Transcript

Welcome to this committee. My name is Councillor Denise Paul, Chair of the Audit Committee. Members of the committee, I will now call your names. Please switch on your microphone to confirm your attendance. Councillor Critchard. Present. Councillor Caddy. Present. Councillor Hedges. Present. Councillor Lawless. Present. We also have present our independent member, Ilva Fotenacana. Present. I'd like us to note that Vanessa has stepped down as the independent chair. So I just wanted to thank Vanessa for her service to this committee and wish her all the best. So moving on to agenda item number one, declarations of interest. Are there any declarations of either pecuniary, other registrable or non-registrable interests? No? Okay. I had a question. Just going back to the independent member. So if Vanessa's no longer with us, will we be recruiting for another? Because I think the committee requires two. That was all. And what's the timescale? There isn't a timescale, but something was going to pick up on any other business. So, yeah. Okay. But that there isn't, so I don't need to pick it up now. So there isn't one at the moment, but it will be shared with the committee members. The item number two, the minutes from the 7th of November, 2024. Just wanted to know if members agreed that this is a correct record of that meeting. Thank you. I just wanted to mention to members as well that we're going to, we'd like to reorder the agenda to take EY first. So item number seven, we'll be taking first. Okay. Okay. Let's move on to item seven, what I failed to say. We do have members, or officers here, who will introduce themselves when they decide to speak. I'm not having a great day today. Item seven. Thank you, Chair. Alicia Atto, Chief Accountant. This paper provides an update of the external audits of the accounts for 22, 23, and 23, 24, financial years, starting with the 22, 23 accounts, as circulated for information to committee members in December, 2024. This was signed off as planned in good time ahead of the backstop date of the 13th of December. Moving to the 23, 24 accounts, these were more recently signed off ahead of the second backstop date, which was the 28th of February, and nothing has changed in terms of the expected opinion since the November committee. The final audit results report was circulated at the time, in February, but it is also included for completion within these papers as well. In relation to the expected disclaimed opinion, which have been given for the accounts, some statistics have recently been released, which we thought would be useful to note. So for 22, 23, there were 158 disclaimed opinions in England. For 23, 24, this figure was 148. These figures are higher than the full stroke final opinions nationally, so the council is in the majority of authorities affected by the approach to issue disclaimed opinions to move through the backstop dates with signed off accounts. In conclusion, the paper also discusses external audit fees, and I believe Janet Dawson and Adrian Barmer were planning to join remotely from EY, who can take further questions. Thank you. Are there any questions from committee members? Do we have EY on the line? We do. Okay, brilliant. I've got a few, I guess. Hi, good evening. I guess the first one is just on the fees. There's an additional 18,000 for the value for money commentary. I just wondered, was that because there was a problem with the value for money commentary, or was that always included? Is that something new? Why isn't that included in the scale fee? And then, I guess, as a kind of, I can maybe go through some more detailed questions in a minute, but as an overall sort of comment, what are other councils, other audit committees, and what can we do to sort of help satisfy ourselves as to the accuracy of the accounts, given that we've got an opinion which is not straightforward, that we've got disclaimer? I guess it's my overall question. Thank you. Thank you. Thank you. Thank you. Thank you. I'll try again. Can you hear me? Yes? Yes, I'm seeing a thumbs up. Is Janet Dawson here? Good. Super. Thank you. Janet Dawson here, audit partner from EY, and I'm joined by Adrian Barmer, the senior manager on the audit as well. Thank you for the two questions so far. So on the fee of 18,000, that is an element of the fee for 2223. PSAA set the fees. They're in an unprecedented situation where they had a scale fee for the audit, which would include both the financial statements audit and the value for money work. Clearly, because we have done a different scope of work for 2223, which is to move to disclaimed opinion, there's a debate within the system as to what the appropriate fee should be for that. So what they've been able to do is look at the work that we have done as part of the VFM commentary and determine a fee associated with that element of the work. What they haven't yet done is determined fees for disclaimed financial statements opinions. So it's not new or additional. It's part of the ultimate total audit fee, which will differ from the scale fee that they had originally set 18 months prior. Unfortunately, I can't give you any more information than we've told them how much it cost us to do that work. And they are now in the process of determining the fee associated with that, as they are for all those other disclaimed opinions. So that's the fee point. Thanks very much. Can I just very quickly come back and just clarify something on that? So is that 18,000 for value for money commentary? I guess what I'm trying to understand or get at, given that there's an issue with the value for money commentary, is that because we haven't provided something? Is it that high because of something that we have or haven't done? Is there some, or is it, is that just the standard sort of fee, scale fee? You're shaking your head. It's a fairly standard scale fee, Councillor Caddy, for the scope of work that we're required to do under the code of audit practice. There were no, we looked closely, spent some time looking at the risk of significant weakness around the arrangements for your joint venture, but found no exceptions to that. So it reflects the amount of work we need to do across the value for money arrangements and the work that we did in that particular area for 22-23. Councillor Hedges. Thank you very much. Just wondered, in terms of the executive summary, there are a number of misstatements that were corrected. And I just wanted to make sure that, one, the council hasn't been disadvantaged in any way. And how much comfort do you have that there are not as many, they're not more mistakes throughout the document? Thank you. Just because there were quite a few large ones. So thank you for the question. And also this links to Councillor Caddy's second part of her question around, you know, how satisfied can you be about the accuracy of the accounts? What we've done is set out in Appendix A the summary of assurance that we were able to gain. So we try to break that down over the different areas of the significant counts within your statement of accounts, your financial statements, and to describe the amount of work that we have been able to do and the extent of assurance that that then gives us over the numbers. So you'll be able to see that it's not that's not a reporting requirement on auditors, but we felt it would be helpful for you to understand how we then move forward and build back assurance over the coming couple of years. So you'll be able to, I think, draw an inference from that as to where we have substantial assurance. We've been able to complete all of our procedures and where we've got partial or limited or no assurance because of the nature of the work that we've been able to do or not. And that will give you an indication of where there may be other issues. What we've done is report to you all those errors that we've identified above our reporting threshold so that you can see what's been adjusted and what's not been adjusted. Councillor Critchard. Excuse me. Thank you. And this is probably might be a question for officers as well as for you is obviously this is we've seen an earlier version of this before. Could you highlight any issues that have in the final version that have we haven't already seen at this committee? Is there anything we should be specifically looking for? I may I may hand over to Adrian because he was able to attend your November meeting. I was unfortunately not able to be there. There's nothing significant that comes to mind. I think at that point we were reporting to you that we had an issue on council dwellings that we were had not yet been able to carry out our work on group accounts. And that remains the case. I'm not sure whether there are any of the specific errors that we identified that weren't reported to that previous committee. I know that we didn't report to you at that point around pension liability on London Pension Authority that we were unable to get assurance over that due to the triennial valuation that had taken place in 22, 23. But other than that, I'm not aware of any other significant areas. Adrian, do you want to come in? No, no, I think that's consistent, Janet. So I think the areas we were still working on in November, the areas that actually flow through into the summary of assurances where we actually didn't have assurance in the end. So I think most of the other areas that we reported in November, the work on the audit was substantially well progressed. And actually, the committee was kind of informed of kind of the key issues coming out from the audit. So I think, as Janet said, they're probably the key issues was around council dwellings group and also just the pensions point. Councillor Cavy. Thank you very much, Chair. Just on page 89 of our PAC, which I think is page 11 of your PAC, under fraud risk, there's a comment on risk of fraud in revenue and expenditure recognition through the inappropriate capitalisation of revenue expenditure. But sort of reading the narrative, why is that a sort of particular fraud risk rather than just a misstatement risk? I just wondered if there was a bit more background behind that. Well, perhaps if I start, Adrian can come in on the specifics there. So across all audits, we would set a risk of fraud in revenue and expenditure recognition. And within local government, the main area where that can be manipulated is where you inappropriately capitalise revenue expenditure. So we would do testing in that area to ensure that revenue expenditure isn't being put on the balance sheet and therefore taken off your bottom line. So what we've identified in our testing is a number of different misstatements in there. Adrian, do you want to just provide a little bit more information on those? On mute. Yeah, so the errors were reported in there were really, none of them were indicative of any type of fraud. And there were really just some inconsistencies within the treatment of Reficus itself. But as Janet said, it is a consistent approach where we would have that higher risk around Reficus transactions. We test those at a substantially high level to be able to give us enough assurance to make sure that everything is correctly classified. And as I say, there was nothing indicative of any fraud. It was mainly just around some of the actual treatment of the Reficus expenditure itself. Thank you very much. And then just one more was on the risk of significant weakness, which was identified in the value for money arrangements. It's page 107, but it's referred to throughout the pack. I guess, is it possible to just get a bit more information? What is the very sort of, what is the specific risk there? And what should we have done differently? What systems could we or should we have had in place to avoid this? And are the group accounts, because I know the group accounts weren't actually late last time we met. Are they now late and missing? And I just wondered, it's probably a question for officers rather than for EY, but I just wondered if they were on their way or what the problem was. So from the value for money arrangements work that we do, we're required to look at, as I say, the arrangements in place to ensure that you have appropriate governance over your main decisions, you're using appropriate information, and that you are looking at your financial position as one particular criteria that we need to focus on. So when we were setting the plan and discussing with the Section 151 officer, Fenella Mary, and her team about the key risks within the business, we were very aware that the organization was considering the future of the joint venture, how it would take that forward within the context of those risks in terms of appropriate governance arrangements, managing any financial risk, and using information appropriately. Now, from our perspective, that was a significant issue that the organization was dealing with throughout the year. And so we raised it as a risk of significant weakness to say, you know, there's a risk that you may not put appropriate arrangements in place. So let us work with you to understand how your governance is working across that, what information you're using, what support you're getting from advisors, and how are you managing the risk to the business, whether it's financial, reputational or operational. So we have looked through at a reasonably high level what those arrangements have been, how the organization has responded to that risk. And we were satisfied that the organization wasn't leaving itself exposed to a significant weakness in any of those three domains for this year. So it's an area, I know there's significant work still ongoing in terms of how the organization then moves forward with the program of work that was being handled by the joint venture. And so it's an area that we'll continue to look at and consider through 24, 25 and beyond. I hope that helps. Thank you very much. To be perfectly honest, it doesn't really, because I'm interested to know, you know, from reading this, it sort of implies that something has gone wrong or something hasn't been available, something hasn't been made available, or it hasn't been managed in a way that's sort of appropriate to minimize the significant risk, which you clearly think exists. And your explanation sort of hasn't explained what we should have done differently, or would you have not expected anything to be done differently? Is the mere existence of it a significant risk in and of itself? I'm just wondering if one of the officers wanted to come in. Can I just explain the value for money arrangements work, though, first? Because I understand your question, which is, you know, should we have done something different? Are we exposed to a risk? Our responsibility is to look across those arrangements, identify where there may be a risk, and consider whether the arrangements are sufficient to manage the risk. So I'm not in a position to say, could you have avoided it in the first place? I'm looking at, now that you have this business risk, what have you done to manage that? And I was satisfied that there were sufficient arrangements in place to do so. But let me hand over to the officers. Thank you, Chair. Catherine Burstyn, Director of Financial Management. Hopefully what Janet just mentioned then was more helpful in that it's flagged as a risk because it's there, exactly that, Councillor Caddy. And EY are satisfied that they, we've been in dialogue with them about our approach and about the future arrangements. And as you said, that's being reported to Housing Committee for the future building arrangements that were previously to be delivered by the JV. In terms of the group accounts, we did provide the accounts to EY. But because of the backstop date, the full group accounts audit has not been completed. So it's not that there's any issue with it. It's just that the time, because of that backstop date, hopefully that helps. That's really helpful. Thank you. The members... Oh, over. Hello. So on the Appendix A, page 130, which you mentioned before, you have indicated if you've got, like, substantial, partial, no assurance. And you have mentioned that you are building a plan for 24-25 to regain assurance. So will the 24-25 opinion be clean now, or do you expect a disclaimer again? So the 24-25 opinion is unlikely to be clean because of the nature of disclaimed ordered opinions. So where you have no assurance over your opening balances in the 23-24 accounts, then clearly those comparatives will move forward. So we'll be looking at transactions in year for 24-25, some of which will have comparatives from this year, where we were unable to provide full assurance. So it is unlikely. If you're used to corporate accounts where they're disclaimed, you would expect a three-year cycle to be able to move from disclaimed accounts to clean accounts. The issue that we have, Ilva, is also that there is as yet no guidance available in the system for where the focus needs to be by auditors to rebuild that assurance. So we are working really closely with the likes of MHCLG, the NAO who set the code, and the FRC who regulate us as auditors to understand whether they have an expected approach and are going to provide guidance for local government auditors to build that assurance back consistently. Otherwise, we as a firm will take a view on how we best do that. So we are building that plan at the moment. We're seeking guidance from the system, and we'll be able to give you more information about how that will build back, or how we anticipate that will build back over the next couple of years in our audit plan for 24-25. Okay, so there will be probably some areas where you will just highlight that you are expressing like a disclaimer because you cannot get, yeah? So will that be mentioned in the opinion? Yes, so you may have a disclaimed opinion again, or you may have, and as we move through, you would expect to move to a limitation of scope where certain areas, a few areas are, there hasn't been sufficient assurance, and then you would move on to a clean opinion ultimately. But it will take a number of years to move to that position. Okay, and from the areas that you have highlighted, which one is the riskiest one that we should be paying attention until we get full assurance? Great question. The one that is most difficult to build back is assurance over reserves, and that is where the main focus of attention has been across local government because when you haven't got the detail of what's been going through those reserves in previous years and assurance over those, you need to work backwards to gain that. So that's the most difficult area to build back. I think there isn't any other aspect of it that I think is more or less risky. I think that's just the complex area to gain assurance. Okay, thank you. Thank you. Just are members happy to agree the recommendations? There's three recommendations. Yep, agreed. So moving on to agenda item three, housing ombudsman complaint, paper number 25 to 110, pages 3 to 14. Are there any questions from the – well, I've got to wait for you. I'll just get Andrew just to introduce us if you don't mind. Thanks. Thank you, Chair. I'll give a brief overview. It's quite a straightforward or a short report. So essentially, the audit team completed a piece of work following a finding by the housing ombudsman in relation to some properties in the all-state state where there had been water ingress. And the ombudsman was unsatisfied with the way that the council as landlord had dealt with the complaint itself from the member of the public and the repairs that needed being completed as well. The ombudsman made a number of orders for the council to comply with, one of those being that an independent review was completed and reported to a governing body or equivalent within the council so that there could be scrutiny around recommendations that were being made and the implementation of those recommendations over a period of time. So the internal audit team was asked and accepted the role of completing the independent review because the audit committee is well-placed to receive the recommendations from us. And then those recommendations will be followed up as part of the usual audit reporting process where we come back to audit committee with updates on recommendations. The work that we completed found that there were two areas where work was still outstanding from the housing team, and those were the recommendations that were in the report that's the Appendix A to this. I think it's fairly straightforward. So we're asking the committee to note the report itself and to note the fact that we will be bringing the recommendations back to you to determine once they've been or to acknowledge once they've been completed in full. The first full lot will be completed in six months from the point where the work was completed, so that will mean that for us we'll be doing it in May. So we'll bring our first report back to the June-July audit committee meeting with an update on the recommendations. And we have Tom Cordy with us from housing to answer any questions if you have any specifics. So Tom was involved in dealing with the ombudsman complaint and overseeing the work that's been completed to date. Thank you. Thank you. Did Tom – is Tom here just to answer some questions or – yeah? I am. Okay. Sorry, I'm on my own. He's behind him. Okay, has the committee got any questions? Hi, Mr. Crawley. I don't know if you can just to start with just give us a really quick rundown just of broadly what the problem was and how the problem arose because it's not sort of clear from the paper where the sort of breakdown in communication, you know, what happened because obviously it was partly to do with the co-op as well. So it would be good to understand sort of practically how it worked, how it broke down, what the problem was, and then just broadly what we need to do to change, to fix it. Sure. So the problems were leaks from the roof of the sort of main block on All Saints Co-operative into the leaseholder's property. They reported first, I think, in – well, they reported in 2018-19 that we'd undertaken repairs to resolve them. They were then reported again in 2020, and we undertook further repairs. Now, at that time, there was a survey undertaken, and the recommendation was that we should start to think about programming it in for roof renewal. And that didn't happen at that point when it should have done. There was quite a lot of back and forth between the area housing team and the co-operative where there was discussion about, you know, what further works might be required to resolve the roof leaks fully but without really doing the referral that needed to be done to recommend it for full roof renewal by a major works team. And that took probably another two years before that referral that actually happened. And that's really the main failure. It's that liaison between the co-operative and the area team about kind of the expertise and responsibility for making that referral. And in the meantime, the leaseholder was suffering from sort of intermittent water ingress, and we were undertaking – or rather, co-operative were undertaking temporary repairs, but they weren't being successful because ultimately the roof had come to the end of its useful life and needed to be renewed. Another factor was that while those issues were ongoing, the co-op wasn't effectively updating the leaseholder in terms of what was happening, what the delays were and why. The third main point which the Ombudsman picked up on was in relation to the stage one complaints that the leaseholder made to the co-operative, and there was a delay in terms of the co-operative responding to that. So in terms of the actions that we've taken to address the issue, the main one was probably the – of introducing some training to the co-ops, which I undertook with all of them in October, not just All Saints, but all of the 10 co-op tips that we look after in relation to complaint handling and what to do in that situation should it arise again. There have also been some staff changes within the area housing team, which were part of the reason why there was the poor sort of level of assistance from that team at that time, so those have been addressed. I've taken the sort of recommendations to the co-op forum, presented it to the co-op, and was there again last night discussing it with them. Another change which will be adopted across all of our housing stock, which we were planning to do anyway, but I think it's been hastened really by this report, was purchasing something called NEC Go Mobile. So NEC is the housing management system we use to raise repair orders, and obviously it contains a huge amount of data on our assets and the quality of our stock. And what that NEC Go Mobile will allow us to do is to have sort of scheduled annual inspections of all our roofs across all our housing stock, and then gathering data on the condition of those roofs, which will then feed into a kind of more data-driven approach to planning in major works such as roof renewal. So that's been purchased, and just in the process of working out the kind of process for how that can be implemented. And just to sort of sum up, the compensation has been offered to all of the leaseholders that's been affected. Other than the leaseholder affected by the report, one has accepted the compensation, and the other three are kind of waiting to see whether they would decide whether to accept it or not. I think they'd want to wait for the roof renewal to actually take place before they decide whether to accept the offer or not. And the roof renewal is expected to start in the summer at the moment. Thank you very much. Just a very quick follow-up. Do we expect that the changes that are going to be made will essentially eliminate the risk of this happening again, or is part of the problem the fact that it involves a co-op and we aren't able to manage the staff of the co-op in the same way that we would manage our own staff and we don't have the same controls? And I guess my question is, has the ombudsman kind of judged us on that, and do we need to think of a way of kind of working around that to be able to get some reassurance that our residents are going to get the correct treatment, or is it much more our processes rather than the co-op issues? I think it's a bit of both. I think it's a fairly unique situation where the co-op and the sort of housing department were at fault. We have sort of made more robust our monitoring of the co-operatives over the last year or so, largely in response to kind of new health and safety legislation, but also to cover eventualities such as this. So that in itself will help. And then, as I said, I think the NEC Go Mobile sort of app and the process that will go with that in terms of roof inspections should eliminate the chances of this happening again. Because in the past, we've been reliant on officers who raise the orders for roof repairs, essentially noticing the fact that they're raising lots of orders to address a roof, a particular roof, and then realising that it should be renewed relatively soon, and then programming it in. Whereas this new kind of processing system should allow us to make sure that we're much more kind of, it's much easier to monitor that process, because we know that every single roof will be inspected every year, and we can see what the outcome of that inspection was, and then what was done in response to that, whether it was a referral, or whether it was kind of noted that the roof has a few more years left in its life. Just before I hand over to you, I've just got one question myself, just around the report itself. I think it was being shared with the Director's Board, and also you mentioned that it was shared with the Co-op Forum. Was there any sort of feedback or anything there at those, once that was sent through to those individuals? No, I mean, I think the Co-op, it was a useful exercise, obviously, to share it with the Co-op Forum, because all of the other Co-ops could see it and learn from it as well. And as the report indicates, one of the things that we've done is to add a kind of learning from complaints agenda item to the Co-op Forum, so that, you know, not just this particular complaint, but any other complaints that we have, and there's learning from it, we share with them, and vice versa as well, if there's complaints that they're dealing with, and there's issues that are picked up that we can learn from what we're doing that. So, you know, one of the outcomes, I suppose, has been a much kind of closer relationship with the Co-ops in terms of information sharing and learning. Thank you, Councillor, sorry, Councillor Hedges. Thank you, Chair. Yes, no, this sounds quite, we had a similar issue. You'll remember Mr. Crawley in Ballam, Abbott House, where we had water ingress, and one of the residents had complained, and I actually went into the flat, and I was really horrified with the damp and the damage that that could do to the residents. So, I mean, have we considered in this situation the health situation of the residents, because, I mean, this has been going on for a long time, so presumably the housing ombudsman picked up on that, because obviously damp has been an issue, and there was something in the press not so long ago about that. So, I wondered whether there's heightened sensitivity around this, hence the outcome of this case. Thank you. Again, I think that probably is a factor. I think, you know, the housing ombudsman generally has been much more kind of proactive in their approach to examining complaints and their findings, and certainly there's always a few that relate to issues of damp and mould. And as a result, we've changed our approach. You know, we inspect all properties where there's reports of mould or, you know, water ingress, regardless of whether it might be condensation-related to mould or not, and obviously make sure that we remove it as quickly as possible, and then look at what measures we can put in place to stop that issue from returning. And you're probably aware we've established our own in-house mould removal team. It becomes a bit more complicated when you've got leaseholders that are affected by, obviously, condensation-related mould or with water ingress. You know, if it's water ingress, then obviously we are as the freeholder, whether that's the co-op or us, are responsible for resolving those issues. What we wouldn't then tend to do is to do work within that leaseholder's property. We might give them some advice, and we might make safe, for example, if there's water ingress that's affecting a light fitting, but we wouldn't kind of go in there and actually do work on their behalf. That would be for them to arrange. Councillor Quitchard. Thank you. It's interesting, actually, because I think either at the last committee or the one before, we had some discussion about All Saints, and I think it's correct to say that we can't take a co-op back. They have to want to come back. Yeah, so if there's been issues with the co-op, how we're working with them. So, I'd also be quite interested about what the ombudsman found for the co-op, and also I'm quite interested in the co-op forum. When we have borough residence forums, we usually have a councillor in attendance. Is this something that we should just think about for the co-ops as well? Also, you know, it just gives an extra person there. And the last question was, you talked about the special tool for working out whether or not a roof needs replacing. Did you say that was being used throughout all our properties, regardless of whether they were being handled through a co-op? That was the bit I wasn't quite clear, or we were using it throughout any property that we manage? So, yes, the first question, we can bring co-ops back in-house if they're failing. There's a relatively recent example of Ackroydon East where, you know, they weren't performing on a number of measures, including kind of repairs and health and safety matters. So, we did take steps to bring them back in-house, and now that estate is managed by the central area team. But we're guided by the modular management agreement in terms of our relationship with them, including what steps we can take to end that relationship, end the co-ops management of those properties and bring them back in-house. So, it does happen, but it's relatively rare. Obviously, what we'd rather do is work with the cooperative to make sure that they're performing and serving the residents as well as we would like. The co-op forum, interestingly enough, Councillor Ireland did attend the forum last night as an observer. So, yeah, I think that's an interesting point, and I can take that away, and we can perhaps invite councillors on a regular basis to that. I'll have a chat with her about it and see whether she found it useful and if she would support that, because, yes, it's useful to have that member oversight and for them to understand what, you know, what happens at those meetings, what's discussed and what the outcomes are. In terms of the sort of app I was talking about, NEC Go Mobile, so, yes, it's applicable to all of ones of council-managed properties, including those managed by the co-operatives. So, it would be used across all of them. I think that's covered all the questions you asked, but if I missed anything, no. No, I think the one I asked was, were there any findings from this investigation for the co-op, which obviously don't affect us, but were there any? It kind of covers both, the investigation. The investigation, so that's why I provided the training for all of the co-ops, because it relates a bit to how they handled the stage one complaint, which was poorly, and they didn't compensate for the delay in responding to that when they should have done. And then also, it was really about, partly about them escalating it with the council if they weren't getting the response that they needed. So, if they were going to the area housing team, for example, to a particular officer and weren't getting a response, it was them being aware that they should escalate that to us and senior managers of the council so we were then aware and we could make sure that, you know, those issues were addressed. So, I think that was the main thing, really. It was the relationship between us and the co-operative, and then also, as I say, how they deal with complaints at stage one. Can I make one other point, too? I also double-checked, I mean, that's happened a while ago, but it's not clear to me whether any councillors were involved, and obviously, sometimes you wouldn't necessarily want people to take that route, but sometimes that is helpful. And I'll just comment, because I, it obviously had started in 2019, which would have been, I'm trying to remember who it was, but yes. Offhand, I must admit, I can't remember which councillors were involved at which stage. I do recall that there were councillors, I think it was towards the kind of latter stages of the issue, when we kind of had worked out that things had gone wrong and were in the process of addressing them. But, yeah, I'd have to sort of go back and look all my records to confirm that. Thank you. So, around the mobile app, and it's good that we're exploring it and we'll implement it, but are we sure that we've got the processes in place and the staff availability or resources or whatever to make sure that the work is still done in a timely fashion once that's there? Because if I use an app with another service to go and log on and they say, great, we'll look into this, but the work still hasn't been done and I'm still facing the same issues for a number of months, I, as the service user, are still going to feel the effects of it. And my other point was going to be around the communication with residents. So, in cases like this, are we making sure that we're keeping residents informed? Because, obviously, if something's going to take six months or a year to repair, to us and to the department, it might sound like that's a reasonable time frame. But for someone who's got water coming through their ceiling, they obviously want to know and get it done as soon as possible. Cheers. Yes, on the first point, I think that's a good question. The building maintenance inspectors within the area teams and the co-op managers, they will regularly be up on roofs anyway and probably inspect most of them throughout the course, a lot of them throughout the course of every year anyway, just through their kind of natural response to reports of roof leaks and, you know, investigations. So, I think the gap has been that there isn't always a record of that inspection and the outcome of that inspection. So, they might be going up on roofs regularly, but we don't know when they got there, what they're finding about the condition of it. So, the purpose of the app really is to make sure that that's always recorded effectively so that we then have a record. And with that record, we can decide what, you know, action is appropriate and monitor to make sure that that action happens. So, yeah, it's kind of less about the inspections perhaps and more about the gathering of data and the recording of those inspections so that we can make sure that they're acted on, you know, the findings from when they're up there. In terms of keeping residents informed, I mean, that was another sort of feature of the training that I gave to the cooperatives. And to be honest, it is, you know, you'll probably know from your casebook, it is sometimes a feature of, you know, the council and the way that we respond to complaints and issues. So, it's mainly just reminding staff to continue to do that and to make sure they keep residents informed and sometimes to manage their expectations. Because, as you say, you know, for example, planning in a major work scheme takes a significant amount of time. So, it's making sure that people are aware of how long that's likely to take and, you know, communicating them very quickly to update them. But, again, that comes a bit down to resources. It's quite resource incentives, obviously, for all of our staff to continue to keep everyone updated in relation to every repair job. So, it's kind of making sure that our officers are updating residents when they need to be updated. And in relation to repairs such as, you know, water and grass, as you say, where someone is, you know, obviously affected by it, you know, on a daily basis, those are the ones that we need to and do prioritise to make sure that there's kind of very regular updates and that people know exactly what's going to happen to try and resolve that. Can I just follow up? Just a quick follow up was around. So, I've noticed with a similar department, the waste management contracts, we've sometimes had a system where they're meant to log, like, when something's missed, when a bin bag's missed. But, actually, the staff on the ground just don't have the time to do that. And so, with this app, are you confident that we have the resourcing to make sure it's used efficiently in whatever way it's meant to be used? Or has there been an extra cost involved in terms of staff recruitment or training or whatever? Well, we bought the app, but we haven't introduced it yet. And we haven't kind of fully determined the process, but that's being worked on at the moment. I think that we know how many roofs we have. So, obviously, we know how many kind of annual inspections would need to be undertaken. So, if there's roofs that haven't been inspected that year, we would be able to clearly see that on our system. You know, if there's not an entry for that, we would know that roof wasn't checked. So, it's quite easy to monitor to make sure we know kind of what may have been missed. And we would be regularly reviewing that to check. And then, obviously, making sure those roofs were inspected. The resource question is a difficult one. As I say, I think most of the roofs, or certainly a very high percentage of roofs, are inspected every year anyway, just for the course of normal day-to-day work in terms of, you know, checking and responding to leaks, et cetera. But until we kind of introduce it and have probably done some sums about the time it takes to kind of inspect a roof, how many we're doing already and how many roofs we've got, I can't answer your question 100% in terms of whether additional resources might be needed to completely fulfil that. Obviously, if that is the case, then that's something we would have to look at to make sure that, you know, those inspections are happening and being acted on. Thank you, Mr Crawley. I'm mindful of the time on this particular subject, but we kind of got to the point maybe of the recommendations. Are we happy to note the internal reports? Councillor Caddy. Sorry, can I just ask something that's very tangential, it's kind of widened this. It was just that there was a reference to the member responsible for complaints on page 11, and obviously we don't have one. And I guess my wider question was, have we considered having one? Should we have one? And is it best practice to have one? Because obviously if it's being referred to by the Ombudsman, the Ombudsman, I guess, is assuming that we might have one. I mean, we can take that away and have a look, but obviously that's, you know, any decision regarding political roles and posts, we need to be done by the relevant political individuals, really. Yeah, and I don't necessarily, you know, I haven't necessarily formed a view over whether it's a good or a bad idea, but it's maybe, if it's referred to, it's maybe something we should consider, whether that's something which would be useful for the Council. Councillor Coochard, or any others? I mean, I'm just, sorry, I was just going to say, I mean, perhaps maybe this is something that obviously there's going to be further discussions around the changes for the Constitution. Perhaps that's something we should just, maybe we ask the committee chair, as her chair role, to just say this has been mentioned and has it been considered. Yeah, that would seem maybe the right way to do it, and I mean, I don't know if you're on general purposes as well, aren't you? Yeah. Oh, yeah, sorry. And I don't know if we've got the general purposes clerk here as well. I think, I think you do. I think you have to. Yeah, I was thinking, I mean, at the moment, I think I'm having a question. I'm happy for it to come here. As you said, it's a wider question that we've got to consider, but I'm happy for it to be discussed here. I mean, what I mean to say is the question, the wider question of should we have a member responsible for complaints is something that we could just ask. Say, it's come up, we just want to know, have we considered it? Is there any benefit, and could that be part of the review? I think would, do you want to ask that, or do you want me to ask it? I don't mind asking. Yeah. Okay, so going back to recommendations, just the members note the internal report and the recommendations at Appendix A and also B. Agreed? Agreed. Good. Okay, agenda number four, audit charter strategy and audit plan. It's paper number 25 to 107, pages 15 to 52. So it's going to be introduced by Ms. Stewart. Thank you, Chair. So this is the annual paper that you get in front of you. It's split out. Obviously, there's three separate appendices. The first one is our charter. The audit team are part of a wider organisation, which is the South West London Audit Partnership. It is hosted here by, under Wandsworth and Richmond councils, and the other three members being Merton, Sutton and Kingston. And this charter is for that whole organisation. There's not really much change from previous years. There's a bit of tidying up, mainly reflecting in changes in role titles. You'll note that, you know, the previous iteration of this, it had me down as the assistant director. I'm now the director. There's no change. I'm doing exactly the same as it is, but we've all called new names. And, obviously, Andrew, covering the head of audit role, is now, obviously, assistant director. So that's really the main sort of changes. It does outline that the strategy that we were following adheres to both, A, initially the public sector internal audit standards, and as we move towards the global internal audit standards from next year, we'll follow those sort of processes. But next, B, is the plan for the better service partnership. Partnership outlines, obviously, your C3 abbreviations, whether it's a joint audit. That's where we are both under the umbrella of, you know, Richmond and Wandsworth working together. And we've also highlighted the two where they're separated out, where the teams operate separately, or the function or the specific asset sits within one borough rather than jointly. And Appendix C gives you, puts things into context. It shows you the whole audit universe that we cover. You'll see this is year three. It always is year three. That line will always just move with it. So you can see the previous two years' audits that we've covered and what we anticipate doing in the further two years. There's no guarantee that next year's will be exactly as it is. But that is our best guess and likelihood of what we would be seeking to cover. So hopefully that you will see that we utilize the 1,600-odd-so days, you know, broadly, effectively, cutting across the various different service areas on a risk-based approach over a five-year period. So that's probably it. That's the intro. Councillor Hedges. Thank you, Mr. Girotti. Just a quick question on – I think somebody may have asked this before, but just wanted to ask you about the global internal audit standards, noting they're coming into effect very shortly, on the 1st of April. And you say that we are substantially compliant. Was there much of an uplift, if anything, and what was the uplift? Thank you. I defer mainly more to Andrew in the corner, but I think we brought a paper last time around on this specifically, and we were showing that we're broadly in line. We've got a, you know, a reasonable period in place to implement those where we think we need to move forward with. Like with all standards, you know, there are musts, coulds, shoulds, and it's getting the right balance right as to where we think it's appropriate because it's a global internal audit standards which will cover a host of organisations, not just local government. And so, therefore, we need to make sure that we take a pragmatic approach to it. But I don't know whether, Andrew, with us, anything else you wanted to add to that? What do I want to add? I do. So, we're substantially compliant because we comply with the public sector internal audit standards and the global internal audit standards build upon those. Self-assessment this year for the public sector internal audit standards was good. that carried on the theme from the external review that we had in 2023, which gave us a good level of compliance against the PSIAS. The main change, I suppose, for the global internal audit standards is there's a domain around governance, and that includes the role of the audit committee and senior leadership team within the council. That's, I guess, that's the area that we'll need to spend most time working through in terms of how we address that. So, some of that is around the committee having more responsibility for approving things rather than noting things. There are some areas that are exempt specifically for local government. So, those would be things like the audit committee approving the budget, which isn't appropriate in local government. So, there's an allowance for that. But in terms of how we do our job, you know, the day job, in terms of how we complete audits, there's very little change. So, you know, come 1st of April, we won't be 100% compliant with the standards. But until we do a self-assessment, we won't be in a position to say. But I am required, as is Paul's head of audit, to come back to the committee with the next assessment, say these are the areas where we're not complying. We have a choice of whether we want to comply with all of the areas, so we can choose not to comply with some areas if they're particularly onerous, or we don't think they're of added value. And the requirement then is for us to notify you by including that in our charter. And so, you know, so it's almost like comply and explain. So, we can choose some specific areas not to do. So, we'll try and implement most of it. It's all really sensible stuff. Yeah, I think that's it. So, we're pretty much there. We'll bring updates during the year to say if there are any significant areas that we need to change, I suppose. But in terms of the day-to-day stuff that we do, it will be the same. Any other questions? Councillor Cuddy. Thank you, Chair. I just wondered if there were any changes proposed proposed to the plans, particularly for housing, given the recent C3 rating, whether these kind of tests and the internal audit focus had shifted at all or should shift. And then, as a second follow-on from that, I guess, are we reviewing our risk structures to understand how we sort of missed that and how we can perhaps mitigate against a negative report in future? Okay, so the rate, obviously, the Ombudsman and, you know, the inspector when they came in gave a particular grade. But, you know, even from that report, I think most of the times there were known issues. It was obviously outstanding factors. And the issues on fire risk assessments had actually been brought to this committee more than once on those. So, I think our coverage actually reinforces that report, obviously reinforces that we had highlighted it. And I think it was either limited or no assurance on one of the areas that have been brought back. So, those areas, I think, are generally have already been addressed as part of the audit plan as such. We do regularly meet with the relevant departments. Similarly, in areas in adult and children's services, when they have an inspectorate, clearly you'll have an oversight. But I don't think there was anything significant new in those sort of reports that hadn't already crossed over that would have been part of our audit universe that we would need to adapt and change. You know, the frequency of those audits are normally based around the assurance levels that we've got. Andrew and the team clearly have done the audit on the Ombudsman's complaint, which is a similar sort of control process type environment, knowledge, awareness, and everything else. Now, that will feature, no doubt, into anything additional that we do as well. I guess as a follow-up, my concern is obviously that we have discussed the fire risk assessments at this committee in the past and seemingly were not able to head this problem off and have it dealt with. So, is there a need to look at our systems again to understand how it was that we were aware of the problem and yet it still, you know, wasn't resolved quickly enough for the inspector? Again, I think that's obviously been addressed. I know the full council had some questions on this particular angle. But if you look at the percentage of the issues that were cleared, the high-priority areas that were cleared, and that has been reported back through to this committee as well. Now, when you have got various different resources available, you prioritise and you get things carried out. Now, reputationally, clearly nobody wants to get, you know, the rating that we did and I'm not trying to undermine the report or downplay the report that's come through. But if you think about what level of recommendations were being made, I know quantity-wise there were loads, but it wasn't put in proportion to how many words to start with and what had been cleared and those key real significant issues that were addressed. And I think also the other outstanding actions had been done at the time when it's been reported back through. So there was a proper programme. It was already notified. It had been reported through to the correct lines through scrutiny committees and through other departmental and director's boards. So I think the process is working. Now, clearly, an inspector wanted us to work more quickly and get things carried out. But from an oversight as to what we cover within those 1,600 days, I think it probably demonstrates that we know it's not perfect, but we are actually covering it right. It is being brought here for yourselves to understand and address. Reporting officers can be brought to this committee. You had Tom Crawley here to come back and understand it. So if you think about what we do as the audit committee, I think it reinforces that our control framework is working effectively. Now, there will always be issues that will crop up. If we had an infinite number of resources, we would never get this. But I think I take comfort in what's coming through and our processes that we've got in place because we were aware, we accepted the timelines because, like I said, some of those issues on fire risk assessment had been come back here and the explanations were done. Can I just jump in a bit here? I think we kind of need to not go into too much detail on that particular issue. I think if there's questions for officers, we can probably post some questions to officers and maybe ask them to come at the next meeting. But if there are any other questions on the audit, yep, councillor Critchard. Thank you. Sorry, I've got a few. Looking at, first of all, appendix B, I was quite, I'll give them all at once. I was quite interested in the Home Acquisition Programme and what the audit was going to cover there. On page 40, completion of 24-25 audits not completed by 31st of March. I think there's a typo. It should be 25, presumably. And I'm actually interested to know how much we've got outstanding. And then there's more detail. I've got some other detail. The other one was, obviously, we're looking at changes to the level of delegated authority. How, if at all, will that affect our audit schedule? I'll do the latter and I'll let Andrew talk about the other ones. If you're talking about delegated authority, if you're... The changes. The changes, yeah. The changes to the constitution. I mean, that's gone through due process. Obviously, audit have been involved in the consultation. I've been involved in that sort of element. The main changes, really, is on the contract award stage. That is not when decisions are made. Decisions are made at scoping stages. And those controls have been strengthened, not weakened, with the process of the information that officers should... sorry, that members should be getting. So I don't think there's a need for us to really address in this programme because we're not weakening controls as a result of those changes. It's changing the focus and shifting away from an award stage to a scoping stage. And that scoping is where spend is determined, not an award. Yeah. And what we want to the contract. Yeah. Yeah. Okay. Councillor Critchard, sorry, can you repeat them? I couldn't keep up with your references to the page numbers. Right. I'm interested in the Home Acquisition Programme audit. I've just wondered what it was. And I also... Oh, sorry. Yes, page 39. Page 40, I think there's a typo when we're going to complete our work for 24, 25. Hopefully, by the end of the year. And I just wondered how much is left now on that. And then I've got some other questions, but that's on the... Yeah, so typo noted. Thank you. That is... That should have been 2025. The Home Acquisition Programme, I'm going to have to get back to you on that. I'll take that outside if I can and come back to you. I haven't got the full details to hand. And the work that's still outstanding from this... from the planned audits for this year? I don't have the percentage, but it's very little. So in comparison with previous years, we've done quite well. So there won't be any work that all work has started and most work will be either field work virtually finished or we'll be at draft report stage and expecting to complete through to final in the first month of next year. So the budget that we've set aside for that is very low. So we're in a good position. And I'll just add to that, obviously, the committee does receive the full stats in the annual report that comes later in the audit cycle. Obviously, you'll see all of the changes that were made based on the plan that was for 24-25 does get reported back to this council later on in the year. I've just got one final question. It's on page 40. It's the fourth audit down or the fourth area, basically. It's information governance and information security support. Does that include cyber security? Not specifically, no. So Kevin actually does some of this for us and one of our auditors sits on the information governance and security forum group. Kevin, did you want to talk about what you did? Because that's probably more relevant, I think. So when you're talking about cyber security and the council's defences, I think it is such a specialist area where we do have market leaders, I think it's BAE, we use to advise the council on that side. So it's a skill set that is beyond probably pay levels that the council could afford to retain itself. So we draw in specialists to advise on that one area. Councilor Quichard. Thanks. And then I had some specific questions on the more detailed bit in three, but I'll just highlight a couple of these. I've noticed an audit's due this year on homelessness, which is clearly the, that's an area where we have a lot of budget pressure. and also on home care and high cost placements, for instance. So there's two or three audits. Is there any chance that the audit might indicate anything that might help us with budget control and budget management? Or is that just not where we're going to go with, where you're likely to be looking? We generally, we would generally include some level of budget management in all of the audit work that we complete. Okay, it's just because for those of us on finance, there's some pretty hefty pressures there and whether we might, I just wondered, I mean, I suppose we'll have to wait and see what you come up with, but it'd be interesting to know if there's anything that can be considered about ways that we could improve or help ourselves with that. I'll just quickly add there, just managing expectations realistically on what's feasible. I mean, certainly when you're looking at high-cost placements, that's market forces and, you know, whether or not you've got Anna or Jeremy, depending on whether it's adult or children, they'll both be adding to the issues of complex need as well. That is beyond the remit of an audit function. And what we can contest what would be making sure is that the control environment on approvals of those high-cost placements is as effective as it can be. We're not the right people to determine whether or not someone is getting, should be placed in, you know, with contractor A or contractor B based on their need. That wouldn't be that, you know, that wouldn't be our audit. Okay, but we get something back about the control environment and that we're managing the management of the placements properly. Yeah. Okay, thank you. Just, does everybody agree the recommendations for that paper? Okay, thank you, agreed. Moving on to agenda number five, this is the fraud update, paper number 25 to 108, pages 53 to 66. Kevin introduced this one, this is mainly a service area. Kevin Holland, I'm the head of the shared fraud partnership and it's across the same five boroughs. So this paper, it's in two parts. First part is just giving the members a flavour of how resources are to be used for next year in terms of combating fraud and the key details I would say are contained within tables one and two. The main change is in terms of the main fraud type areas that we historically deal with, with the reduction in the right to buy grant in November we are expecting that right to buy fraud will all but disappear. That's not the case at the moment obviously that reduction created a huge surge in interest and applications and there is a backlog of applications and referrals to us that we'll have to go through but planning going forward we're looking to replace that area with more intensive work and reviews in around temporary accommodation and in addition to the resources I've got declared here I've also had funding some temporary funding for some additional posts again to specifically target temporary accommodation placements the fraud type there is from my side is probably more the short midterm placements so whilst there's a high cost involvement with that overnight placement that's one that's more of a housing day to day monitoring issue but where people who place accommodation for three months and more have it or need that's where they can potentially start to see that placement as an asset that potentially could be misused and that's where I'll be looking to focus our resources and our attention on going forward so with that in table two in terms of the sort of indicative targets there are new sets of targets in there around temporary accommodation fraud the second part is just to provide you with feedback of what has been completed during the year well the tables are up to the end of January and if we even look at that table three there one of our key targets is in terms of temporary tenancy fraud and properties recovered I'm pleased to see progress in that area we had for a number of years suffering delays and we're still suffering delays with getting court action but it is beginning to move forward but even with that you see there are 13 cases there where the hearing has been held judgment has been given in our favor and we're still waiting for no I think possession orders to be given to us we have to go through evictions and bailiffs in order to secure possession and again we have to wait for court time to require those so it's constant pressure on that but it is slowly improving then they give stats on the number of cases we deal with I think probably just head off a question so my expectation is that of the referrals that we actually accept and take on board to investigate I would expect one in five of those to achieve a sanctionable outcome and the reason this is sometimes well yes allegations fraud don't actually mean that there is fraud but also allegations we need to be able to realistically be able to acquire the evidence to prove it and sometimes we have to unfortunately cut and run on a fraud investigation case for a sanction wise because we know we're not going to be able to get the evidence we need to actually achieve that and then just at the appendix A gives a very sort of brief details of some of the closed cases and yes happy to take questions Councillor Caddy thank you very much for this I'd be interested in on page 59 paragraph 19 it talks about data analytics and data cleansing and I wonder whether we were doing any more work on things like AI and data analytics perhaps in order to help with some of those I mean if you look at the social housing as you've already pointed out the social housing line the benefit that we're getting there is like I mean it's hugely outweighs all of the other categories so that was I guess my first question and then on the second one obviously totally understand and agree with the terrible court delays not allowing people to be you know have their houses to be evicted when they're in there fortunately have we got any kind of system for being able to sort of almost negotiate with them without having to go to court or is there no leeway for that so is there any opportunity to sort of say look you sign away you're going to be evicted we're waiting for a court date you know we'll help you with moving costs or I don't know what it might be if you just leave and sign it across to us now is there any opportunity for that kind of flexibility and pragmatism I'll go to the second part first yes there is but there's just a huge reluctance in terms of the person to do so and part of that may be some of the council own services in the advice they've got to give to people in residence so if they volunteer to leave they're not deemed straight away to be homeless so by volunteering to move on if they haven't got somewhere else to move on to they will lose certain rights and entitlements so certainly pre-COVID we had lots of cases when we got there keys would be handed over or things would have moved on the bits about working with housing is something we are going to be moving forward on I think we do close work with the TA side so we'll have a look at that again in terms of is there anything more we can do with the backlog of cases because again those numbers are increasing and then on the first one about the data analytics well there is work we do main data matching through the national fraud initiative a lot of that comes up with false positive matches but we're trying to pick a big drive on those across all the services because everyone wants to make greater use of the data AI smart decision making well in order to do so you need good quality data and if we've got lots of historical errors in our data then obviously we're going to end up with more false positives which take time away from working on real cases so we've got the two prong attack on that in terms of the data cleansing so that when we get to use the data analytics we'll get a better return Thank you for the update appendix a number 10 talks about forged or falsified documents basically officers that were submitting inflated or false overtime claims and it looks like the claims were exceeding over 39,000 which is obviously quite a lot of money it says here HR to review and enhance systems and controls to prevent similar breaches from occurring but also says here the weakness in the system remains so I just wondered if you had an update on that thank you so yes I was actually speaking with HR on that this morning so it's one of these things where there are a number of changes to be made to the council's HR system so we use something called Midland HR ITREM system and there's a whole scale review that's ongoing in terms of the benefits that the system can actually provide the overtime is one of those so the reason why it remains is that it's the whole system has been reviewed so therefore the issue how the overtime claims or exaggerated over claims were put through will be picked up within that wider review Councillor Lawless Thank you I'm on the officer fraud and instances where it's our own staff and we've got evidence or allegations that money has been taken or similar ways if they've resigned what do we do to follow that up to try and get that money back so where we've got the evidence to recover any sort of funds recommends to the council we will always do so even if officers have resigned they can be invoiced if we have officers who have resigned I might say specifically this authority but I know I'm investigating officers have resigned but we're still carrying forward a case jointly with the police for further action because yes the reservation yes you've gone but you've committed fraud and there are still public funds to be recovered so we will always look to see if there is an realistic opportunity for recovering money or reimbursing council losses we always look to see if we can achieve that in these ones the ones at 10 so it's been identified it's been quantified and that's then handed back to the service now for them to recover I know the invoices some might have been paid I don't have in hand whether it's all been repaid but I know they've all been invoiced and they are in the process of recovering that loss I mean if I can add to some context there's a difference between an employment matter a civil court matter and a criminal matter and there's different degrees of evidence that you need and your ability to go out and to recover clearly as Kevin's indicated I mean those particular cases three individuals or four individuals originally I was the adjudicating officer for those that particular matter but so the ability to get some of the money quite often is the willingness of the individual on the recipient side those who've been dismissed because clearly those people were invoiced and some may be more willing to accept the issue at hand and take appropriate action and refund the money clearly if they don't we will need to then have to weigh up and assess the likelihood of success and expense associated with taking that matter further through the relevant courts because these matters have not gone through courts they've only been done by an employment matter held in house and the ability to recover you'd need to take further action if you were to pursue it

have an internal database so if there's any situation like this the cabinet office that information goes to the cabinet office and they can't be recruited again back into the civil service so I'm just wondering if there's a similar set up for local authorities because there is it is national government or central government definitely obviously with the civil service being one employer it is probably easier to manage than it would be for local authorities who are independent authorities and we need to abide by GDPR and other regulatory issues so our ability in order to do that is limited we don't have the same freedom and flexibility that the civil service would have in that particular manner about sharing information because as I mentioned before this is an employment matter it isn't going through courts when appropriate sanctions therefore being able to be registered beyond our own remit of what the information commissioner will allow us to do any other questions no okay is this one for notes isn't it so does everybody agree to note this paper information agreed thank you so moving on to agenda item number six annual review of RIPA did you want to go through this yeah I mean I do very briefly I mean again this is an annual paper that you see before you it sets out in paragraph four the five areas for where we will actually engage in directed surveillance under the protection of the regulation of investigator powers act and the appendix and table later on in the paper outlines the areas where it is although there are five potential different things like parking permit fraud fly tipping etc we've only actually used it this last year and for several years for the misuse of parking permit fraud you'll see the two different tables the first one is where we've actually utilised the protection that normally means it's going to magistrate's court to get approval to doing so that would mean that the sentence for which we're investigating the crime under would fall potentially of a sanction of six months custodial sentence or more which normally means that will be investigated under the fraud act so they would be no doubt probably using a stolen badge where it's a misuse we still will carry out that we still believe that that is the appropriate thing to do and we still use the same techniques and the same style of investigating it but we do it without that protection shield although we get an inspector that will come around regularly to look and approve and to assess our use of these powers and as you know when we've brought those reports back to these committees it's generally you know exemplary responses so we're seeking permission to continue doing what we have been for the last few years agreed thank you that's the end of the meeting just want to say I think we just want to pick up on the other independent member as I mentioned before that's all going to come through the committee probably at the next committee or if anything happens in between members will be updated thank you thanks thanks thank you thank you thank you