For Commission use only
Commission for Local Administration in England
Operational Risk Register
August 2008
This document should be read in conjunction with the Risk Management Strategy.
The attached grids set out the business risks related to our key business processes as listed below. They describe the nature of the risk, our arrangements for controlling the risk and the response when failures occur. The residual risk is assessed as a product of likelihood of a failure/incident occurring and the severity (to the organisation). If the score is 6 or more (ie likelihood x severity) then the residual risk is high (red). If the score is 3 but less than 6 then the residual risk is medium (yellow). Anything less than 3 is low (green). In areas where the residual risk is judged unacceptable further action is being undertaken and progress is reported to the Audit Committee.
Key Business Processes
1Business processes: / 2Management of resources: / 3External communications:LGOAT
1.1Access and Advice
1.2Screening
1.3Investigating
London
1.2Screening
1.3Investigating
1.4Determining investigated cases (maladministration, injustice, remedy)
York
1.2Screening
1.3Investigating
1.4Determining investigated cases (maladministration, injustice, remedy)
Coventry
1.2Screening
1.3Investigating
1.4Determining investigated cases (maladministration, injustice, remedy)
Corporate Services
1.5 Business Planning
1.6Risk Management / Corporate Services
2.1Finance
2.2Property
2.3Staffing
2.4Information / Corporate Services
3.1Increasing public awareness and understanding
3.2Giving advice on good administrative practice
Key to job titles
AO – Assistant OmbudsmanCh - Chairman
CSM – Customer Services Manager
CSS – Customer Services Supervisor
DCE – Deputy Chief Executive
DO – Deputy Ombudsman
DO(C) – Deputy Ombudsman (Coventry)
FC – Financial Controller
FM – Facilities Manager / HoC – Head of Communications
HoFE – Head of Finance & Estates
HoHR – Head of Human Resources
HoIT – Head of Information Technology
Inv – Investigator
ITT(C) – Information Technology Technician
(Coventry)
LGOAT – LGO Advice Team
MT – Management Team / O – Ombudsman
PA – Personal Assistant
PFM – Principal Facilities Manager
Prog Board – LGOATProgramme Board
SA –Systems Administrator
SI – Senior Investigator
SS – Support staff
STL – Support Team Leader
YMT – York Management Team
A summary matrix of the risk responsibilities of these jobs is set out at the end of the register.
Key to analysis of risk
Risk category / Severity (to the organisation) / Frequency / LikelihoodF – Financial / 1. Impact/effect is insignificant. / A - Annual / 1. Does not occur/occurs rarely
I – Information / 2. Medium impact/small effect (can be cumulative) / D – Daily / 2. Occurs sometimes
J – Injury / 3. Major impact/jeopardises operations / M – Monthly / 3. Occurs frequently
R – Reputation / Q – Quarterly
S – Service Disruption
U – Under-achievement/ineffectiveness
L i k e l i h o o d / 3 (Likely) / M / H / H
2 (Unlikely) / L / M / H
1 (Highly Unlikely) / L / L / M
1 (Minor) / 2 (Medium) / 3 (Major)
Severity
Summary of the calculation of risk
1
1. Business Process (LGOAT)Lead Officer: Neville Jones
Business Risk / Risk Category / Consequence / Severity / Strategic risk / Control Arrangement / Monitoring / Likelihood of Incident / Response to Incident / Residual Risk / Acceptable?Responsibility / Frequency / July 08 / Sept 08
Previous / Current
1.1 LGO Advice Team
Premises
1.1.1 Impairment of premises due to external factors / S / Delay or interruption of service / 2.1 2.2 2.4 / Monitoring other occupants and sub-tenants. Monitor behaviour. / DO (C) / D / Enforce contractual or tenant’s obligations
1.1.2 Absence of a business continuity plan / S / Risk to the integrity of the service and loss of service to customer. / All / The preparation and agreement of a separate plan for the AA unit in place prior to operations commencement. / DO (C)
CSM / Y / Approve draft and undertake test by autumn 2008.
Staffing
1.1.3 Excess demand for the service (insufficient staff) / F/R / Advice team swamped and Commission not able to deliver to the public on the expectations of new service. / All / Monitor the flow of calls and have in place back-up arrangement that will provide support from core service into advice team on temporary basis. / Prog. Board / D / Examine experience of other new centres and learning points of fluctuating demand.
Redeployment of resources. Increase staff complement.
1.1.4 Failure to retain staff (whatever reason) / F/R / The consequence is inability to provide advertised service. Potential overload for remaining staff. Potential disruption between AA and core. / All / Actively monitor performance, attitudes and commitment. Engender strong team spirit and bonding. Invest in individuals and gain loyalty. / DO (C) / M / Examine recruitment processes and their effectiveness. Gain feedback on exit interviews.
1.1.5 Failure in staff competence / F/R / Poor service to customers. Loss of confidence in AA service. Insufficient return on investment. / All / Rigorous training, induction and appraisal throughout the process. Extend mentoring role. Consider supplementary training. / DO (C) / M / Assess cause of weaknesses:
(a) candidate
(b) training methodology
(c) excessive expectation
Service Provision
1.1.6 Failure to develop and adapt service following implementation. / F/U / Service fails to deliver improvement affecting service reputation and a fall in confidence. / 2.1 2.2 2.4 / Post implementation review and tracking improvements using sampling and management review High level of governance. / DO (C) / Q/A / Identification of a problem and early resolution. Analysis of PI’s and drawing conclusions.
1.1.7 Loss of Commission staff support for the initiative. / R / Loss of goodwill and adverse impact on front and back ends of operation. / 2.1 2.2 2.4 / Maintain regular updates. Tackle areas of concern at outset.
Ensure embedded buy-in across Commission staff. Concerted effort to engage and encourage staff commitment. / Prog. Board / W / Obtain urgent feedback on reason for any loss and address areas of concern.
1.1.8 Poor linkage between front and rear operations. / S / Inefficient service delivery.
Loss of case identity.
Confusion for service users. / 2.1 2.2 2.4 / Weekly up date meetings. Staff feedback. / LGOAT / M / Devote additional resources to ensure joined-up working is established.
Finance
1.1.9 Failure to provide sufficient resources-internal allocation. / F/S / Undermines service provision / 2.1 2.2 2.4 / Develop detailed costed budgets for various outcomes / CSM / M / Release underspend from 2007/08.
IT
1.1.10 Failure in IT support / I/R/S / Undermines system / 2.1 2.2 2.4 / Contractor supports the post implementation period with Commission staff. / HoIT / D / If contractor lost an alternative supplier will need to be found. Loss of Commission staff impacts on day to day operations would be more difficult to fill.
1.1.11 Failure of COIN system / I/R/S / Unable to process calls to LGOAT electronically. Revert to manual recording of data. / 2.1
2.2
2.4 / Mirror server (LGO8) in London can take over until fault rectified. Standard daily backup arrangements. / HoIT
SAs / Contin-uous / Run with COIN until a substitute can be found from a different supplier (6 – 12 months).
1.1.12 Failure of HiPath Call Centre system / I/R/S / No automatic call distribution to LGOAT. Revert to manual pickup of calls. / 2.1
2.2
2.4 / Support agreement with Mts. Calls answered with emergency message. / HoIT
ITT(C) / Contin-uous / Rely on Mts to repair or replace HiPath Call Centre.
1.1.13 Failure of Coventry telephone switch / I/R/S / No calls reach LGOAT. / 2.1
2.2
2.4 / Support agreement with Mts. Calls answered with emergency message. / HoIT
ITT(C) / Contin-uous / Rely on Mts to repair or replace switch.
1.1.14 Failure of inter-office network (WAN) / I/R/S / Unable to process calls to LGOAT electronically. Revert to manual recording of data. / 2.1
2.2
2.4 / Support agreement with Mts. / HoIT / Contin-uous / Report faults to Mts/Global Crossing.
1.1.15 Continual errors on COIN system / I/R/S / Interruptions to users. Loss of confidence in system. Failure to meet system expectations. / 2.1
2.2
2.4 / Work with CAS to overcome errors. / HoIT / D / Work with CAS to resolve. TR to meet with directors if situation getting out of hand.
Commentary
1.1.2:CoventryOperational Business Continuity Plan has been mocked up for LGOAT plan but as yet information has not been populated and the plan is still work in progress.
Previous risk 1.1.3 deleted and subsequent risks renumbered.
Signed: ...... Date: ......
1
1. Business Process (LGOAT)Lead Officer: Stephen Purser
Business Risk / Risk Category / Consequence / Severity / Strategic risk / Control Arrangement / Monitoring / Likelihood of Incident / Response to Incident / Residual Risk / Acceptable?Responsibility / Frequency / Aug 08
Previous / Current
1.2 Screening
1.2.1 Failure to identify a valid complaint / R/U / Complainant’s injustice prolonged/exacerbated. / 1.1 / Complaint about failure. / CSM/CSS / - / Make up complaint.
1.2.2 Correspondence wrongly identified as a complaint to LGO / R/U / Time wasted for complainant and us on processing / 1.1 / Initial scrutiny
Early personal contact with the complainant (M).
Casework review.
Monthly supervision. / CSM/CSS / -
-
-
- / Pass to correct authority/de-register
1.2.3 Delay by staff in screening / R/U / Complainant’s injustice prolonged/exacerbated.
Complainant’s opportunity to seek alternative remedy is prejudiced. / 1.1 / Monitoring of performance data.
Casework review.
Complaint about failure. / CSM/CSS / ?
-
- / Action with individual caseworker/PA.
May need to reassign work.
Apology/compensation if severe
1.2.4 Failure to identify as an urgent complaint / R/U / Complainant’s injustice exacerbated/remedy compromised / 1.1 / Initial scrutiny
Complaint about failure / CSM/CSS / -
- / Prioritise action
1.2. 5 Incorrect decision - complaint screened out / R/U / Complainant’s injustice prolonged/exacerbated.
Complainant’s opportunity to seek alternative remedy is prejudiced. / 1.1 / 5% monitoring.
2 cases/month/investigator monitoring.
Complaint about failure. / CSM/CSS / M
M
- / Review jurisdictional guidance.
Action with individual caseworker.
1.2.6 Incorrect decision - complaint screened in / R/U / Time wasted investigating complaint (LGO, council, complainant).
Complainant’s opportunity to seek alternative remedy is prejudiced / 1.1 / Casework review.
Monthly supervision. / CSM/CSS / -
M / As above.
Signed: ...... Date: ......
1
1. Business Process (LGOAT)Lead Officer: Stephen Purser
Business Risk / Risk Category / Consequence / Severity / Strategic risk / Control Arrangement / Monitoring / Likelihood of Incident / Response to Incident / Residual Risk / Acceptable?Responsibility / Frequency / Aug 08
Previous / Current
1.3 Investigating
1.3.1 Misunderstanding of complaint / R/U / Time wasted investigating (us, council, complainant) / 1.1 / Early personal contact with the complainant (M).
Complaint about failure.
Casework review.
Monthly supervision / CSM/CSS / -
-
-
M / Amend records
Renew actions / -
1.3.2 Complainant’s expectations poorly managed / R / Complainant’s expectations falsely raised Complainant’s injustice prolonged/exacerbated.
Complainant aggrieved.
Complainant notifies press/MP.
Disincentive to new complaints. / 1.1 / Explanatory publicity
Indicating response times in acknowledgement letters
Early personal contact with the complainant (M).
Agreeing statement of complaint and confirming actions in writing
28 day KITs (M)
Send provisional views (M)
Complaint about failure / CSM/CSS / -
-
-
-
-
-
- / Clarify/improve publicity.
Training.
Action with individual caseworker.
Creation of A&A from 1April 2008. / -
1.3.7 Poor quality communications (letter, phone, etc) / R/U / Time wasting.
Could result in wrong decision.
Complainant/council loses confidence. / 1.1 / 5% monitoring.
2 cases/month/investigator monitoring.
Complaints about failure. / CSM/CSS / M
M
- / Action with individual caseworker.
Training. / -
1.3.8 Misconduct by investigator concerning customers / R / Customer aggrieved
(council/complainant). / 1.1 / Complaints about failure
Observation by colleagues. / CSM/CSS / -
- / As above. / -
Commentary
The risk numbering is consistent across the offices but not all risks occur in all offices.
Signed: ...... Date: ......
1
1. Business Process (London)Lead Officer: Richard Shaw
Business Risk / Risk Category / Consequence / Severity / Strategic risk / Control Arrangement / Monitoring / Likelihood of Incident / Response to Incident / Residual Risk / Acceptable?Responsibility / Frequency / Mar 08 / Aug 08
Previous / Current
1.2 Screening
1.2.1 Failure to identify a valid complaint / R/U / Complainant’s injustice prolonged/exacerbated. / 1.1 / Complaint about failure / AO / - / Make up complaint
1.2. 5 Incorrect decision - complaint screened out / R/U / Complainant’s injustice prolonged/exacerbated.
Complainant’s opportunity to seek alternative remedy is prejudiced. / 1.1 / 5% monitoring.
2 cases/month/investigator monitoring.
Complaint about failure / O
AO
AO / M
M
- / Review jurisdictional guidance.
Action with individual caseworker.
1.2.6 Incorrect decision - complaint screened in / R/U / Time wasted investigating complaint (LGO, council, complainant).
Complainant’s opportunity to seek alternative remedy is prejudiced / 1.1 / Casework review.
Monthly supervision / INV
AO / -
M / As above.
Commentary
The risk numbering is consistent across the offices but not all risks occur in all offices.
Signed: ...... Date: ......
1
1. Business Process (London)Lead Officer: Richard Shaw
Business Risk / Risk Category / Consequence / Severity / Strategic risk / Control Arrangement / Monitoring / Likelihood of Incident / Response to Incident / Residual Risk / Acceptable?Responsibility / Frequency / Apr 08 / Aug 08
Previous / Current
1.3 Investigating
1.3.1 Misunderstanding of complaint / R/U / Time wasted investigating (us, council, complainant) / 1.1 / Early personal contact with the complainant (M).
Complaint about failure.
Casework review.
Monthly supervision / INV
AO
INV
AO / -
-
-
M / Amend records
Renew actions
1.3.2 Complainant’s expectations poorly managed / R / Complainant’s expectations falsely raised Complainant’s injustice prolonged/exacerbated.
Complainant aggrieved.
Complainant notifies press/MP.
Disincentive to new complaints. / 1.1 / Explanatory publicity
Indicating response times in acknowledgement letters
Early personal contact with the complainant (M).
Agreeing statement of complaint and confirming actions in writing
28 day KITs (M)
Send provisional views (M)
Complaint about failure / HoC
MT
INV
INV
INV
INV
AO/
DO / -
-
-
-
-
-
- / Clarify/improve publicity
Training
Action with individual caseworker
1.3.3 Delayed or poor response from complainant / U / Council uncertainty prolonged.
Time wasted chasing. / 1.1 / Bring forward system.
Casework management
Monthly supervision / INV
INV
AO / D
-
M / Review timescales.
Exercise discretion to terminate.
1.3.4 Delayed or poor response from council / R/U / Complainant’s injustice prolonged/exacerbated.
Time wasted chasing.
Complainant loses confidence. / 1.1 / Bring forward system.
Casework management
Monthly supervision
Monitoring data. / INV
INV
AO
O / D
-
M
- / Pursue with council.
Minimise our own delays
Refer to in annual report.
Training/Seminars for link officers.
1.3.5 Delay in allocation / R/U / Complainant’s injustice prolonged/exacerbated.
Complainant aggrieved.
Complainant notifies press/MP.
Disincentive to new complaints. / 1.1 / Monitoring of performance data.
Complaints about failure / AO/
MT
AO / W
M
- / Action depends on overall workload. May stockpile, pass to other team/office, amend acknowledgement letters, warn Advice Line, set up task force, etc
Action with individual AO.
1.3.6 Delay in investigation / R/U / Complainant’s injustice prolonged/exacerbated.
Complainant aggrieved.
Complainant notifies press/MP.
Disincentive to new complaints. / 1.1 / BF system
Casework management
28 day KITs (M)
Monitoring of performance data
Monthly supervision
Complaints about failure / INV
INV
INV
AO
MT
AO
AO / D
-
M
-
Q
M
- / Action depends on workload. May coach, pass to other team/office,
Action with individual investigator
1.3.7 Poor quality communications (letter, phone, etc) / R/U / Time wasting.
Could result in wrong decision.
Complainant/council loses confidence. / 1.1 / 5% monitoring.
2 cases/month/investigator monitoring.
Complaints about failure. / O
AO
AO / M
M
- / Action with individual caseworker.
Training.
1.3.8 Misconduct by investigator concerning customers / R / Customer aggrieved
(council/complainant). / 1.1 / Complaints about failure
Observation by colleagues. / AO
- / -
- / As above.
1.3.9 Too much attention to the case/ ‘over investigating’ / R/U / Less time available to progress other cases.
Time of others wasted.
Complainant’s expectations falsely raised and any injustice prolonged.
Complainant aggrieved.
Complainant notifies press/MP.
Disincentive to new complaints. / 1.1 / Casework management
Monthly supervision
5% monitoring.
2 cases/month/investigator monitoring.
Monitoring of performance data / INV
AO
O
AO
MT / -
M
M
M
Q / As above.
1.3.10 Too little attention to the case/ ‘under investigated’ before conclusion reached / R/U / Incorrect decision possible.
Complainant/council dissatisfied with quality. / 1.1 / Casework management
Monthly supervision
5% monitoring.
2 cases/month/investigator monitoring.
Send provisional views (M)
Monitoring of performance data
Complaints about failure
Ombudsman’s seminars / INV
AO
AO
O
AO
INV
MT
AO/
DO / -
M
M
M
M
-
Q
-
Q / Action with individual caseworker.
Training.
Re-launch investigation
Signed: ...... Date: ......
1
1. Business Process (London)Lead Officer: Richard Shaw
Business Risk / Risk Category / Consequence / Severity / Strategic risk / Control Arrangement / Monitoring / Likelihood of Incident / Response to Incident / Residual Risk / Acceptable?Responsibility / Frequency / Apr 08 / Aug 08
Previous / Current
1.4 Determining investigated cases (maladministration, injustice, remedy)
1.4.1 Right decision - complainant dissatisfied / R/U / Complaint to MP, letter to the press.
Comeback lodged.
JR lodged. / 1.1 1.2 / Consider jurisdiction throughout complaint (M)
Send provisional views (M)
Commission discussion/decisions
Monthly supervision
5% monitoring.
2 cases/month/investigator monitoring.
Complaints about failures / INV
INV
O
AO
O
AO
AO / D
-
-
M
M
M
- / Review and further letter to complainant.
Settle or fight JR.
1.4.2 Right decision - council dissatisfied / R/U / JR lodged.
May notify associations and press. / 1.1 1.2 / Consider jurisdiction throughout complaint (M)
Inform Council of complaint and outcome (M)
Send provisional views (M)
Commission discussion/decisions
Monthly supervision
5% monitoring.
2 cases/month/investigator monitoring.
Complaints about failures / INV
INV
INV
O
AO
O
AO
AO / -
- / Review and further letter to council.
Settle or fight JR.
1.4.3 Wrong (or inconsistent) decision (complaint not upheld) / R/U / Standing damaged.
Injustice continues/ exacerbated.
Council unfairly cleared (may have consequences for others).
JR.
Complainant notifies press/national bodies/MP.
Bad decision precedent / 1.1 1.2 / Consider jurisdiction throughout complaint (M)
Send provisional views (M)
Commission discussion/decisions
Monthly supervision
Casework management
5% monitoring.
2 cases/month/investigator monitoring.
Complaints about failures
Limits to delegation
Advice
Ombudsman’s seminars
Comtrac (LA info, ad-hoc queries, etc) / INV
INV
O
AO
INV
O
AO
AO/
DO
O
AO/DO
O
O
INV / D
-
-
M
-
M
M
-
-
Q
- / Commission agree a common view.
Pattern of poor decisions may lead to action on procedure or individual staff.
Settle or loose JR - costs.
Re-launch and substitute correct decision (if not functus).
Apology/ Compensation if severe.
Revise/reissue guidance
1.4.4 Wrong (or inconsistent) decision (complaint upheld) / R/U / Standing damaged
Council unfairly penalised.
Inappropriate remedy.
JR.
May notify associations, MPs and press.
Bad decision precedent / 1.1 1.2 / Consider jurisdiction throughout complaint (M)
Inform Council of complaint and outcome (M)
Send provisional views (M)
Commission discussion/decisions
Monthly supervision
Casework management
5% monitoring.
2 cases/month/investigator monitoring.
Complaints about failures
Limits to delegation
Advice
Ombudsman’s seminars
Comtrac (LA info, ad-hoc queries, etc) / INV
INV
INV
O
AO
INV
O
AO
AO
O
AO/DO
O
O
INV / D
-
-
-
M
D
M
M
-
-
-
-
- / As above.
1.4.5 Wrong (or inconsistent) remedy / R/U / Standing damaged
Council wrongly penalised.
Complainant wrongly redressed. / 1.1 1.2 / Monthly supervision
Commission discussion/decisions
Ombudsman’s seminars
5% monitoring.
2 cases/month/investigator monitoring
Comebacks.
Ombudsman’s seminars
Comtrac (LA info, ad-hoc queries, etc) / AO
O
O
O
AO
AO
O
INV / M
-
M
Q
M
-
-
- / If not functus, issue new recommendation.
Training
1.4.6 Failing to act appropriately on post decision correspondence / R/U / Comeback not identified/addressed leading to aggrieved complainant and possible bad publicity
Deadlines for FOI/DPA requests missed leading to legal action.
JRs not identified/ addressed / 1.1 1.2 / Comebacks, FOI/DPA requests and JRs to be brought to AO’s attention.
Complaints about failures. / INV/
AO
AO / -
- / Deal with comeback, apologise, compensation in severe cases.
Court action
*(M ) in this column means the control arrangement is a mandatory requirement of the Investigation Handbook.
Definitions:
Casework review is the normal day to day consideration of a case by the investigator
Complaint about failure is any expression of disagreement with action or inaction and includes internal complaints and comebacks
Signed: ...... Date: ......
1
1. Business processes (York)Lead Officer: Karen Hill
Business Risk / Risk Category / Consequence / Severity / Strategic risk / Control Arrangement / Monitoring / Likelihood of Incident / Response to Incident / Residual Risk / Acceptable?Responsibility / Frequency / Mar08 / Aug 08
Previous / Current
1.2 Screening
1.2.1 Failure to identify a valid complaint / R/U / Complainant’s injustice prolonged/exacerbated. / 1.1 / Complaint about failure. / AO/SI/
PA / - / Make up complaint
1.2. 5 Incorrect decision - complaint screened out / R/U / Complainant’s injustice prolonged/exacerbated.
Complainant’s opportunity to seek alternative remedy is prejudiced. / 1.1 / Targeted monitoring.
1-2 cases/month/investigator monitoring.
Complaint about failure / O
AO
AO/DO/O / Bi-monthly
M
- / Review jurisdictional guidance.
Action with individual caseworker.
1.2.6 Incorrect decision - complaint screened in / R/U / Time wasted investigating complaint (LGO, council, complainant).
Complainant’s opportunity to seek alternative remedy is prejudiced / 1.1 / Casework review.
Regular supervision.
Targeted monitoring.
1-2 cases/month/ investigator monitoring. / INV
AO
O
AO / -
Varies (1)
Bi-monthly
M / As above.
Commentary
Some commentary redacted
The risk numbering is consistent across the offices but not all risks occur in all offices.
Signed: ...... Date: ......