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implemented <strong>and</strong> that substantial<br />

assurance could be provided.<br />

<strong>The</strong>re were three risks identified<br />

that required management action<br />

assessed at amber/green, with<br />

implementation dates of mid to<br />

late 2010.<br />

In<strong>for</strong>mation assurance<br />

72. <strong>The</strong> 2008–09 Statement on<br />

Internal Control highlighted the<br />

fact that due to late confirmation<br />

of data requirements by DIUS,<br />

little progress had been made<br />

against a number of actions to<br />

meet the minimum requirements<br />

on data-h<strong>and</strong>ling outlined in the<br />

Hannigan <strong>Report</strong>.<br />

73. Internal Audit considered that<br />

acceptable progress had been<br />

made towards implementing<br />

the audit recommendations<br />

made from testing carried out in<br />

2008–09. While there were some<br />

systems of control operating,<br />

these were only sufficient to give<br />

a restricted assurance over the<br />

level of control established in<br />

relation to managing in<strong>for</strong>mation<br />

assurance risks. Full compliance<br />

against the Security Policy<br />

Framework by the end of 2009–10<br />

continued to pose a significant<br />

challenge.<br />

74. <strong>The</strong> <strong>Annual</strong> <strong>Report</strong> on In<strong>for</strong>mation<br />

Security produced by the LSC’s<br />

Senior In<strong>for</strong>mation Risk Owner in<br />

April 2010 reported that of the<br />

126 controls, processes, policies<br />

<strong>and</strong> procedures outlined within<br />

the Security Policy Framework<br />

<strong>and</strong> against which the LSC was<br />

required to be compliant, all were<br />

complete except <strong>for</strong> seven, which<br />

were partially complete. Three<br />

were non-compliant while the<br />

rest were fully, mostly or generally<br />

compliant, or were not applicable.<br />

75. In February 2010, the LSC<br />

undertook a self-assessment<br />

against Level 1 of the In<strong>for</strong>mation<br />

Assurance Maturity Model. <strong>The</strong><br />

LSC was between 81 per cent <strong>and</strong><br />

100 per cent compliant across<br />

six headings.<br />

76. In overview, the report concluded<br />

that the LSC could identify its<br />

in<strong>for</strong>mation assets <strong>and</strong> assess the<br />

level of business risk surrounding<br />

them. An In<strong>for</strong>mation Security Risk<br />

Register is now maintained.<br />

Travel <strong>and</strong> expenses<br />

77. In preparation <strong>for</strong> the publication<br />

of details of Council members’ <strong>and</strong><br />

staff expenses, Internal Audit was<br />

asked to provide assurance over<br />

compliance with LSC systems.<br />

78. <strong>The</strong> review gave no indication of<br />

fraud, although many examples<br />

of non-compliance <strong>and</strong> ignorance<br />

of the policies were identified,<br />

along with some errors. A<br />

‘restricted assurance’ opinion was<br />

appropriate, due to the extent<br />

of non-compliance with systems<br />

(mainly inconsistent use of<br />

corporate procurement cards) <strong>and</strong><br />

the failure of the systems to meet<br />

business need. A number of the<br />

issues identified were addressed in<br />

2009–10 <strong>and</strong> the expenses policy<br />

is being reconsidered, as much<br />

of the non-compliance was due<br />

to policy not reflecting current<br />

business conditions.<br />

Business continuity<br />

planning<br />

79. Follow-up work on the<br />

recommendations set out in the<br />

improvement plan <strong>for</strong> the ‘BCP<br />

Management Letter’ issued in<br />

June 2008 was undertaken by<br />

Internal Audit. Although there had<br />

been progress in implementing<br />

recommendations, the LSC still<br />

lacked established arrangements<br />

to co-ordinate business continuity<br />

planning activities across the<br />

organisation. <strong>The</strong> LSC had revised<br />

its Business Continuity Policy in<br />

August 2008 but had not yet<br />

developed its approach, processes<br />

<strong>and</strong> arrangements <strong>for</strong> business<br />

continuity plans in line with<br />

BS 25999.<br />

80. <strong>The</strong>re was a good response to<br />

dealing with the threat of a swine<br />

flu p<strong>and</strong>emic, where plans were<br />

revised <strong>and</strong> advice was given to<br />

regions about the actions they<br />

should take.<br />

81. Going <strong>for</strong>ward, it was<br />

recommended <strong>and</strong> agreed that<br />

arrangements <strong>for</strong> business<br />

continuity plans in line with BS<br />

25999 will be developed; that<br />

the Business Continuity Policy<br />

will be revised in the light of the<br />

new organisations; that roles <strong>and</strong><br />

responsibilities <strong>for</strong> both the <strong>Skills</strong><br />

Funding Agency <strong>and</strong> the YPLA will<br />

be established to ensure that there<br />

are effective arrangements <strong>for</strong><br />

business continuity management;<br />

<strong>and</strong> that arrangements will be put<br />

in place <strong>for</strong> <strong>for</strong>mal <strong>and</strong> regular<br />

reporting to senior management<br />

on the overall management of<br />

business continuity planning, its<br />

delivery <strong>and</strong> its implementation in<br />

both the <strong>Skills</strong> Funding Agency <strong>and</strong><br />

the YPLA.<br />

Leadership <strong>and</strong> Governance<br />

LSC <strong>Annual</strong> <strong>Report</strong> <strong>and</strong> <strong>Accounts</strong> 2009–10 41

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