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HeritageAssets_FinalReport

Argyll and Bute Council · 20 December 2022
Back to Audit and Scrutiny Committee — 20 December 2022 and its agenda

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Argyll and Bute Council
Internal Audit Report
November 2022
FINAL 
High Medium Low VFM
Number of
Findings
0 1 5 0 
Heritage Assets
Audit Opinion: Substantial

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Argyll and Bute Council – Internal Audit Report – Heritage Assets, August 2022 
Contents 
1. Executive Summary ........................................................................................................................ 1
Introduction ............................................................................................................................................ 1
Background ............................................................................................................................................. 1
Scope ....................................................................................................................................................... 2
Risks ........................................................................................................................................................ 2
Audit Opinion ......................................................................................................................................... 2
Recommendations ................................................................................................................................. 3
2. Objectives and Summary Assessment ........................................................................................... 3
3. Detailed Findings ............................................................................................................................ 4
Appendix 1 – Action Plan ..................................................................................................................... 10
Appendix 2 – Audit Opinion ................................................................................................................. 13 
Contact Details 
Internal Auditor: Mhairi Weldon 
Telephone:  01546 604294 
e-mail:   Mhairi.weldon@argyll-bute.gov.uk 
www.argyll-bute.gov.uk

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Argyll and Bute Council – Internal Audit Report – Heritage Assets, August 2022
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 heritage assets.
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 has a remarkably rich and diverse historic and cultural heritage reflecting
thousands of years of historic development.   
5. Heritage assets are intended to be preserved in trust for future generations because of their
cultural, environmental and historical associations.  In common with other Local Authorities, the
Council is responsible for caretaking these interesting, rare and unique artefacts.  This includes: 
 the records, civic chains and regalia of former parish and burgh councils, Argyll County
Council and Bute County Council 
 Anderson Trust Collection of paintings of Helensburgh and District
 Argyll Collection of prints, paintings, ceramics, textiles, drawings and sculpture
 McGrory photographic collection of Kintyre 1890 – 1911 (partially reproduced from
original glass plates)
 Other heritage assets including schools, museums, libraries, public art, scheduled
monuments and grave yards and historic gardens and landscapes.   
6. Sound asset management is crucial if the Council is to make best use of the resources available
to it to deliver its overall aims and objectives.  Asset management is a structured and systematic
approach to managing assets on an ongoing basis to address all phases of its life-cycle.  Effective
asset management planning means knowing what you own, where it’s located, it’s value, what it
costs you, what it will cost you in the future, whether it will support current and future service
delivery and who is responsible for it.  Asset management is the process of ensuring that the
Council’s Assets are:
 Fit for purpose
 Used efficiently
 Maintained on a sustainable basis
 Matched in investment terms to service needs

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Argyll and Bute Council – Internal Audit Report – Heritage Assets, August 2022 
7. The Corporate Asset Management Strategy acknowledges that in preparing Service Asset
Management Plans, Service Asset Managers must consider sharing assets with Community
Partners and Third Sector to maximise public benefit.  Heritage assets are therefore managed
across Council Services and also in partnership with LiveArgyll and Kilmartin Museum who make
arrangements for artwork and historic artefacts to be displayed at various locations throughout
Argyll and Bute. 
8. Heritage assets are reported in the Council’s balance sheet at insurance valuation which is based
on market values and are updated periodically.  These assets are deemed to have indeterminate
lives and a high residual value and it is therefore considered inappropriate to charge
depreciation. 
9. In February 2022, another local authority reported that 1,330 objects from their art gallery and
museums’ collection with an aggregate value of just under £200k were missing due to thefts,
historic losses or unconfirmed location. It is therefore important that suitable measures are in
place for the management and control of such assets.
Scope 
10. The scope of the audit was to review the management and record keeping of heritage assets as
outlined in the Terms of Reference agreed with the Head of Commercial Services on 30
September 2022. 
Risks
11.  The risks considered throughout the audit were:
 SRR02:  Condition and suitability of infrastructure & asset base
 Audit Risk 1:  Heritage assets are ineffectively managed leading to damage, loss or theft of
items
 Audit Risk 2:  Heritage assets are not catalogued with sufficient information (e.g. description,
value, location, condition and ownership)
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.

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Argyll and Bute Council – Internal Audit Report – Heritage Assets, August 2022
Recommendations
14. We have highlighted one medium priority recommendations and five low priority
recommendations where we believe there is scope to strengthen the control and governance
environment. These are summarised below:
 Officers representing the various services involved should meet to discuss the
requirements for valuation, insurance and inclusion within the Council’s Annual
Accounts and nominate responsible officer(s) to take forward any actions identified as a
result.
 The procedure followed to create and maintain archive records should be documented.
 A list of missing artworks should be provided to schools with a request to check the
premises in an effort to locate them.
 The record of artworks belonging to the Argyll Collection should be updated to include
those omitted using details from the 2016 valuation schedule.  
 The condition of civic chains should be documented when issued and returned.
 A programme of inspections to evaluate the condition of artworks belonging to the
Argyll Collection should be implemented.
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 Policy and
procedures are in
place to ensure
assets are managed
appropriately
SRR02
Audit Risk 1
Substantial High level asset management
documentation is approved by Council
each year.  Heritage assets are
appropriately managed across various
services within the Council or by
external organisations acting as
curators via formal agreement. 
Artworks and civic chains are included
within the Council’s All Risks insurance
policy however, valuable archive
documents are not.
2 A robust cataloguing
procedure/system is
in place to prevent
assets being
misplaced, lost or
otherwise
unavailable for users
Audit Risk 2 Substantial There are detailed records of assets
held within each area of responsibility. 
Artworks recorded as missing from the
museum and libraries collection have
been recovered, however only 4 of 11
have been recovered for the Argyll
Collection and one has been located in
another local authority with whom we
share ownership.  The details of 6

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Argyll and Bute Council – Internal Audit Report – Heritage Assets, August 2022
artworks were omitted from the Argyll
collection record.
3 Heritage assets are
displayed or stored
securely,
appropriately
insured and subject
to a programme of
inspection and
maintenance
SRR02
Audit Risk 1
Reasonable Museum exhibits and artworks on
display are available for the public to
view during opening hours.  Storage
areas are secure, however, in some
cases the artworks are inappropriately
stacked against each other.  Civic
chains and archive documents are
secured in council accommodation and
made available for use by prior
arrangement.  Elements of the
collections can be accessed digitally by
members of the public from their
personal devices, however there is no
access to historical archive records by
this means.  Most of the collections are
subject to periodic or ad-hoc
inspections, however, these are not
always recorded.  The Argyll Collection
is not currently rotated around schools
and is not inspected unless loaned to
external organisations who will check
the condition of the artwork.  
4 Heritage assets are
accurately reported
in the Council’s
financial statements
Audit Risk 2 Substantial Heritage assets are recorded as fixed
assets on the Council’s AIRS system
however there was no inclusion of the
civic chains nor any archive documents
considered to be of value.  The total
value of heritage assets recorded on
AIRS is correctly reflected on the
Council’s Annual Accounts. 
17. Further details of our conclusions against each control objective can be found in Section 3 of this
report.  
3. Detailed Findings
Policy and procedures are in place to ensure assets are managed appropriately
18. There is a Corporate Asset Management Strategy and Plan, together with a Capital Plan that are
approved by council at its budget setting meeting in February of each year.  These strategic
documents encompass all asset categories and their need to support and contribute to the
corporate objectives in the Argyll and Bute Outcome Improvement plan (ABOIP), they are
published on the Council’s webpage and are therefore available for public access. 
19. Heritage assets are managed across various services within the Council and also by LiveArgyll,
Kilmartin Museum and Culture, Heritage &Arts (CHARTS) Argyll & Isles who are appointed
curators with line management responsibilities.  The asset categories and the service area
responsible for their management are detailed in the table below.

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Argyll and Bute Council – Internal Audit Report – Heritage Assets, August 2022
Asset Responsible Service Area
Archaeological Museum Exhibits Kilmartin Museum (Curator support via SLA)
Social History, Natural History and Fine Arts
Collections
CHARTS (Curator support and line
management of modern apprentice via SLA)
Archive Documents LiveArgyll
Anderson Trust Artworks Collection The Anderson Trust (stored & insured by the
Council) 
The Argyll Collection  Education Services
Museum and Libraries Artworks Collection LiveArgyll
War Memorials Amenity Services
Civic Chains Members Services 
20. Service Level Agreements (SLAs) are in place between the Council and LiveArgyll and also with
Kilmartin Museum who are appointed curators for the Council’s archaeological museum
exhibits.  An annual report summarising management of the collection has been provided by
Kilmartin Museum as required by the SLA.  A further agreement is in place between LiveArgyll
and CHARTS, who will provide professional support for the delivery of services at Campbeltown
Museum and train a modern apprentice in curator responsibilities.
21. There is guidance in place to manage the museum exhibits, Archives, the Argyll Collection and
the Museum and Libraries collection, the Anderson collection is managed by a Trust out with the
Council.  A security protocol is in place to guide members and officers when civic chains are
required to be worn at events.  
22. Paintings and museum exhibits are covered in the “All Risks” section of the Council’s insurance
policy with a value assigned that is consistent with the artworks valuations that took place in
2015 and 2016, there was no valuation provided for the museum exhibits.  The civic regalia are
also covered in this policy based on the original value and adjustments made accordingly.  There
is, however, no inclusion of archive documentation within the policy despite some of these being
of considerable value, in particular there are original drawings of the Hill House in Helensburgh
by Charles Rennie Macintosh.
Action Plan 1
A robust cataloguing procedure/system is in place to prevent assets being misplaced, lost or
otherwise unavailable for users
23. Heritage assets are managed by various officers across the Council and with third-party
organisations appointed as custodians.  These assets are included within the Council’s annual
accounts in accordance with accounting standards.
24. Detailed catalogues or a register of artworks are maintained for each of the collections.  
25. There is detailed guidance on how to maintain the records for the museum collections and this is
planned to be updated in the near future.   The catalogues for the archives are maintained in a
structured format on the Council’s shared drive area and whilst there is an acquisition policy and
collecting agreement explaining what may be accepted, the process to create and maintain
these records has not been documented.  
Action Plan 2

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Argyll and Bute Council – Internal Audit Report – Heritage Assets, August 2022
26. Records held for the artworks collections and war memorials are maintained in list formats and
require little updating.  Copies of all records were provided and found to be comprehensive with
appropriate fields available for completion.
27. The 2015 and 2016 valuation schedules were reviewed, it was found that there were no
artworks recorded as missing at the time of the valuation for the Anderson Collection, however,
there were six items recorded as missing in the valuation schedule for the Museum and libraries
collection, these have all now been located and updated on the custodian’s collection record
provided.  Additionally, there are 54 entries on the Museum and Libraries collection record that
are not included within the valuation schedule as they had been added after the valuation
exercise took place.  These artworks will be included in any future valuation exercise conducted.  
28. There were 11 artworks recorded as missing in the valuation document for the Argyll Collection,
five of these have been located and six remain missing, the value of these artworks is unknown,
they are as follows:
 Unknown artist, Round Bowl, Ceramic, Green, 195mm diameter (no record)
 Anne Gillie, Drawing, 43 X 56cm (location unknown)
 Charles Mitchell, winged skull, mixed media, 64 X 64cm (location unknown)
 William Birnie, "Mains Farm, Buchlyvie", watercolour, 55 X 72cm (no record)
 Rock Samples, Rocks, granite, pumice, black rock, beige pebble and beige rock with
water worn holes(reference no. missing from list)
 Unknown (Anita Man), Penguins and two chicks, Wood carving, 210mm tall (no record)
Action Plan 3
29. A sample of 36 artworks including the 17 recorded as missing on the valuation documents and
an additional 19 with the highest values was selected from across the three collections and
records were compared with the valuation schedules of 2015 and 2016, these were found to
contain similar fields for storing information.  There was a small number of differences in sizes
recorded across the collections, however these are considered to be immaterial.
30. The review of the Argyll Collection record revealed that four of the five recovered artworks were
included, however the remaining artwork is located at another local authority with whom the
Council shares ownership and the record has not been updated to reflect this.   Additionally,
there was no detail entered against the reference number for 4 of the artworks that remain
missing and one was omitted from the record (both reference and detail).  One further entry for
an artwork that has been recovered but has a duplicate reference was not included on the
record provided.  
Action Plan 4
Heritage assets are displayed or stored securely, appropriately insured and subject to a
programme of inspection and maintenance
31. The 6 missing items noted above, one located at another local authority and one located
remotely were removed from the sample of 36 artworks leaving 28 for viewing.

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Argyll and Bute Council – Internal Audit Report – Heritage Assets, August 2022
Location Artworks
Expected
Artworks
Found
Comments
Helensburgh Library 2 2 One located in Library storage room, the
other on display in Campbeltown Marriage
Room.
Helensburgh Library
Anderson Collection
5 5 All items were located in the storage area.
Castle House
Museum
2 2 Both on display to the public near the main
entrance.
Library HQ 2 2 Both are displayed although visits are by
appointment only, one is situated on an easel
and the other on the floor against a cabinet.
Campbeltown
Museum/ Marriage
Room
7 7 Three were displayed in the Marriage room, 2
in the museum and 2 in storage.  
Schools 10 10 All 10 artworks were located although one
was at a different school from that recorded. 
32. All but one of the artworks viewed on display were appropriately fixed to a wall or mounted on
an easel, the remaining one was placed on the floor leaning against a cabinet.  The locations
allow either members of the public or school pupils to view the artworks within opening hours
and are secured within the buildings when closed.
33. The purpose of the Argyll Collection is to provide a learning resource for the young people of
Argyll and Bute that will enable them to experience fine art in an area with little access to
museums and galleries.  The artworks were formerly rotated around schools to provide a variety
of artist’s works for young people to view, however, there has been no full rotation since May
2013 and following the valuation exercise in 2016, art teachers are no longer prepared to be
responsible for transporting valuable artworks in private vehicles and no budget is currently
available to fund the professional packaging and transportation required.  The Cultural Co-
ordinator, Education is working with CHARTS to identify and apply for external funding to
reinstate the rotation of the artworks.
34. The artworks in storage belonging to the Anderson Collection and those located at Campbeltown
Museum were located in numbered racks in purpose designed, climate controlled locked storage
rooms.  The remaining artworks were located in secure storage areas, wrapped in protective
coverings and stacked upright against other artworks at floor level.  This situation is not ideal as
it is difficult to locate specific items and damage may result from the accumulated weight of
multiple artworks or movement to gain access to other items in the storage areas.  A potential
storage solution at Council Headquarters in Kilmory had been identified for the Argyll Collection
and is expected to progress under the “Our Modern Work Space” project.
35. The Council’s Members Services Officers are responsible for managing the Civic Chains.  Seven of
these are retained at Kilmory Castle in a suitable protective environment.  All seven were
present, stored in protective casing and appeared to be in good condition at the time of the
review.  The remaining two are located at Mull Museum and Inveraray Castle.  Chains are issued
by the Council Officers following authorisation from the Executive Director.

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Argyll and Bute Council – Internal Audit Report – Heritage Assets, August 2022
36. Archive records are retained in Council office accommodation in a climate controlled storage
area.  Access to records by the public is by prior arrangement and officers are present at all
times.
37. War memorials are located across the Argyll and Bute area, 16 of these were viewed and found
to be located according to the record provided, appeared to be in good condition with
surrounding grounds maintained and accessible by members of the public at any time.
38. There is no specific reference of heritage assets within the ICT Digital Strategy 2021/24,
however, the document encompasses all services with an aim to create efficiencies, savings and
improve services for both staff and customers.  Elements of the collections can be viewed on the
internet with further links provided to social media sites to obtain additional information. 
Committee records from 1995 and other information is available to the public on the Council’s
website, however, historical archive records cannot be accessed digitally by members of the
public as the system used is not able to replicate the structured format of files from the shared
drive area.  There has been some consideration of creating a new digital archive facility that
would be accessible by the public, however, this was deemed to be cost prohibitive.
39. The artworks and museum collections are marketed via websites and social media platforms
operated by the various appointed curators.  These items are non-income generating to
encourage the public to enjoy the content, there is a small charge, however, to those who wish
some research to be conducted by the archivist team on their behalf and any associated printing
of documents.  LiveArgyll are currently exploring an opportunity to generate income via the
installation of donation receptacles in some of their facilities.
40. Heritage assets are not generally disposed of due to their historical and cultural significance,
however, they may be loaned to other areas of the Council or external organisations by use of a
formal terms of agreement which is completed in each instance.
41. The museum and library exhibits are inspected prior to and following exhibitions with the
condition noted on records and dated.  Periodic artefact checks are undertaken by the museum
curator in compliance with the SLAs in place.  
42. Archive documents are inspected as part of the stock-taking process and whenever extracted for
use. The Anderson collection is managed independently by the Trust who carry out their own
inspections. Civic chains are carefully checked by a Council Officer prior to and following every
issue for use at events, however, this is not documented.
Action Plan 5
43. The Argyll Collection is not currently subject of any programme of inspection, when artworks are
loaned, the condition is checked by the external organisations.
Action Plan 6
44. There is no budget nor schedule for maintenance or preservation of heritage assets, any needs
would be of an ad-hoc nature and identified during inspections or at time of use.   Any funding
required to address identified needs for maintenance or preservation would be requested via
the appropriate channels.

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Argyll and Bute Council – Internal Audit Report – Heritage Assets, August 2022
Heritage assets are accurately reported in the Council’s financial statements
45. Heritage Assets are recorded as fixed assets on the Council’s AIRS system which holds details of
two museums, two monuments, two clock towers, 57 war memorials and 270 works of art in this
category.   One of the works of art from the sample selected for review had the incorrect value
applied on AIRS, however, the overall effect of this error is immaterial.  The values of the
remaining items correspond with those provided on the 2015 and 2016 valuation records and
excludes those that were recorded as missing at that time.  There is no inclusion of any museum
exhibits, valuable archive documents owned by the Council nor the Civic chains.
Action Plan 1
46. The total value of heritage assets recorded on AIRS has been correctly reflected in the Council’s
Audited Accounts as at 31 March 2021.

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Appendix 1 – Action Plan 
No. Findings & Recommendations Risk Agreed Action Responsibility/ 
Due Date
Medium
1
Valuations, Insurance & Fixed Assets Register
Finding:  Civic chains, archive documents and museum
exhibits are not included within the Council’s programme
of valuations.   
Finding:  There is no inclusion of valuable archive
documentation within the Council’s All Risks insurance
policy.   
Finding:  Civic chains, Museum exhibits and valuable
archive documents are not included within the Council’s
Fixed Asset Register, AIRS. 
Recommendation:  Officers representing the various
services involved should meet to discuss the requirements
for valuation, insurance and inclusion within the Council’s
Annual Accounts and nominate responsible officer(s) to
take forward any actions identified as a result. 
Valuable heritage assets
may not be
appropriately covered
by the Council’s All Risks
insurance policy should
they be lost, stolen or
damaged. 
The value of assets
stated on the Council’s
annual accounts may be
incorrect.
Officers representing
the various services
involved will meet to
discuss the
requirements for
valuation, insurance
and inclusion within
the Council’s Annual
Accounts and
nominate responsible
officer(s) to take
forward any actions
identified as a result. 
Head of Legal and
Regulatory Support 
31 March 2023 
Low 2
Archives cataloguing procedure
Finding:  Whilst there are some policies surrounding the
management of archives, there is no documented
procedure in place regarding creation and maintenance of
records. 
Recommendation:  The procedure followed to create and
maintain archive records should be documented.
Failure to document
formal policies,
procedures and
processes may lead to
the loss of skill and/or
knowledge when staff
members leave.
Procedure notes will
be reviewed and
updated.
Archives Officer
31 March 2023

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Argyll and Bute Council – Internal Audit Report – Heritage Assets, August 2022 
No. Findings & Recommendations Risk Agreed Action Responsibility/ 
Due Date
Low 3
Argyll Collection – Missing Assets
Finding:  Six missing artworks at the time of the valuation
in 2016 have not been located. 
Recommendation:  A list of missing artworks should be
provided to schools with a request to check the premises
in an effort to locate them.
Assets may have been
lost or stolen.
A list of missing
artworks will be
provided to schools
with a request to check
the premises in an
effort to locate them.
Cultural Co-ordinator,
Education
31 December 2022 
Low 4
Argyll Collection – Record Keeping
Finding:  There were no entries on the record provided
for 4 of the missing artworks, one shared with other local
authorities nor one with a duplicate reference number.   
Recommendation:  The record of artworks belonging to
the Argyll Collection should be updated to include those
omitted using details from the 2016 valuation schedule. 
Incomplete or incorrect
records may lead to
inefficient management
of assets.
The record will be
updated to include
missing artworks
identified in the 2016
valuation.
Cultural Co-ordinator,
Education
31 December 2022 
Low 5
Civic Chains
Finding:  Civic chains are carefully checked by a Council
Officer prior to and following issue for use at events,
however, this is not recorded. 
Recommendation:  The condition of civic chains should be
documented when issued and returned.
The condition of civic
chains would not be
available should the
information be required.
The record of issue of
chains will be updated
to include date
checked and condition
of chain at that time.
Members Services
Officer
31 December 2022
Low 6
Argyll Collection – Artworks Inspections
Finding:  There is currently no programme of inspections
taking place to evaluate the condition of artworks held. 
Recommendation:  A programme of inspections to
evaluate the condition of artworks belonging to the Argyll
Collection should be implemented. 
The condition of
artworks would not be
available should the
information be required
e.g. insurance claim.
Programme of
inspections will be
agreed by Education
Services
Cultural Co-ordinator,
Education
31 December 2022

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Argyll and Bute Council – Internal Audit Report – Heritage Assets, August 2022 
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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Argyll and Bute Council – Internal Audit Report – Heritage Assets, August 2022
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.