex Clinical Care – following approval at the Argyll and Bute NHS Complex
Clinical Care Group
 Complex care 
We were advised that this group has been suspended as it was felt there was no added value to
having a single ACAG as the majority of Learning Disability care packages were already over the
threshold, and the wider ACAG members had no expertise or input in Learning Disability.  It was
felt that all the required expertise to make decisions on high cost care packages for Learning
Disability sat with the new CRG, along with the appropriate budget holders. Learning Disability
also have an additional Complex Care Group meeting where care packages are requesting an
element of funding from Health. In addition, how and where the decisions on resource
allocations are taken and recorded has not yet been confirmed.                        
Action Plan 5 
32. The large majority of Learning Disability services are commissioned under the Supported Living
contract and Older People services are commissioned under Care at Home contract. There are a
few anomalies where some providers of Care at Home services are commissioned to provide
support outside of their normal client group (majority in rural areas where it’s difficult to
commission). We were advised that the question regarding prioritisation of personal care in
each locality has been raised several times over the last few months. Due to the pressures on
both sides for commissioning, Learning Disability have requested that a small number of
packages be placed on the unmet need/waiting list for Care at Home services where they
require personal care only. This has not yet been agreed by management. A paper was
submitted to management for comment and response in November but there has been no
feedback as of yet. 
Action Plan 6 
33. Unmet need for Older People Care at Home is collated by the resources team on a weekly basis,
this is then submitted to Performance and Improvement Team, and is reported to Scottish
Government. This data is available on the HSCP SharePoint site. The data for Learning Disability
is not currently recorded formally and not included in the above, increasing the risk that
individuals remain in the community without the required support in place to meet their needs,
particularly around personal care needs. At present there is no overview of the total unmet need
and available resources across each of the localities, we have been advised that services are
working in silos.                                 
Action Plan 7 
34. The Coming Home Implementation Report, published by the Scottish Government, focusses on
improving care for people with complex needs and learning disabilities.  As part of the Coming
Home Implementation work, the Scottish Government is working to improve monitoring of the
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experiences of people with learning disabilities and complex care needs who are in hospital, who
are in out-of-area placements and/or whose current support arrangements are at risk of
breaking down. This is to avoid people living in hospitals or in inappropriate out-of-area
placements that they and their family have not chosen. Through the Coming Home
Implementation Memorandum of Understanding between the Scottish Government and COSLA,
it has been agreed that Integration Authorities will use and operate a local Dynamic Support
Register.  The Dynamic Support Register is designed to improve outcomes. The Register records
information about people with learning disabilities and complex care needs who are in hospital,
in out-of-area placements or whose current support arrangements are at risk of breaking down.
The HSCP reports data quarterly from their Register using a new national reporting process
delivered by Public Health Scotland (PHS). 
Roles and responsibilities have been documented and assigned 
35. Roles and Responsibilities are outlined in the various policies and procedures. The “Assessment
and Care Planning procedures” outlines the roles and responsibilities for each of the staff
categories, including Service Managers/ Area Service Managers/Team Leaders, First Line
Managers, Practitioners and Administration staff.  Financial processes and budget information is
provided in the document with guidance on responsibilities for budgets outlined.                                                        
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Appendix 1 – Action Plan 
No Finding Risk Agreed Action Responsibility / Due Date
Medium
1
Policies and Procedures 
Care Assessment policies and procedures are in place with
a number of key documents provided for review.  The
documents provided refer Carefirst.  With the
implementation of the new client database recording
system – Eclipse these require to reviewed and updated.
Policies and procedures may
not reflect current practice 
Policies and procedures to be
updated as part of the Eclipse
Implementation Program 
Head of Strategic
Planning, Performance
and Technology 
30 June 2024
Medium
2
Induction Pack 
Staff have access to relevant policies and procedures,
including access to relevant training. All staff should have a
session with the Carefirst/eclipse support team to learn to
navigate their way through the systems. An induction pack
is in the process of being developed and this will include
an introduction to policies and procedures.
New staff may not be aware
of how to access policies and
procedures leading to
inconsistencies in practice
 Incorporate Eclipse
Training into the HSCPs
induction program 
 Facilitate training sessions
as part of the Eclipse
Implementation Program
Head of Strategic
Planning, Performance
and Technology 
30 June 2024
Medium
3
Case Notes 
Case notes are maintained on Eclipse, the replacement
client database for Carefirst.  It was noted that case notes
were not always maintained and up to date.  
Records not maintained and
up to date
 Record keeping session(s)
to be delivered by
professional lead 
 Senior Managers to
implement case note
audit within their
respective services – this
should be linked to
individual practitioner
supervision
Senior Managers (Adult
Services) 
30 June 2024
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No Finding Risk Agreed Action Responsibility / Due Date
Medium
4
Client Records 
A previous audit report highlighted the fact that client
records were stored in multiple locations, including on the
Council’s network drive.  Evidence obtained during the
audit suggests that client records are still being maintained
in several locations. A successful pilot project was run in
Mid Argyll transferring all records onto CIVICA.  A proposal
has been submitted to roll this out across all other areas in
Argyll.
Lack of consistency in the
recording of client records
which may lead to inaccurate
record management or loss of
information 
Ensure that a standardised and
compliant electronic recording
system is implemented across
HSCP services – this should be
achieved via the Eclipse
Implementation Program 
Head of Strategic
Planning, Performance
and Technology   
30 June 2024
Medium
5
Resource Allocation Group 
We were provided with a Terms of Reference for the
“Adult Care Allocation Group (ACAG)”. We were advised
that this group has been suspended as it was felt there
was no added value to having a single ACAG as the
majority of Learning Disability care packages were already
over the threshold, and the wider ACAG members had no
expertise or input in Learning Disability.  In addition, how
and where the decisions on resource allocations are taken
and recorded has not yet been confirmed. 
Inconsistencies in allocation or
resources and a lack of
transparency of resource
allocation decisions 
Develop a Terms of Reference for
the Acute and Complex Care
directorate’s Care Allocation
Group that meets fortnightly and
is chaired by the Head of Service  
Head of Adult Services
(Complex and Critical
Care) 
30 June 2024 
Medium
6
Allocation of Resources 
The large majority of Learning Disability services are
commissioned under the Supported Living contract and
Older People services are commissioned under Care at
Home contract. There are a few anomalies where some
providers of Care at Home services are commissioned to
provide support outside of their normal client group,
however it was found that priority was given to older
peoples services with Learning Disability clients remaining
on a waiting list for personal care services.
Inequity of service provision Review the Care at Home contract
as a matter of priority to ensure
that there is personal care
provision across the authority for
those under the age of 65 with
complex needs, who do not
require more intensive care such
as that provided via Supported
Living.  
Head of Adult Services
(Health & Community
Care)
Chief Finance Officer 
30 June 2024
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No Finding Risk Agreed Action Responsibility / Due Date
Medium
7
Unmet Need 
Unmet need for Older People Care at Home is collated by
the resources team on a weekly basis, this is then
submitted to Performance and Improvement Team, and is
reported to Scottish Government. The data for Learning
Disability is not currently recorded formally and not
included in the above.  
Clients’ needs may not be met Include the data re unmet need
for those under 65 in the weekly
reporting format already in place
for Older People 
Head of Strategic
Planning, Performance
and Technology 
Head of Adult Services
(Health & Community
Care) 
30 June 2024 
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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. 
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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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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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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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 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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 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. 
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Argyll and Bute Council
Internal Audit Report
April 2024
FINAL 
High Medium Low VFM
Number of
Findings
0 0 4 0 
Freedom of Information
Audit Opinion: High 
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Contents 
Introduction ............................................................................................................................................ 3
Background ............................................................................................................................................. 3
Scope ....................................................................................................................................................... 4
Risks ........................................................................................................................................................ 4
Audit Opinion ......................................................................................................................................... 4
Recommendations ................................................................................................................................. 4
1. Objectives and Summary Assessment ........................................................................................... 5
2. Detailed Findings ............................................................................................................................ 6
Appendix 1 – Action Plan ..................................................................................................................... 11
Appendix 2 – Audit Opinion ................................................................................................................. 13 
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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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 Freedom of Information.
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. There are three main pieces of legislation that provide rights of access, subject to certain
exceptions or exemptions, to most of the information held by Scottish Public Authorities. These
are:
 The Freedom of Information (Scotland) Act 2002 (FOISA), the main Act;
 The Environmental Information (Scotland) Regulations 2004 (EIRs); And
 The Data Protection Act 2018 (DPA), which updated data protection law in the UK, to
complement the European Union's General Data Protection Regulation (GDPR). 
5. The Freedom of Information (Scotland) Act 2002 (FOISA) came into force on the 1st of January
2005 and gives everyone a legal right to request information held by a Scottish Public Authority.  
The Act is regulated by the Scottish Information Commissioner and aims to increase openness
and accountability across the public sector.  Any information recorded by the Council on paper,
electronically, and other methods, which cannot otherwise be withheld under the exemptions
contained in the legislation, can be requested and obtained. 
6. The Act requires Scottish public authorities to produce and maintain a publication scheme which
tells the public, the classes of information that the authority makes routinely available, how to
access the information and what it might cost. All Scottish authorities have adopted the Model
Publication Scheme produced by the Scottish Information Commissioner. 
7. The purpose of the publication scheme document is to make it easier for people to find
information directly, without having to request it from the authority, setting out classes of
information.  Argyll and Bute Council (the Council) has listed on its website, all the information it
currently publishes within each class and encourages The classes are shown below; 
 About Argyll and Bute Council
 How we deliver our functions and services
 How we take decisions and what we have decided
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 What we spend and how we spend it
 How we manage our human, physical and information resources
 How we procure goods and services from external providers
 How we are performing
 Our commercial publications 
8. The Council encourages anyone looking for information from the Council, to check the
publication scheme first, as it may be available people to access directly. Information that is not
available from the publication scheme can be requested via a FOI online request form, with the
Act requiring responses to be issued within 20 working days of receipt of the request.   
9. The Environmental Information (Scotland) Regulations 2004 (EIRs) sit alongside the FOI Act, and
govern access to environmental information held by Scottish public authorities. The EIRs require
every Scottish public authority to publish environmental information, and make it available on
request. 
10. The Data Protection Act 2018 (DPA), incorporating GDPR,  provides a right of access to any an
individual’s personal information, via Subject Access Request (SAR) and must be responded to
under data protection law, which is overseen and enforced by the UK Information
Commissioner's Office (ICO).
Scope 
11. The scope of the audit was to review of the processes and procedures for the collection and
response to FOI requests and assess the response times across the Council, as outlined in the
Terms of Reference agreed with the Governance, Risk and Safety Manager on 17 July 2023.
Risks
12.  The risks considered throughout the audit were:
 Audit Risk 1: Failure to comply with the FOI legislation
 Audit Risk 2: Requested information is not provided within the statutory timescales
Audit Opinion
13. We provide an overall audit opinion for all the audits we conduct. This is based on our
judgement on the level of assurance which we can take over the established internal controls,
governance and management of risk as evidenced by our audit work.  Full details of the five
possible categories of audit opinion is provided in Appendix 2 to this report.
14. Our overall audit opinion for this audit is that we can take a 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
15. We have highlighted four low priority actions where we believe there is scope to strengthen the
control and governance environment. These are summarised below:
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 The FOI/EIR procedure note requires to be updated to reflect current working practices
 Key contact details for staff involved in the collection and response to information
requests are not up to date.
 A review of the Council’s Publication scheme should be undertaken, including checking
that any links to information are still working.
 To highlight the number of marginally late responses, consideration should be given to
including a more detailed summary in reports to DMT/other relevant meetings. 
1. 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 The Council
has processes
and
procedures in
place for the
collection and
response to
FOI requests
Audit Risk 1 High  The Council has an overarching procedure
note for the collection and response to
Information requests, this is published on
the Council’s Intranet but is not up to date
and does not reflect current working
practices.
 Mandatory training for all staff is available
on the LEON system, which also records
and monitors completion.
 Additional training is provided to
designated Service FOI representatives,
who are responsible for ensuring that
actions and correspondence in relation to
the request are logged on the tracking
database.
 There is a Teams Channel where FOI
Service reps can access training and other
materials.
 Key contact details, on the Hub, for staff
involved in the collection and response to
Information requests are not up to date. 
 A review of the Council’s Publication
scheme should be undertaken, including
checking that any links to information are
still working.
2 The Council
has
arrangements
in place to
monitor its FOI
performance.
Audit Risk 2 High  The Compliance and Regulatory team
provide monthly updates to the Chief
Executive, the Chief Officer, Directors,
Heads of Service and the departmental
FOI reps. Quarterly reports are provided
to all DMTs and on an annual basis to the
Audit and Scrutiny Committee.
 The information in the reports is clear and
relevant.  The recent addition of a second
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tab provides Senior Managers with a
detailed breakdown of the late responses
and the reasons for such which further
highlight specific areas for improvement.
 To highlight the number of marginally late
responses, consideration should be given
to including a more detailed summary in
reports to DMT/other relevant meetings.   
17. Further details of our conclusions against each control objective can be found in Section 3 of this
report.  
2. Detailed Findings
The Council has processes and procedures in place for the collection and response to FOI
requests
18. The Council has processes and procedures in place for the collection and response to Freedom
of Information (FOI) requests. The access to information page on the Council’s Intranet site, the
Hub, publishes the FOI and Environmental Information (EIR) requests procedure note, along with
a list of the contact details for the Service FOI representatives. 
19. The Compliance and Regulatory team within Legal and Regulatory Support Services are the
Council’s experts on the legislation, that provide advice on the rights of access, subject to certain
exceptions or exemptions, to most of the information held by the Council. They are responsible
for overseeing compliance by the Council Services/Departments with regard to their statutory
responsibilities in relation to information requests, providing training and support as required,
and reporting upon performance. 
20. The FOI/EIR procedure is the overarching guide for all Council staff. It sets out the procedure for
dealing with and answering Information requests while emphasising the Council’s duties which
include: 
 proactively publish as much information as possible,
 respond to requests in within the statutory timescale of 20 working days for FOI
requests and up to 40 days for more complex EIR requests 
 to provide an adequate audit trail 
 follow best practice guidelines 
21. The document clearly defines the roles and responsibilities of staff by providing step by step
instructions to be used by staff during collection and response for information, and the
timescales for these, including: 
 how staff should respond to these, 
 checking if the information can be supplied using the Council’s Publication Scheme 
 checking to see if the information has already been requested as part of another FOI
request
 the documents/forms to use when collating information 
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22. While the FOI/EIR procedure is comprehensive and takes cognisance of the legislation, testing of
requests highlighted that it does not reflect all current working practices. The Compliance and
Regulatory team are currently exploring options to see how the use of technology can
streamline the collection and response to Information requests. A review of all procedure notes
will be undertaken during this process.
Action Plan 1 
23. To ensure that staff comply with current policies and legislation and that knowledge is up to
date, the Council has mandatory Freedom of Information module available on the LEON system.
Monitoring of this mandatory training is automated now with LEON sending emails to staff with
a link to the course two months before the training is due to expire. Reminders are sent to staff
and their manager until the training has been completed. We regard this as an area of good
practice. 
24. Specific training is provided to the designated Service FOI representatives, by the Compliance
and Regulatory Officer. Support is also offered during Reps meetings. In order to ensure business
continuity, services identify staff to provide cover for holidays/ absence. Whenever new
representatives are identified a training session is set up and invites are issued to all Service FOI
representatives. There is a dedicated Teams Channel where the Reps can access training and
other relevant materials as and when they need. 
25. The Compliance and Regulatory Officer maintains a list of the current Service FOI Reps, a review
of which found that it does not match those listed on the Councils Intranet Hub site.
Additionally, at the time of the review there were ongoing staff changes within the Compliance
and Regulatory team. The result is that key contact details on the Hub, for staff involved in the
collection and response to information requests, are not up to date. It is expected that the staff
recruitment process will be completed very soon, at which point the contact details on the Hub
will be updated.
Action Plan 2 
26. The majority of FOI requests are in an electronic form, either email or web form, both these
formats arrive via the FOI inbox. Where the request meets the legislative requirements, these
are logged on the central database system, AXLR8, by staff within the Compliance and
Regulatory Team. Requests are mostly distributed to the Services with the exception of more
complex requests, for example where a response requires information from multiple services, it
will be collated and monitored by staff within the Compliance and Regulatory team. 
27. Services have ultimate responsibility for collating the requested information and responding to
the requests. The designated Service FOI Reps administer this process, liaising with the staff
tasked with gathering the information, monitoring the time taken, updating the case log where
applicable, checking and issuing the response to the request to ensure it answers the questions
and closing the log.   
28. The Council uses the AXLR8 system when collecting and responding to requests for information
to ensure that it can evidence that it is meeting its legislative requirements. The system is used
to log requests, allocate these to the relevant services, monitor the timeframes, record when
exemptions/exceptions have been used and record the response issued. 
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29. There are built in email templates for responding to requestors to acknowledge the request and
eleven response templates to choose from to cover various legislative options for response,
examples include: 
 Section 25 – Otherwise Accessible –where requested information is already published.
 Section 27 – Intended for future publication – where the information is held but there
has been a decision to publish this prior to the request being received e.g. this could be
a timing issue, where a procurement tender process is being undertaken the results and
details of which will be published after the contract has been awarded.  
 Section 38 – Personal Information – Disclosure would contravene data protection. 
30. The decision on whether to apply an exemption/exception is taken by the Service when issuing a
response with the specific exemption/exception applied recorded on the system and the
appropriate standard template response used. It is the responsibility of Services to ensure any
required quality assurance checks are carried out, the Compliance & Regulatory team are
available should they have any queries or require further advice. 
31. A sample of 31 requests were selected for testing, the conclusion is that the Council has robust
procedures in place for the collection and response to requests for information. As noted above
the procedure note needs to be updated to reflect current working practices and any
recommendations as a result of this review. 
32. As outlined in the background information above, legislation requires that all Scottish public
authorities must adopt and maintain a "publication scheme", publish information in accordance
with it and review the scheme from time to time. The Council’s publication scheme is easily
accessible on its website but has not been updated since May 2021. The Council launched an
updated website in 2023. A review of the Council’s Publication scheme should be undertaken, to
ensure Services are publishing as much information as possible, this should include checking that
any links to information are still valid and working as intended. 
Action Plan 3 
33. The legalisation provides Councils with the choice of whether to publish and maintain a
Disclosure Log.  This is a list of the information that has been released in response to FOI/EIR
requests. The Council has currently chosen not to have a Disclosure List, as the resources
required to redact and publish responses and maintain the log would not be offset by a
reduction in requests. The Council can evidence this by the volume of responses issued with the
“otherwise accessible” exemption.  
The Council has arrangements in place to monitor its FOI performance
34. The Council has arrangements in place to monitor performance relating to the collection and
response to information requests, at various stages during the process of gathering the
requested information, prior to the response being issued and after to report upon uses of
exemptions/exceptions and compliance with the statutory timescales and to further raise
awareness where this has not been possible. 
35. Performance relating to how Council collects and responds to requests for information has a
high profile. Using information from the AXLR8 system, the Compliance and Regulatory team
provide monthly updates to the Chief Executive, the Chief Officer, Directors, Heads of Service
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and the Service FOI Reps. These performance reports provide details of the number of
responses, the responses submitted on time and those which were late, for each service/
department. 
36. Quarterly reports, with this same information, are provided to all Departmental Management
Team (DMT) meetings and the FOI annual report is presented to the Audit and Scrutiny
Committee at its September meeting. Externally, quarterly statistical reports are submitted to
the Office of Scottish Information Commissioner (OSIC) returns. 
37. The statutory requirements are that FOI requests should be responded to within 20 days and up
to 40 days for more complex EIR requests. Internally the Compliance and Regulatory team
promote the aim to respond within 10 days where possible. As an aide, triggers have been built
into the AXLR8 system to generate email reminders to the Service FOI reps which will reach the
allocated inbox on the morning of day 10 and day 15. These should then be forwarded to those
staff tasked with gathering the required information. Testing could not establish whether this
happens consistently. 
38. Overall, the Council has a very good within timescale response rate, which has increased slightly
from 93% in 2021/22 to 94% in 2022/23 with many service areas achieving a very high level of
performance, between 97-100%.  The quality of the responses also appears to be high, with only
31 requests for reviews were received from a total of 1495 requests, which is less than 2%. 
39. An analysis of responses was undertaken using the 2022/23 data with a summary by service, of
the late responses broken down into 1 Day, 2 Day & 3 Days plus. The table below highlights the
number of marginally late (1 or 2 days) responses: 
Dept /
Service
Total
rec’d
RESPONSES Days Late and percentage of total late responses
In
time
% in
time
Late  %
Late
1 day
late 
%  2 days
late 
%  3 days
+
% 
Chief Exec                      
Financial 98 97 99% 1 1% 0 0% 0 0% 1 100%
Community P&D 1 0 0% 1 100% 0 0% 0 0% 1 100%
Customer Services                      
Education  254 251 99% 3 1% 2 67% 1 33% 0 0%
L & RS 400 388 97% 13 3% 2 15% 1 8% 10 77%
Commercial 44 44 100% 0 0% 0 0% 0 0% 0 0%
D & I                      
D & EG 246 204 83% 42 17% 4 10% 6 14% 32 76%
R & IS 206 184 89% 22 11% 10 45% 5 23% 7 32%
Customer Services 106 104 98% 2 2% 1 50% 0 0% 1 50%
HSPC                      
IJB 0 0 0% 0 0% 0 0% 0 0% 0 0%
Adult Care 78 76 97% 2 3% 1 50% 0 0% 1 50%
C & F / CJ 42 40 95% 2 5% 1 50% 0 0% 1 50%
Live Argyll                      
Live Argyll 20 16 80% 4 20% 1 25% 0 0% 3 75%
TOTALS 1495 1404 94% 92 6% 22 24% 13 14% 57 62%
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40. If the number of 1 day and 2 day late responses were answered on time, this would have
significant impact upon the Councils response time, which using the data above would rise by
1% for each day: 
PROJECTION Total rec’d
RESPONSES
In time % in time Late  % Late
If 1 day late was responded to on time  1495 1426 95% 70 5%
If 2 day late was responded to on time  1495 1439 96% 57 4% 
41. To raise awareness and to try and reduce the number of marginally late responses the
Compliance and Regulatory team have taken the undernoted steps: 
 Updating training notes for Service FOI reps advising that Third Tier Managers be copied
into the 10 day reminder and Head of Service copied into day 15 reminder emails when
these are issued by Service FOI representatives to those gathering the information. 
 Introduced a second tab on the monthly and quarterly performance reports. This
provides Senior Managers with a breakdown of the late responses and the reasons for
such which highlights specific areas for improvement. This also brings the report format
in line with the FOI Annual Report provided to Audit & Scrutiny Committee. 
42. To highlight marginal late responses at Senior Manager level, consideration should be given to
including a more detailed summary in reports to DMT/other relevant meetings. 
Action Plan 4 
43. The Council are required to submit statistical quarterly returns to OSIC, providing details which
include reporting on the number and category of exemption and exception used. The
Compliance and Regulatory Team submit these on behalf of the three bodies required by OSIC.
These are: 
 Argyll and Bute Council – which includes all of the information relating to the Council,
the HSPC and LiveArgyll. 
 The Integrated Joint Board (IJB)
 The Argyll and Bute Licensing Board. 
44. Our review found these are submitted on time and with no issues arising which require to be
brought to management’s attention. 
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Appendix 1 – Action Plan 
No Finding Risk Agreed Action Responsibility / Due Date
Low 1
FOI/EIR Procedure Note 
The FOI/EIR Procedure Note is the overarching procedure
note for the collection and response to information
requests, is not up to date and does not reflect current
working practices.
The Compliance and Regulatory team are currently
exploring options to see how the use of technology can
streamline the collection and response to Information
requests. A review of the procedure notes will be
undertaken during this process. 
Potential for confusion as
procedure note does not
reflect current working
practice
Review and Update procedure,
publish on HUB and provide copy
to Audit
Compliance & Regulatory
Officer  
31 March 2025
Low 2
Contact Details 
Key contact details, on the Hub, for staff involved in the
collection and response to Information requests are not up
to date. This is a known issue due to ongoing recruitment.
Once this process is complete the contact details will be
reviewed and the Hub updated. 
Potential for delays if
information and departmental
contact details are not be up
to date. 
Update Hub and provide link to
audit
Compliance & Regulatory
Officer 
30 June 2024
Low 3
Publication Scheme 
The Council’s Publication scheme not updated since May
2021, and the Council’s website was updated in 2023. 
A review of the Council’s Publication scheme should be
undertaken, including checking that any links to
information are still working. 
The Publication Scheme is not
be up to date and may contain
outdated links to information.
This may contribute to a rise
in requests for information
and staff time dealing with
these.   
Review and Update Publication
Scheme, publish on Website and
provide link to Audit
Compliance & Regulatory
Officer  
31 March 2025
Low 4
Performance Reports 
To highlight the number of marginally late responses,
consideration should be given to including a more detailed
summary in reports to DMT/other relevant meetings.  
Potential that marginally late
responses by services reduce
the Councils overall response
rate.
Copy of 2024/25 FQ1 covering
report to be provided to Audit
Compliance & Regulatory
Officer  
30 Sept 2024
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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. 
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Argyll and Bute Council
Internal Audit Report
May 2024
FINAL 
High Medium Low VFM
Number of
Findings
0 4 1 0 
Cloud Computing Services
Audit Opinion: Substantial 
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Contents 
1. Executive Summary ........................................................................................................................ 3
Introduction ............................................................................................................................................ 3
Background ............................................................................................................................................. 3
Scope ....................................................................................................................................................... 4
Key Dates ................................................................................................................................................ 4
Risks ........................................................................................................................................................ 4
Audit Opinion ......................................................................................................................................... 5
Recommendations ................................................................................................................................. 5
2. Objectives and Summary Assessment ........................................................................................... 5
3. Detailed Findings ............................................................................................................................ 7
Appendix 1 – Action Plan ..................................................................................................................... 11
Appendix 2 – Audit Opinion ................................................................................................................. 14 
Contact Details 
Internal Auditors: Mhairi Weldon and Annemarie McLean 
Telephones:  01546 604294 and 01700 501354 
e-mails:   mhairi.weldon@argyll-bute.gov.uk and 
annemarie.mclean@argyll-bute.gov.uk  
Website:  www.argyll-bute.gov.uk
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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 Cloud Computer Services.
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. Cloud services are described by the National Cyber Security Centre (NCSC) as “an on-demand,
massively scalable service, hosted on shared infrastructure, accessible via the internet”.  These
services are therefore located outside the Council’s network environment and typically provide
data storage, processing and pre-defined user functionality.  The NCSC advises that public sector
organisations select a provider using their cloud security principles.
5. The NCSC states that cloud usage has steadily grown in recent years and is now the preferred
option when organisations purchase new IT services in alignment with the UK and Scottish
Government’s Cloud First Policies.
6. The Council’s ICT and Digital Strategy aligns to the Digital Strategy for Scotland and promotes
improvement and sustainability through digital innovation to deliver efficiencies, savings and
improved services for council staff and customers.  In particular, the strategy aims to provide
systems and applications available to all employees, wherever they work, operating the latest
software versions that are fully supported by suppliers.  Where applicable, IT solutions will
continue to be provided in the cloud where it is economically viable to reduce long term cost
and improve on-premises solutions.
7. The 2022 Society for Innovation, Technology and Modernisation (SOCITM) Benchmarking report
indicated that the Council is one of the most cost effective and highest performing Local
Authority ICT services out of 31 participating across the UK, it is also indicated that the Council
use cloud computing more than most other Councils.
8. The adoption of cloud services aims to generate efficiencies, improve operations and reduce the
overall cost of ownership for the Council.  The main benefits of migrating to the Cloud include:  
 Reduced operational and maintenance costs
 Rapid deployment
 Scalability to address demand fluctuations
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 Security capabilities to protect data and infrastructure
 Resilience in system availability
9. The Council requires access to the Public Services Network (PSN) on an ongoing basis which
requires security assessments to have been conducted against Cloud Security guidance from the
National Cyber Security Centre (NCSC), including protective monitoring, identity and
authentication, separation between consumers and secure consumer management.  
10. Back-up data is a copy of primary data made at a point in time that can be used to reinstate
primary data should it be lost as a result of hardware or software failure, data corruption,
malicious attack or human error.  This data must be retained in a secure, secondary location to
maintain its integrity and validity for use should it be required.  As part of their service provision,
cloud service providers create back-up copies of customer’s data, they may also/alternatively
implement continuous replication to provide a more up-to-date copy of data.
11. The overall responsibility for service provision and data security remains with the Council rather
than with the Cloud service provider.
Scope 
12. The scope of the audit was to review systems and processes in place to support security and
data integrity of cloud-based computer services as outlined in the Terms of Reference agreed
with the Head of Customer and Support Services on 2 May 2024.
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 2 May 2024
Fieldwork Commencement 11 April 2024
Draft Report issued 27 May 2024
Management Comments received 30 May 2024
Final Report issued 30 May 2024
Audit and Scrutiny Committee 13 June 2024
Risks
14.  The risks considered throughout the audit were:
 SRR11:  Service Delivery – Cyber Security
 KF ORR35:  Cyber security breach and associated cyber attack
 CSRR12:  Security information and event management (SIEM)
 CSRR18:  Password Security
 CSRR19:  Account Management
 CSRR31 & 39:  Backups
 CSRR33:  Critical Infrastructure Security
 CSRR38:  Multi-factor Authentication (MFA)
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 CSRR42:  Cloud Security
 Audit Risk 1:  Failure to comply with Public Services Network (PSN) and Cyber Essentials Plus
certification requirements 
 Audit Risk 2:  The Council has limited control over access to systems and data
 Audit Risk 3:  Information stored in Cloud services is not appropriately segregated from that
of other organisations resulting in data protection and commercial failings 
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 is provided in Appendix 2 to this report.
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
16. We have highlighted 4 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:
 Review content of ICT Contract Application and cloud services asset register to ensure all
systems are included with links to all associated documentation.  
 ICT officers investigate why access to one system was achieved using a personal device
and seek resolution to prevent recurrence.
 Appropriate authorisation should be sought for all new system users.
 Periodic review of users takes place to remove leaver access in a timely manner.
 ICT services prepare, update or finalise disaster recovery documentation and implement
testing.
17. 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
18. 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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Exhibit 1 – Summary Assessment of Control Objectives 
Control Objective Link to Risk Assessment Summary Conclusion
1 Contract/SLAs are in
place and include
security and related
performance
monitoring
arrangements.
SRR11
KF ORR35 
CSRR12, 31,
33, 39 & 42
Audit Risk 1,
2 & 3
Substantial ICT and procurement teams assist
services implement new systems
following robust due diligence
processes.  Documentation requested
for review was retained, however, this
proved challenging to gather at the
outset of the audit.  The list of cloud
based systems provided did not fully
align with the contracts held on the ICT
application.  Arrangements for
business continuity, data recovery,
change management and performance
targets were found to be present and
appropriate oversight takes place.
2 Access to systems
and data is properly
authorised and held
securely.
SRR11
KF ORR35 
CSRR18, 19,
38 & 42
Audit Risk 2
& 3
Substantial Each system reviewed was multi-factor
authentication (MFA) compatible,
however, this was not utilised in two of
the systems.  New users were not
always appropriately authorised and
leavers are not being promptly notified
for one system.  Training in the use of
each system has been provided and/or
appropriate guidance made available. 
Service providers have implemented
measures to protect the Council’s data
in transit and at rest within the Cloud
systems and prevent unauthorised
access from their employees and other
customer organisations.
3 Business
continuity/disaster
recovery
arrangements are in
place to ensure
back-ups of data
have been created,
are securely stored
and are accessible
and usable should
they be required.
SRR11
KF ORR35 
CSRR12, 31,
39
Audit Risk 2
Reasonable Cloud service providers have
arrangements in place to backup
and/or replicate Council data to ensure
its ongoing availability.  A
comprehensive overarching Cyber-
incident response plan has been
prepared, however, system specific
disaster recovery plans and/or run
books require to be prepared, updated
and/or finalised and tested for specific
cloud systems. 
19. Further details of our conclusions against each control objective can be found in Section 3 of this
report.   
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3. Detailed Findings
Contract/SLAs are in place and include security and related performance monitoring
arrangements
20. New or improved technology services are implemented following identification of a business
need and completion of an options appraisal to identify the solution best suited to the needs
and demands of the Council.   ICT Client Liaison Officers often assist throughout the processes
involved including, contributing to composition of the business case, providing a project
management role, representation on the Project Board and providing technical expertise.  The
successful system is selected based on a number of elements including functionality,
performance and best value and may be either on premise or in the cloud, although there has
been a significant move towards cloud services in recent years.   
21. A significant amount of due diligence takes place in the forming of contract to ensure the
Council’s specific requirements are met, this includes: 
 Preparation of a business case with justification, rationale and approval for the
procurement project.  (business objectives, scope, options appraisal, costs and budget,
risks timeline etc.)
 Tender specifications requirements and response for inclusion within the final contract
(covers technical and security functionality, outcomes or both) 
 Tender evaluation and scoring
 ICT Security Assessment 
 Financial Checks to ensure integrity of supplier organisation
 Formation of a project board and sponsor for management, oversight purposes and to
decide the most appropriate option.  (This is primarily service led)
 Data Protection Impact Assessment
22. A sample of four cloud services was selected for review from a list of current providers, for the
purpose of this report we will refer to these systems as A, B, C and D to protect the Council from
potential harm following identification of areas for improvement.  
23. The Council’s ICT services maintain an ICT contract application containing detailed
documentation in respect of systems and services procured, however, this application did not
contain documentation pertaining to all of the systems identified in the list of current cloud
service providers.     
24. Contract documentation and supporting information was requested to evidence contract
arrangements were in place for the four systems selected for review in order to manage
information security and data integrity in line with the agreed scope of the audit.  Documents
were found to have been retained safely and were provided by ICT officers, however,
coordination of a number of officers was required to identify and collate information for audit
purposes. 
Action Plan 1
25. The documentation and publicly available terms and conditions reviewed stated that there were
measures in place to ensure ongoing service availability and security of data stored within each
of the provider’s data centres.  The security responsibilities of each party to the contracts were
also outlined.
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26. Arrangements for business continuity and data recovery were in place for each of the systems
and included solutions such as replication of data at additional data sites, frequency of data
back-up routines and for system C, provision of periodic copies of back-ups to customers for
additional resilience.  Recovery time objectives were present for systems A, C and D and system
B stated recovery in a timely manner.  
27. Arrangements are also in place to make provisions for modifications to cloud systems to ensure
they reflect any changes in the business environment (e.g. legal/regulatory updates) and ensure
ongoing functionality and availability.  
28. Performance targets are represented in a Service Level Agreement (SLA).   Council services
(system users) undertake the role of performance monitoring with support provided by ICT
Client Liaison Officers if required, where issues are identified, the Council’s procurement team
may step in to assist with resolutions and details are reported to Department Management
Teams and Information Technology Management Team for escalation and oversight purposes.   
Access to systems and data is properly authorised and held securely
29. Access to cloud services is managed by multi-factor authentication (MFA) for systems B and C, it
appears to be available for systems A and D but has not been switched on.  Access to system A
was found to be achievable by use of a personal device during the course of audit testing. 
Although not selected for testing, we have been made aware of a further system that can also
be accessed by personal device, we understand that this is a supplier issue and affects all users,
not just Argyll and Bute Council.  
Action Plan 2
30. User access to data held on the cloud service is managed by systems administrators.  A sample
of ten users was selected from systems A, B and C to assess if authorisation was appropriately
provided, system D is managed by a small team of users within ICT itself.  All ten users were
appropriately authorised in systems A and C, however, three users from system B had submitted
the new user form themselves without authorisation being evident from their line managers,
checks undertaken by the Council service’s systems administration team are limited to ensuring
that the request has been sent from a valid domain email address (Council or partner
organisation).
Action Plan 3
31. Systems A, B and C were also reviewed to assess if timely notification of leavers is received to
ensure prompt removal of access to data.  System C was provided with weekly updates from the
Council’s HR service to remove users from the Council’s overarching network infrastructure that
provides system access and system A undertook a quarterly review of all users to identify and
remove leavers.  System B relies on the Council service’s systems administration team receiving
notifications from line managers that users are no longer required to have access, testing found
that eight recent leavers had not had their access removed.  Whilst there is some comfort in the
fact that this system is also dependent on network access, it does not prevent unauthorised
access when an employee transfers to another service area of the council or partner
organisation, additionally, there is currently no leaver notification received from HR and there
has been no user review since implementation of the system in June 2023.  
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Action Plan 4
32. Training in the use of the cloud services was provided to key individuals prior to implementation
and cascaded to other authorised users.  Documented guidance and training modules are also
available to support users via the systems administrators, the Council’s intranet or LEON training
platform.
33. Cloud service providers are required to provide assurance that their employees and other
organisations who use the services provided (tenants) are unable to access the Council’s data. 
Documentation reviewed indicated that strong security measures are in place in each of the four
systems reviewed to segregate Council data from that of other organisations to prevent
unauthorised access.   Where the provider’s employees are legitimately required to access data
for maintenance or resolution of issues identified, specific permission is sought and approved by
the Council to do so, additionally, immutable audit trails are maintained of any changes that do
take place.
34. Documentation also indicated that standard encryption technologies and options to protect data
while in transit or at rest are in place.  Data held within each of the systems is held in accordance
with the Data Protection Act with the Council acting as data controller and the cloud service
provider the data processor. 
Business continuity/disaster recovery arrangements are in place to ensure back-ups of data have
been created, are securely stored and are accessible and usable should they be required
35. Provisions have been made within materials reviewed to ensure data is backed-up or replicated
at secure sites to ensure availability in the event of a disaster or cyber incident.  
36. A cloud based solution is not currently utilised for the Council’s on premise systems, however,
other robust means of providing resilience are employed.
37. The Council has prepared a generic Cyber Incident Response Plan that aligns to the Scottish
Public Sector Cyber Incident Central Notification and Co-ordination Policy.  This is a
comprehensive document including details of what constitutes an incident, how it should be
managed and the roles and responsibilities of parties required to contribute should the need
arise.
38. The Council operates many systems, including both on premise and cloud based.  In the event of
a cyber-incident, it would not be possible to restore all systems simultaneously, therefore a
process has taken place to categorise all systems into four tiers with each being completely
restored in numerical order prior to moving on to the next.  A further prioritisation exercise has
taken place to ensure that the most critical systems are addressed earliest within each tier.    
39. ICT services have developed a disaster recovery planning storage area with an array of
comprehensive plans and run books to aid recovery of data in the event of a disaster or cyber-
incident.  Whilst it is deemed that the cloud service providers have adequate disaster recovery
arrangements in place, there is a further need to include regular review of the provider’s plans
and activities in addition to being assured that disaster recovery is appropriate.  
40. Cloud service providers have disaster recovery plans in place, however, the Council also has
responsibilities to ensure these plans adequately address our needs and the services can be
accessed in the event of a disaster situation.  A disaster recovery plan has been drafted for
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system A and a run book has been prepared for system C, however, it is considered that this run
book requires to be updated to reflect additional information specific for cloud restore.  A
disaster recovery plan is being prepared for system B and there was no evidence of
documentation for system D.
Action Point 5
41. Each of the systems websites were reviewed to establish if independent assurance could be
provided in terms of security and performance and all were found to have several third party
accreditations in place. 
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Appendix 1 – Action Plan 
No Finding Risk Agreed Action Responsibility / Due Date
Low 1
Contract Application and Cloud Services Asset Register
Finding:  The ICT Contract Application did not contain all
systems contained on a list provided by ICT Project &
Liaison Manager. 
Recommendation:  Review content of ICT Contract
Application and cloud services asset register to ensure all
systems are included with links to all associated
documentation. 
ICT may be unable to track
and manage systems and their
risks, ensure licence
compliance and plan
upgrades/replacements. 
The ICT Contract Register will be
reviewed and will include a Cloud
Asset Register to ensure all
systems are included with links to
all associated documentation.
ICT and Digital Manager 
31 August 2024
Medium
2
Multi-factor Authentication
Finding:  access to one system was found to be achievable
using a personal device during the course of audit testing. 
An additional system not included within the sample
selected for review is also known to allow access from a
personal device. 
Recommendation:  ICT officers investigate why a personal
device was able to access the system and implement
suitable means to restrict such access. 
Council data may be accessed
inappropriately, including by
recent leavers of the Council.
ICT Engineers will work with the
supplier of System A to ensure
only council managed devices can
access the system. 
ICT Engineers will investigate
whether the supplier of the
national system referred to in the
report (which is used by almost all
public sector organisation in
Scotland with built in access from
personal devices), can switch off
access to the Council’s instance
from non-council devices. 
ICT and Digital Manager 
31 August 2024
Medium
3
User Authorisation
Finding:  for one system reviewed, user access was not
appropriately authorised by line management in all
instances. 
Recommendation: service systems administration
implement a procedure insisting that appropriate
authorisation to access sensitive data is obtained for all
new users. 
Unauthorised access to
sensitive data
The System B team will send
reminders to all users,
emphasising that Line Managers
must approve all requests for
system access. Additionally, they
will conduct quarterly reviews of a
random sample of (5) request
forms to ensure quality assurance. 
Systems Support Officer 
30 May 2024 
Completed
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No Finding Risk Agreed Action Responsibility / Due Date
Medium
4
User Revocation
Finding: for one system reviewed, we found that systems
administrators are not always promptly informed when
users leave or no longer require access.  Termination of
network access provides some comfort where leavers are
concerned, however, this does not prevent users gaining
continued access when transferring to another service
area. 
Recommendation:  periodic review of user status takes
place by service systems administration to ensure access
to sensitive data is restricted to those with current and
legitimate service needs. 
Unauthorised access to
sensitive data
The System B Team will promptly
implement a monthly procedure
to identify and deactivate
accounts that have not been used
within the month.
Systems Support Officer 
30 June 2024 
Medium
5
Disaster Recovery Plans and Run books
Finding:  Disaster recovery plans/run books are not in
place for all systems reviewed and therefore not tested to
cover any potential disaster affecting the Council’s ability
to access these systems. 
Recommendation:  ICT services prepare, update or finalise
disaster recovery documentation and implement testing. 
Disaster Recovery Plans/Run
Books are not available or up
to date to provide the
necessary information in the
event of a cyber-incident.
ICT will prepare, update and
finalise disaster recovery
documentation and implement
testing for those recently
introduced cloud systems not
already documented.
ICT and Digital Manager 
31 October 2024 
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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. 
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