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8 - 2023 03 28 IA action points follow up Q3

North Ayrshire Council · 28 March 2023
Back to Audit and Scrutiny Committee — 28 March 2023 and its agenda

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NORTH AYRSHIRE COUNCIL 
28 March 2023 
Audit and Scrutiny Committee 
Title:    Internal Audit and Corporate Fraud Action Plans: 
Quarter 3 update 
Purpose:  To advise the Audit and Scrutiny Committee on the progress
made by Council Services in implementing the agreed actions
from Internal Audit and Corporate Fraud reports as at 31
December 2022. 
Recommendation:  That the Committee (a) notes the current position with the
implementation of Internal Audit and Corporate Fraud actions;
and (b) challenges those Services that have not implemented
actions within the previously agreed timescales. 
1. Executive Summary 
1.1 The CIPFA document 'Audit Committee Principles in Local Authorities in Scotland'
highlights that Audit Committees should monitor and review the progress made in
implementing audit recommendations. 
1.2 Service managers are responsible for ensuring that agreed actions arising from
Internal Audit and Corporate Fraud reviews are implemented.  This provides
assurance that identified control weaknesses have been addressed and are being
managed effectively. 
1.3 All actions are monitored on the Pentana system and service managers are
responsible for updating Pentana as they progress each action.  This enables Internal
Audit to monitor progress on a 'real-time' basis and address any delays in
implementation. 
1.4 This report details the position at 31 December 2022. 
2. Background 
2.1 The last report to the Audit and Scrutiny Committee on 15 November 2022 highlighted
that there were 13 actions outstanding at the end of September 2022: one that had not
been started or were only partially implemented and 12 where the due date had not
yet passed.

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2.2 In addition to these 13 carried forward actions, there have been 12 new actions
agreed, giving a total of 25 action points for review. 
2.3 Services have completed 16 actions since the last report.  All Council Services are
required to retain evidence of work carried out in completing their actions and Internal
Audit carries out 'spot-checks' on a sample of completed actions on an ongoing basis. 
2.4 Of the remaining nine actions, eight were either not started or only partially complete
at 31 December 2022 and the remaining action was not due for completion until after
that date. 
2.5 Appendix 1 to this report provides the Committee with full details of the eight actions
that were not completed within the agreed timescales. 
3. Proposals 
3.1 It is proposed that the Committee (a) notes the current position with the
implementation of Internal Audit and Corporate Fraud actions; and (b) challenges
those Services that have not implemented actions within the previously agreed
timescales. 
4. Implications/Socio-economic Duty 
Financial 
4.1 None. 
Human Resources 
4.2 None. 
Legal 
4.3 None. 
Equality/Socio-economic 
4.4 None. 
Climate Change and Carbon 
4.5 None. 
Key Priorities 
4.6 The effective implementation of agreed Internal Audit and Corporate Fraud actions
helps to support the efficient delivery of the strategic priorities within the Council Plan
2019-2024.

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Community Wealth Building 
4.7 None. 
5. Consultation 
5.1 Council Services are consulted during the completion of each Internal Audit and
Corporate Fraud review and have also provided updates on progress made in
implementing action points. 
Mark Boyd
Head of Service (Finance) 
For further information please contact Laura Miller, Senior Manager (Audit, Fraud, Safety
and Risk), on 01294 324524. 
Background Papers
None.

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Actions due by 31st December 2022 but not started or partially complete 
Code CFT3120f Description
Audit Action: Education Service should consider routes to recover the embezzled
funds as recommended for any financial loss to the Council, through fraudulent
activity, in its Counter Fraud and Corruption Strategy. 
Audit Risk: Loss of council funds, No deterrent or consequences for wrongdoing or
breach of Council policy, procedures and regulations.  
Priority 1 Latest Note
Legal Services have advised the Service not to progress recovery until the outcome
of the court case is known, as the court may impose repayment on the subject. The
case is currently still pending at court. Next review date, as agreed with Audit, is 30
April 2023.
Progress Bar  Original Due Date 30-Apr-2022 Due Date 31-Oct-2022
Parent Code & Title CFT3120 Allegation against an Education Business Assistant (Early Years)
Managed By Lindsay Morris
Assigned To Lindsay Morris

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Code IA2017PA020b Description Data protection information awareness for schools training should be agreed and
implemented as soon as possible. 
Priority 1 Latest Note
There is only one school left to complete this training, which is Garnock Campus.
Sessions have been arranged at this school twice, in November 2022 and February
2023, and on both occasions these were cancelled at short notice due to trainer
availability.  The Head of Service (Democratic Services) has given a commitment that
the training will proceed at the next agreed date, which is 30th May 2023.
Progress Bar  Original Due Date 01-Jun-2018 Due Date 22-Nov-2022
Parent Code & Title IA2017PA020 Email Controls In Education
Managed By Andrew McClelland
Assigned To Susan Lauder 
Code IA2019IJB001d Description
HSCP Management should work with officers from East and South Ayrshire HSCP’s to
progress the fair share methodology at the earliest opportunity, including developing
detailed Directions with commissioning plans  
Priority 1 Latest Note
The pan Ayrshire work on Directions has recommenced and workstreams have been
agreed to take forward the elements in relation to - Integration Schemes, Set Aside, Joint
Commissioning Plans and Lead Partnership Arrangements. Expected completion date
31st March 2024.
Progress Bar  Original Due Date 31-Mar-2019 Due Date 31-Dec-2022
Parent Code & Title IA2019IJB001 IJB Lead Partnership Arrangements
Managed By Caroline Cameron
Assigned To Caroline Cameron

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Code IA2020PA007a Description
Audit Action:  Carefirst should be considered as a storage location for holding all
relevant placement information – as a replacement to the current systems being
used. 
This would ensure that all data is held securely against each young person’s record,
whilst remaining accessible to those with appropriate system access rights. In
addition, Carefirst could be used to hold financial cost information on each placement.
This would reduce the reliance on spreadsheets. 
Audit Finding: Highly sensitive young person placement data is being kept in paper
files by Education, with no direct electronic equivalent being available. 
Risk: Data loss due to paper files not being backed up; inability to locate highly
confidential data; GDPR breaches  
Priority 1 Latest Note
We now have a secure filing system for all Psychological Service files - Fast Online
Referral Tracking (FORT) - we still need to complete archiving our paper files.
Archiving is expected to be complete by the end of June 2023. 
Progress Bar  Original Due Date 31-Dec-2019 Due Date 31-Dec-2022
Parent Code & Title IA2020PA007 External Residential and Education Placements
Managed By Caroline Amos
Assigned To Gail Nowek

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Code IA2021PA009b Description
Audit Action: The team should liaise with the Transformation team to streamline this
part of the process and reduce the number of times the same information must be
keyed. 
Audit Finding: The admin team are required to update the budget monitoring
spreadsheet, an operational access database and the CareFirst system at each stage
of this process for all council tenant jobs. In addition, the access database is not
supported by IT Services.
Risk: Inefficient use of staff time and increased risk of keying errors.  
Priority 2 Latest Note
We are currently working with the Eclipse team to build the Community OT process
into the system.  We are hoping to capture reporting information within this process. 
Unfortunately there have to be no new developments to CareFirst therefore this will
be hopefully come into place by August 23.
We are also running our budget reports from Integra and validating the information
against our old process.  Once we are confident that this is accurate the database
and some of the fields in the spreadsheet can be reduced.  Validation will run for
approximately 3 months.
Progress Bar  Original Due Date 31-Dec-2021 Due Date 31-Dec-2022
Parent Code & Title IA2021PA009 Aids and Adaptations
Managed By David Thomson
Assigned To Lynn Kirkland

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Code IA2022PA019b Description
Audit Action: A minimum technical standard for CCTV systems should be set for the
Council. A Council-wide audit of CCTV inventory should be carried out to assess
compliance of CCTV assets against the standards, which will give an indication of the
level of capital investment required to bring the Council’s CCTV systems up to an
appropriate standard and form the basis of a bid for capital.
An approval process should be introduced to ensure new CCTV purchases meet the
requirements of the standards.
Audit Finding: Audit were advised that there are various capital budgets in place
covering vehicles and property lifecycle investment. However, there is no formal
replacement programme for CCTV equipment.
Risk: Substandard systems that aren’t fit for the intended purpose. CCTV footage is
not available or not usable when required.  
Priority 2 Latest Note
The corporate asset register for all CCTV systems has been completed, however it is
evident that the data which has been returned by the services requires to be further
scrutinised in terms of both the DPIA’s and the physical assets reported. Work,
including cross checking with other council data sets, is underway to ensure that all
systems have been recorded and Protective Services are exploring the best method
of capturing the physical data. The options being explored for this are either
establishing an in-house team or utilising the existing the CCTV maintenance
contracts and a budget pressure bid of £40K has been submitted for 23/24 to
commence this work as soon as possible. Protective Services are, on request,
currently advising on the operational requirements for new or replacement systems to
ensure compliance for projects ongoing at the moment. This process will be finalised
and formally embedded once the quantity and quality of the physical assets has been
fully determined. The Corporate CCTV policy, published in August 2022 is being kept
under review to take account of industry best practice and developments. Work is
underway to rollout the I-Learn CCTV awareness course for those operating and
responsible for CCTV systems which is anticipated to “go-live” on 10th March 2023. 
Note that that this essentially forms phase 1 of a wider project to have fully compliant
council CCTV systems, subsequent phases being the physical asset surveys, then
the prioritised replacement/removal programme. The quantum on funding required

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will be established on completion of the physical surveys. Expected completion of
audit action by end of financial year 2023/24.  
Progress Bar  Original Due Date 30-Jun-2022 Due Date 31-Dec-2022
Parent Code & Title IA2022PA019 CCTV in Council Buildings and Vehicles
Managed By Aileen Craig
Assigned To Mark Boyd; Russell
McCutcheon 
Code IA2023PA006b(1) Description
Action Description: Services should revisit all agency staff transactions in 21/22 and
assess whether these could have fallen within the scope of IR35.  All decisions
should be evidenced, and if deemed within the scope of IR35 appropriate corrective
action should be taken.
Finding: IR35 is not being considered, evidenced, and applied consistently
throughout the Council.
Risk: Council faces fines and penalties from HMRC for not correctly applying IR35
legislation.
Priority 1 Latest Note
This has been progressing – we identified Lynne Ferguson (Business Support) and
Lee Thomson (Finance) to be the experts around IR35 and undertake the training,
who could then be a point of contact for managers who were looking at engaging
someone via an agency.  3 of the CFJ SMT have now completed the training.
New completion date: 31/3/23 
Progress Bar  Original Due Date 31-Oct-2022 Due Date 31-Oct-2022
Parent Code & Title IA2023PA006 Off Payroll Working (IR35)
Managed By Alison Sutherland
Assigned To Alison Sutherland

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Code IA2023PA006b(2) Description
Action Description: Services should revisit all agency staff transactions in 21/22 and
assess whether these could have fallen within the scope of IR35.  All decisions
should be evidenced, and if deemed within the scope of IR35 appropriate corrective
action should be taken.
Finding: IR35 is not being considered, evidenced, and applied consistently
throughout the Council.
Risk: Council faces fines and penalties from HMRC for not correctly applying IR35
legislation.
Priority 1 Latest Note
This has been progressing - we identified Lynne Ferguson (Business Support) and
Lee Thomson (Finance) to be the experts around IR35 and undertake the training,
who could then be a point of contact for managers who were looking at engaging
someone via an agency. 1 of the MH SMT has now completed the training
New completion date 31/3/23 
Progress Bar  Original Due Date 31-Oct-2022 Due Date 31-Oct-2022
Parent Code & Title IA2023PA006 Off Payroll Working (IR35)
Managed By Thelma Bowers
Assigned To Thelma Bowers