Democracy Spraffa

202223_BurialRecords_FinalReport

Argyll and Bute Council · 20 June 2023
Back to Audit and Scrutiny Committee — 20 June 2023 and its agenda

Text extracted from the council's PDF. Layout and reading order may differ from the original.

Original council PDF · Download plain text

Page 1

Argyll and Bute Council
Internal Audit Report
June 2023
FINAL 
High Medium Low VFM
Number of
Findings
1 3 2 0 
Burial Records
Audit Opinion: Reasonable

Page 2

2 
Argyll and Bute Council – Internal Audit Report – Burial Records, June 2023 
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 ............................................................................................................................ 7
Appendix 1 – Action Plan ..................................................................................................................... 11
Appendix 2 – Audit Opinion ................................................................................................................. 15 
Contact Details 
Internal Auditor: Mhairi Weldon 
Telephone:  01546 604294 
e-mail:   Mhairi.weldon@argyll-bute.gov.uk 
www.argyll-bute.gov.uk

Page 3

3 
Argyll and Bute Council – Internal Audit Report – Burial Records, June 2023
1. Executive Summary
Introduction
1. As part of the 2022/23 internal audit plan, approved by the Audit & Scrutiny Committee in
March 2022, we have undertaken an audit of Argyll and Bute Council’s (the Council) system of
internal control and governance in relation to Burial Records.
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. Argyll and Bute Council (The Council) is a burial authority and as such has a legal duty to provide
a burial facility in the Council area.   
5. Due to the diverse geography of Argyll and Bute, a single burial ground is not appropriate and as
such, the Council operates 131 burial grounds, 68 of which are closed leaving 63 able to take
additional burials.  As each cemetery nears capacity it is difficult to identify and purchase land
which is suitable and cost effective for the purpose of accommodating burials.  Five of the 63
operational cemeteries are expected to reach capacity within the next 5 years.  A specific report
detailing capacity issues has been submitted to the Environment, Development and
Infrastructure (EDI) Committee on 2 March 2023. 
6. The Council has been utilising a computerised Burial and Cremation Administration System
(BACAS) since 2003, to record details of burials and cremations in addition to maintaining
manual records at area offices.  Burial records prior to 2003 have not been fully transferred to
the BACAS to enable information to be accessed remotely.   
7. The provision of a burial and cremation service across the Council area involves a wide range of
staff in terms of management, administration and operational requirements.  Due to an aging
workforce, a number of key members of staff have reached or are approaching retirement age
and there has been difficulty in recruiting and training replacements for those members of staff.   
8. Charges for burial services are reviewed annually and updated as required, the fees charged by
other comparable local authorities are similar in some elements and vary significantly in others. 
There are no charges imposed for burial of under 18s. 
9. Income for services provided is not always received in a timely manner, as at 1 March 2023,
£155k cemetery income is outstanding, £73k of which has been outstanding for greater than 3

Page 4

4 
Argyll and Bute Council – Internal Audit Report – Burial Records, June 2023
months and has been passed to the Council’s legal services to pursue in accordance with the
Council’s corporate process.   
10. The overall budget for burial services in the current year (2022-23) is £470k, there are elements
of this that are uncontrollable, however, there are no major concerns regarding meeting this
target.
Scope 
11. The scope of the audit was to review the control environment and administration of burial
records as outlined in the Terms of Reference agreed with the Head of Roads and Infrastructure
Services on 23 March 2023.
Risks
12.  The risks considered throughout the audit were:
 SRR 06 – Service Delivery
 Audit Risk 1 – failure to comply with relevant legislative/regulatory requirements
 Audit Risk 2 – recruitment and retention of trained workforce (age profile, training and
absence)
 Audit Risk 3 – burial records may not be accessible in an electronic format in support of
remote working arrangements
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 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.
Recommendations
15. We have highlighted one high priority recommendations, three medium priority
recommendations and two low priority recommendations where we believe there is scope to
strengthen the control and governance environment. These are summarised below:
 A unified approach to records management should be adopted to establish consistency
and provide resilience across the service.  Additionally, a sample of burial records should
be periodically checked for accuracy.  This should be documented in a procedure note
and issued to the relevant members of staff.
 Policies and procedures should be subject to periodic review and updated as required. 
Updated documents should be promptly circulated to staff and published on the
Council’s website where appropriate.

Page 5

5 
Argyll and Bute Council – Internal Audit Report – Burial Records, June 2023
 Liaise with the Council’s ICT Service to establish a more secure means of access to
BACAS. 
 Management should undertake a review of the BACAS system user requirements and
ensure sufficient licences are purchased to maintain service delivery as well as legal
compliance.
 Liaise with system provider and other Local Authorities to establish which additional
features would provide benefits to the service.
 Source temporary additional resource to update historical burial records on BACAS.
16. 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
17. 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 Burial records are
complete, accurate
and up-to-date. 
All Risks Reasonable Policies and procedures are in place
and made available to staff, however
these require to be reviewed on a
regular basis.   There is no procedure in
place to guide staff in maintaining
burial records which has resulted in
some inconsistencies across the service
and unnecessary printing of
documentation received electronically. 
The BACAS system is updated with
burial details following receipt of the
application for interment.  The system
has additional functionality that may
help deliver efficiencies but are not
currently utilised.  Traditional registers
are updated with appropriate burial
information to match BACAS system. 
Historical information from traditional
registers has been updated on BACAS
in one area and partially in others
when lairs are re-opened, the majority
of burial records have yet to be
updated.  There is no record of private
(home) burials outwith registered
private burial grounds and
documentation in support of
exhumations was not available at the
time of the review.
2 Burial records are
maintained in a safe
All Risks Reasonable The BACAS system is installed on a
terminal server managed by the

Page 6

6 
Argyll and Bute Council – Internal Audit Report – Burial Records, June 2023
and secure manner
to preserve integrity
of information
stored.
Council’s ICT service and supported by
the supplier, Clear Skies.  Users logon
to the terminal server but there is no
additional requirement to logon to the
BACAS system, therefore any employee
with access to the terminal server has
unrestricted access to BACAS.  The
Council has purchased 8 licences for
BACAS but it is unclear if this is the
optimum number required.  There are
no supervisory checks in place and no
reports are generated to highlight
exceptions or management
information.
Traditional registers are stored
securely either in locked rooms, a safe
or in locked filing cabinets.  Printed
application for interment forms and
supporting documentation were either
stored with the registers or in offices
which are locked when unattended. 
Where retained, electronic versions of
the forms and documents are saved on
the Council’s secure network drives.
3 Burial records are
available to those
with authority to
access them and a
General Data
Protection
Regulations (GDPR)
compliant version
made available to
the general public
upon request.
All Risks Substantial The BACAS system is able to restrict
user access levels according to level of
responsibility but this is not currently
used due to the method of access. 
Whilst this provides resilience across
the service it also increases risk of
unauthorised access and errors
affecting data integrity.  Leavers are
promptly removed from the Council’s
network via a corporate process,
however, access may be retained if
moving to another post within the
Council.  Burial registers are not
currently made available to the public
to view in compliance with GDPR
legislation but information can be
provided upon request and payment of
associated charge. 
18. Further details of our conclusions against each control objective can be found in Section 3 of this
report.

Page 7

7 
Argyll and Bute Council – Internal Audit Report – Burial Records, June 2023
3. Detailed Findings
Burial records are complete, accurate and up-to-date
19. Policies and procedures have been prepared and made available to employees on a SharePoint
site, additionally, the Rules for the Management of Burial Grounds and Protocol for provision of
cemetery and cremations services are available to the public on the Council’s website in addition
to other general information.  The documents are clear and concise, relevant to work involved
and consistent with legislative requirements, however, there is no evidence that these
documents have been subject to regular review.  It is noted that an update to the Rules for the
Management of Burial Grounds has been presented to the Environment, Development and
Infrastructure Committee on 2 March 2023 and endorsed, this document has yet to be
circulated to staff and published on the Council’s website. 
Action Plan 2
20. A system manual has been provided to the system administrator, however, it is not currently
available to BACAS users.  There are help menus embedded within the system and peer support
is available for inputting of data, any system issues are progressed by the system supplier, Clear
Skies.
21. There is no procedure document in place to guide staff in maintaining burial records.  Whilst the
burial registers vary from cemetery to cemetery, the application for interment form and other
supporting documentation is consistent across the Council.  It was observed at the time of the
audit that there are some variances in the filing structure of these documents and updating of
the BACAS burial system.   
Action Plan 1
22. Burials are arranged via phone call from a funeral director or applicant directly and recorded in a
manual desk diary, the full details are promptly updated on the BACAS system upon receipt of
the application for interment form and other relevant supporting documentation.  Unless an
existing lair is to be re-opened, lairs will be purchased at this stage and a certificate of right of
burial is generated and issued to the applicant.  The BACAS system also generates a digging slip
which is passed to the appropriate operations team to include the burial service within their
work schedule and financial summary to update the debtors system with the charges incurred.  
23. The burial registers and lair plans located in Council offices are old and very delicate in some
instances, they contain the required fields for recording information and are updated
periodically when a few burials have accumulated as they are stored in other parts of the
buildings.  Where registers are also maintained at cemeteries, these are updated by the
operations team when the burials take place.
24. The BACAS system is user friendly and contains all of the required fields for inputting burial
information and has additional functionality that is not currently utilised.  Users are not aware of
any reports being generated to provide management information.  Management is aware that
other Local Authorities are using the booking function and recording additional information such
as when lairs are levelled.  It is also possible that the financial information may be extracted to
feed the debtors system without the need to duplicate manual input.   
Action Plan 5

Page 8

8 
Argyll and Bute Council – Internal Audit Report – Burial Records, June 2023
25. BACAS has been used by the Council since 2003, whilst it has been updated with information
from the traditional registers in some areas, this has not been possible in all areas due to the
volume of work this requires.  There has been some effort to update information when lairs are
reused and information is to hand.  Part 7, section 102 of the Burial and Cremation (Scotland)
Act 2016 (The Act) requires “information and registers to be kept in electronic form”, Scottish
Government has advised that this section is not yet in force, however, management should
prepare for this change and ensure that all information is available electronically when
implemented. 
Action Plan 6
26. A sample of 34 recent burials was selected for audit review and all were found to have been
updated on BACAS, however, the applicant tab was not updated in one area as it was considered
that the funeral director information was sufficient.   
Action Plan 1
27. The Application for interment form and supporting documentation is now submitted to the
Council via email, a change that was implemented during remote working requirements as a
result of Covid and has continued.  These documents are then printed and filed within the local
area office.  Scottish Government has advised that the electronic copy is sufficient. 
Action Plan 1
28. Private burial grounds are recorded on BACAS, however, home burials are not.  Section 23 of The
Act requires that “Each local authority must prepare and maintain a register of private burials
authorised by the authority”.  When an enquiry for a private burial is received, the details are
passed to colleagues in Environmental Health to provide information to the applicant.  Whilst
there is a record of the enquiry, the burial does not appear to be formally authorised or
registered.   
Action Plan 1
29. Section 30 of The Act requires that “Each local authority must prepare and maintain a register
containing prescribed information about exhumations of human remains”.  When an
exhumation is required, both the registers and the BACAS system are updated to reflect the
removal of the human remains.  In one instance BACAS had not been updated (this was
corrected at the time of the audit visit) and we were informed that in another instance the
record had been deleted as the remains were no longer within the lair.  There is no separate
register of exhumations maintained and at the time of the audit we could not be advised of the
location of the formal documentation authorising each exhumation.   
Action Plan 1
30. The sample of 34 recent burials was also reviewed to ensure application for interment and all
relevant supporting documentation was available for review at the time of the audit visit:
 The application for one interment and it’s supporting documentation could not be
located in one area.
 One application did not include the appropriate document for transferring human
remains from England to Scotland.

Page 9

9 
Argyll and Bute Council – Internal Audit Report – Burial Records, June 2023
 With the exception of one very recent interment, all registers had been updated with
the appropriate burial information and lair holders were recorded.
 Digging slips had been generated by BACAS, passed to the operations team and returned
upon completion of the burial. 
Action Plan 1
Burial records are maintained in a safe and secure manner to preserve integrity of information
stored
31. The BACAS system is located on a terminal server managed by the Council’s ICT service and is
included within the routine back-up and business continuity processes applied at a corporate
level.  Users access the terminal server using a shortcut provided by ICT on their assigned laptop
and are required to re-enter their network credentials to gain access.  The BACAS system has 9
users assigned (one is system support), however, this does not prevent other users from
accessing the system as no authentication is required to gain access, therefore, any user with
access to the terminal server has full unrestricted access to BACAS. 
Action Plan 3
32. The Council purchased 8 licences for BACAS when previously installed on stand-alone desktop
computers within area offices.  At the time of the review it was unclear whether these were user
licences or concurrent licences and whether 8 licences was optimum for the number of system
installations and users in place.     
Action Plan 4
33. The BACAS system makes use of compulsory fields to ensure essential data is input and dates are
added via a calendar icon.  There are no supervisory checks in place and no exception or
management information reports are generated. 
Action Plan 1
34. Registers and lair books were all stored safely in locked rooms, a safe or in a locked filing
cabinet.  The printed application forms and supporting documents were retained with the
registers in one location and partially in another, the remainder were stored in files within the
office area which are locked when unattended.  Where electronic versions are retained, these
are saved in the secure shared drive areas managed by ICT service.   
Burial records are available to those with authority to access them and a General Data Protection
Regulations (GDPR) compliant version made available to the general public upon request
35. The BACAS system is able to apply access restrictions based on specific roles and user location,
however, this is not currently implemented due to the method of accessing the system. 
Unrestricted access for all users of the BACAS system provides resilience across the service but it
also increases the risk of unauthorised access and errors affecting data integrity.   
Action Plan 3
36. Leavers are promptly removed from the BACAS system when leaving the service, however this
does not prevent them having access if moving to another post within the Council and network

Page 10

10 
Argyll and Bute Council – Internal Audit Report – Burial Records, June 2023
access is retained.  Employees leaving the Council are removed from the ICT network as part of
the corporate leaver process.   
Action Plan 3
37. There is no requirement for specialist stationery for system output.  Printing is managed by the
corporate print server which requires a personal access code to facilitate printing of documents.  
38. It is not possible to make burial registers available to the public to view as the lair holder
information may be covered by General Data Protection Regulations (GDPR).  Searches can be
made on behalf of members of the public upon completion of the lair enquiry form and payment
of the associated charge.  Officers will provide the applicant with the information requested and
exclude any personal information they are not entitled to receive.

Page 11

Appendix 1 – Action Plan 
No. Findings & Recommendations Risk Agreed Action Responsibility / Due Date
High 1
No Procedure for Records Management 
Finding:  There is no consistent approach to updating and
managing burial records across the Service. 
Finding:  Private burials on home ground do not appear to
be authorised or registered. 
Finding:  Officers are printing documentation provided by
funeral directors and applicants via email unnecessarily.   
Finding:  Documentation was missing or could not be
located at the time of the audit visit. 
Recommendation:  A unified approach to records
management should be adopted to establish consistency
and provide resilience across the service.  Additionally, a
sample of burial records should be periodically checked for
accuracy.  This should be documented in a procedure note
and issued to the relevant members of staff. 
An offence may be committed
under The Act as data may not
be fully or accurately
populated on the BACAS
burial system and lair/burial
registers. 
Records may be misplaced or
difficult to locate. 
A unified approach to records
management will be implemented
and documented in a procedure
note.  This will include a
requirement for periodic sample
checking to take place. 
Operations Manager,
Roads and Infrastructure
Services 
30 June 2024
Medium
2
Review of Policies and Procedures 
Finding:  Policies and procedures provided to the auditor
contained no evidence of recent review or were not dated. 
Recommendation:  Policies and procedures should be
subject to periodic review and updated as required. 
Updated documents should be promptly circulated to staff
and published on the Council’s website where appropriate. 
Policies and procedures may
not reflect current working
practices. 
Policies and procedures will be
reviewed and updated if required. 
These will be re-issued to staff
and published where appropriate.   
Operations Manager,
Roads and Infrastructure
Services 
30 June 2024

Page 12

12 
Argyll and Bute Council – Internal Audit Report – Burial Records, June 2023 
No. Findings & Recommendations Risk Agreed Action Responsibility / Due Date
Medium
3
Access to BACAS 
Finding:  BACAS is located on a terminal server and is
available to all employees with access to that terminal
server as no further user authentication is required to gain
full system access.   
Recommendation:  Liaise with the Council’s ICT Service
and system supplier to establish a more secure means of
access to BACAS.   
Unauthorised users may gain
access to the BACAS system
and affect the integrity and
security of the data. 
The system supplier will be
approached to activate the login
function within the system to
provide an additional layer of
security. 
Operations Manager,
Roads and Infrastructure
Services 
31 December 2023
Medium
4
BACAS Licences 
Finding:  The Council has purchased 8 licences for BACAS,
however, it is unclear if these are user or concurrent
licences and whether 8 licences are the optimum required.   
Recommendation:  Management should undertake a
review of licences for the BACAS system. 
The council may have the
incorrect number of licences
in place to access the BACAS
system resulting in legal
challenge. 
The Council will liaise with the
system supplier to ensure the
optimum number of licences are
in place to maintain service
delivery. 
Operations Manager,
Roads and Infrastructure
Services 
31 December 2023
Low 5
Additional Functions within BACAS 
Finding:  BACAS system has additional functionality that is
not currently utilised to provide efficiencies. 
Recommendation:  Liaise with system provider and other
Local Authorities to establish which additional features
would provide benefits to the service. 
BACAS system is not fully-
utilised to provide efficiencies
and best value. 
The service will liaise with the
system provider and other local
authorities to identify useful
additional system functionality
and arrange training for
implementation. 
Operations Manager,
Roads and Infrastructure
Services 
30 June 2024

Page 13

13 
Argyll and Bute Council – Internal Audit Report – Burial Records, June 2023 
No. Findings & Recommendations Risk Agreed Action Responsibility / Due Date
Low 6
Historical Register Information 
Finding:  The Burial and Cremation (Scotland) Act 2016
(The Act) requires information to be retained electronically
although this is not currently in force it will be at a future
date.  The BACAS system has been partially updated with
historical information recorded in burial registers, it has
not been possible to update with all information due to
the volume of work involved.   
Recommendation:  Source temporary additional resource
to update historical burial records on BACAS. 
Burial records may not be fully
electronic when part 7,
section 102 of The Act comes
into force. 
The service will source temporary
assistance to update records
during Summer 2024. 
Operations Manager,
Roads and Infrastructure
Services 
30 June 2024

Page 14

14 
Argyll and Bute Council – Internal Audit Report – Burial Records, June 2023
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).

Page 15

15 
Argyll and Bute Council – Internal Audit Report – Burial Records, June 2023
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.