Document
Corporate risk register
001 The Benefit Subsidy claim may be qualified and/or financial losses.
Horsham District Council has a case load with a particularly high number of working people with many changes of circumstances.
Risk Cause
The External Auditors audit the Horsham District Council Benefits Grant Subsidy return to the Department for Work and Pensions (DWP) on an annual basis to identify errors.
Risk Effects
Financial. Service Delivery. Compliance with regulation. Reputation.
Controls
- Continuously monitor the level of quality control checking.
- An earmarked reserve for subsidy provision is now in place that would cover the loss of subsidy in the event that the upper threshold in the subsidy claim is breached.
Quarterly update
Pressure has been building in the service since the outbreak of Covid-19. In 2022/23, a pre-audit 0.58% Local Authority error rate breached the upper threshold of 0.54%, resulting in a loss of £122,925. Post-audit, the final subsidy loss was £191,235 after extrapolations. As part of a commitment to continued service improvement, including staff development, 2024/25 has seen an increased amount of quality assurance measures in year. These increased measures have also been a result of the issues previously identified, as well as areas for improvement identified in some of the quality review deep dives. A DWP support review was also undertaken in 2024 to help improve processes, procedures and approaches. The outturn LA error for 2023/24 was for a pre-audit figure of 0.24%, below the lower threshold of 0.48%, leaving some headroom. However, the audit has identified some errors which, after extrapolation, has pushed the error rate over the lower threshold. The audit is still in progress and therefore the risk is extremely high that any further large or extrapolated error could result in going over the upper threshold and a higher loss of subsidy. At month 6, the forecast error rate for 2024/25 is 0.59% based on current caseload expenditure following the identification of two large errors: a £15k error from 2016 (Census legacy) and one £11k error from 2021 (during Covid). As customers move to Universal Credit during 2024/25, this will reduce the expenditure population, further increasing the year-end error rate as high as 0.69%. The pre-audit position year-end error rate position will therefore be above the upper threshold limit, resulting in subsidy loss during 2024/25.
Target Risk
High (16) (Threat; High; Major)
Current Risks
High (20) (Threat; High; Critical)
Responsible Officer
Director of Resources
Action Officer
Director of Resources
002 Recruitment and Retention.
Inability to recruit and retain officers in key service areas, especially Legal, Building Control, Planning and Technology Services. Failure to have resilience in the staff structure, and so lacking the right number of staff with the right skills to deliver services, along with unrealistic expectations of services.
Risk Cause
Linked to national shortage of labour in some sectors as well as experienced professionals leaving the public sector for retirement or better pay in the private sector. Capacity problems increase turnover and absence and adversely affect wellbeing and productivity levels.
Risk Effects
Adverse effect on morale. Financial. Failure to achieve agreed business objectives. Compliance with regulations. Complaints / claims / litigation. Stress and absenteeism.
Controls
- Workforce planning, training and development, growing your own, leadership and management programmes, apprenticeships, coaching, supporting skills and qualifications are all activities undertaken.
- Efficient and effective recruitment processes tailored to job roles, enhancing the employer brand, recruitment benefits, such as relocation package, flexible and hybrid working, market supplements, recruitment & retention allowances and review of pay point spinal column are potential measures.
- Ongoing workforce planning and review of recruitment and retention effectiveness. Bi-annual staff survey to be undertaken and action plans progressed.
- Review options for alternative solutions, e.g. investigating Horsham weighting allowance, increasing efficiencies in process and transformation through automation, or job redesign etc.
Quarterly update
Recruitment and retention in key services such as Building Control, Planning and Technology Services has resulted in locums and vacancies, resulting in delays in delivering workloads. Senior posts are currently all filled. Legally trained support staff are in place and lawyer posts have been filled recently, reducing the need for legal locums. Building Control has three trainee posts filled and there currently is no longer a need to take on a further trainee in September 2024, as some activity has slowed down. All surveyors are supported in achieving the Building Inspector registrations. However, four employees have resigned, and have left or are working their notice, for reasons of career progression and the associated greater pay. We are considering the options for future service provisions. Other services have been able to recruit, but also retained their staff well, against a background of the recruitment market slowing down and fewer jobs being available for people to move to. Turnover of employees in the year 2023/24 has been lower than in previous years and was just under ten percent.
Target Risk
Medium (12) (Threat; Medium; Major)
Current Risks
Medium (12) (Threat; Medium; Major)
Responsible Officer
Director of Resources
Action Officer
Head of HR & OD
003 Rapidly rising costs and lower income making balancing the budget more difficult.
Lower levels of planning fees & property income. Increased costs from inflation and from higher levels of homelessness. Loss of income due to the moving housing benefit claims to Universal Credit. The impact on the financial markets and the pound could bring forward the next recession slowing down the housing market.
Risk Cause
Uncertainty in the UK and World economy. Higher levels of salary and non-salary costs from inflation. Impact on the financial markets and the pound in the wake of war in other countries and the energy crisis. Likelihood of a deeper depression and slowdown in the property and financial markets. Loss of income because of changes in spending habits due to cost of living and impacts from government due to changes in benefits processing.
Risk Effects
Financial. Service Delivery. Compliance with Regulations.
Controls
- Monitor the external environment.
- Monitor internal indicators, particularly costs from inflation, income generation and respond appropriately to adverse trends.
Quarterly update
At month 6 the Council is forecasting an operational deficit of £0.04m. Parking income in the town centre car parks is lower than budgeted by £0.24m, and in Strategic planning difficulties in recruiting to the vacant land drainage post and additional spend on local plan consultancy create a total £0.24m forecast overspend. The cost of HVO fuel has reduced, offsetting some of this loss of income. There are also significant pressures on homelessness and benefits cases, partly offset by an increase in government funding for homelessness. Spending our reserves for social and wellbeing gain, without achieving a revenue return will increase the pressure over the medium term. Budget shortfalls of around £2m to £2.5m a year are forecast once we introduce p.a. a 1,2,3 food waste collection and the Capitol Theatre refurbishment. The migration of housing benefits to Universal Credit has started with 367 cases moved to date. A further 706 will be migrated by the end of 2024/25.
Target Risk
High (15) (Threat; Medium; Critical)
Current Risks
High (15) (Threat; Medium; Critical)
Responsible Officer
Director of Resources
Action Officer
Head of Finance and Performance
004 Funding from Government is less than assumed in the Medium Term Financial Strategy (MTFS) from 2026.
Funding from Government is less than assumed in the Medium Term Financial Strategy (MTFS) from 2026.
Risk Cause
The Council is reliant on Central Controlled Government funding (e.g. Business Rates).
Risk Effects
Reductions in funding. Adverse effect on morale. Financial. Failure to achieve agreed objectives.
Controls
- Continue to keep a watching brief.
- Revisit the MTFS and if necessary 2024/25 budget in year.
- Evaluate and discuss with Members possible future actions to mitigate loss of income. e.g. Corporate Restructure, cuts to quality and / or non-statutory services, investment and infrastructure projects that generate income.
Quarterly update
The Chancellor has announced the Autumn budget will take place on 30 October 2024. This will announce the Government’s taxation and spending plans. Departmental expenditure allocation will be announced on the same date, with Local Government Funding for 2025/26 included in this funding envelope. For 2024/25 The Council has thoroughly reviewed income and expenditure and set a balanced budget, albeit using £0.6m of the Funding Guarantee grant from Government. However, a £2.5m budget deficit is forecast at the end of the MTFS, if we implement food waste before the statutory deadline March 2026 and / or spend our reserves without achieving a revenue return such as on the Capitol Theatre refurbishment. The gap will only get larger if the funding cuts are sharper than anticipated.
Target Risk
High (16) (Threat; High; Major)
Current Risks
High (16) (Threat; High; Major)
Responsible Officer
Director of Resources
Action Officer
Head of Finance and Performance
005 Funding from Business Rates is less than assumed in the Medium Term Financial Strategy (MTFS) from 2026.
The Council is reliant on Central Controlled Government funding on Business Rates and Government raising the baseline. Decrease in Rateable Value due to appeals and businesses failing. This may cause the Council to fall below the business rates baseline, resulting in loss of funding.
Risk Cause
Cause: The Council is reliant on Central Controlled Government funding Business Rates). Government re-baselines less favourably, or businesses start to fail and the RV falls below the baseline.
Risk Effects
Reductions in funding. Financial. Adverse effect on morale. Failure to achieve agreed objectives.
Controls
- Continue to keep a watching brief.
- Revisit the MTFS & if necessary 2024/25 budget in year.
- Evaluate and discuss with Members possible future actions to mitigate loss of income. e.g. Corporate Restructure, cuts to non-statutory services, investment and infrastructure projects that generate income.
Quarterly update
The Rateable Value listing remains higher than it started, which retains a greater share of the business rates funding in the Sussex Pool area.
Target Risk
Medium (12) (Threat; Medium; Major)
Current Risks
Medium (12) (Threat; Medium; Major)
Responsible Officer
Director of Resources
Action Officer
Head of Finance and Performance
006 Non-compliance with control procedures.
Officers are either unaware of expected controls or do not comply with control procedures.
Risk Cause
Governance: Managers are responsible for ensuring that controls to mitigate risks are consistently applied.
Risk Effects
Failure of business objectives. Health & Safety. Financial. Service Delivery. Compliance with Regulations. Personal Privacy Infringement. Reputation damage.
Controls
- Officer training
- All Service Managers required to sign an Assurance Statement. (By 30th June Annually) (Cyclical)
- Internal Audits identify service based issues and help managers to resolve these.
- Programme of training and information to ensure all managers understand their roles.
Quarterly update
The Annual Governance Statement (AGS) actions in the 2023/24 action plan were implemented. The internal audit opinions issued in 2023/24 were either Substantial or Reasonable. The Chief Internal Auditor issued a Reasonable opinion. Minor breaches in controls have been reported in the AGS and actions are being addressed. These are not considered significant. There has been one partial assurance opinion issued in 2024/25 but no significant issues or risks to report in the year to date.
Target Risk
Low (8) (Threat; Low; Major)
Current Risks
Medium (12) (Threat; Medium; Major)
Responsible Officer
Director of Resources
Action Officer
Director of Resources
007 A health & safety failure occurs.
A health & safety failure occurs.
Risk Cause
Physical. The Council is responsible for the health & safety (H&S) of its clients, staff and other stakeholders, owns and maintains significant assets, and also has responsibility for H&S in some partner organisations where it does not have operational control.
Risk Effects
People come to harm. Complaints/claims/ litigation. Financial losses. Censure by audit / inspection. Reputation damage. Adverse effect on morale. Stress and absenteeism.
Controls
- H&S Management Forum reviews corporate inspection strategy and all other H&S issues quarterly. An audit programme is in place to provide assurances on varying aspects of managing H&S. A Personal Safety of Staff and Lone Working audit completed last year gave Reasonable Assurance.
- Training programme includes annual refreshers on a rolling programme. All mandatory H&S training must be completed as part of probation. Compliance is monitored centrally by the HR service and non-compliance escalated to Heads of Service initially and thereafter to SLT.
- Risk assessments undertaken and reviewed as required.
- H&S Officer regularly reviews high risk areas personally.
Quarterly update
Risk assessments are being undertaken, reviewed, and updated. Refresher training on Fire Safety for all staff has been completed in Q4, 2023/24. All other control actions are ongoing. In light of recent incidents in our refuse service, we have reviewed our H&S procedures and procedures which were found to be robust.
Target Risk
Medium (10) (Threat; Low; Critical)
Current Risks
Medium (10) (Threat; Low; Critical)
Responsible Officer
Director of Resources
Action Officer
Director of Resources
008 Key Contractor Failure.
Key contractor failure.
Risk Cause
Uncertainty in the UK and World economy. Instability and high-profile failures.
Risk Effects
Financial.
Controls
- Regularly check accounts of key suppliers.
- Check public liability insurance of key suppliers.
- Ask for key suppliers’ business continuity plans.
- Consider whether the failure of a key supplier needs to go in service business continuity plan.
Quarterly update
The impact of the world shortage of building supplies remains uncertain. Risk of inflation (now falling), interest rates, and recession are being monitored. Some suppliers are starting to come forward to increase prices outside of the contract, which is being resisted. The Council terminated two contracts in 2023/24; one by mutual agreement with the supplier resulting in a termination payment to the Council, the other because of poor supplier performance. Both are being re-procured during 2024/25 and interim measures are in place. Key contracts are reviewed as part of the ongoing contact management arrangements and officers have been reminded to check the financial health of key suppliers and be ready to implement alternative arrangements.
Target Risk
Medium (10) (Threat; Low; Critical)
Current Risks
Medium (10) (Threat; Low; Critical)
Responsible Officer
Director of Resources
Action Officer
Head of HR and OD
009 Adopting an up to date Local Plan by end of 2025.
Delay to plan preparation due to the requirement of the plan to demonstrate water neutrality, or as a result of significant / unexpected changes to government guidance. Adverse outcome of Kilnwood Vale inquiry re access to the Sussex North Offsetting Scheme (SNOWs) / Local Plan delivery.
Risk Cause
Requirement to adopt an up-to-date Local Plan by end 2025 in accordance with government requirements.
Risk Effects
Economic and environmental damage to district as a result of limits to development which can take place. Council loses control over SNOWs prioritisation. Significant risk of speculative development prior to adoption of local plan, with impact on Local Plan trajectory and how this may be defended at the Local Plan examination.
Controls
- Joint working with partners to develop water neutrality mitigation strategy.
- Keep watching brief on government messaging on planning reforms.
- Sufficient staff and budgetary resourcing to support progression through regulatory stages of consultation, evidence base preparation and examination.
- Officers seeking KC advice and support prior to submission and to support through the examinations process.
Quarterly update
Inspector's Matters, Issues and Questions (MIQs) received 14 October 2024 - Local Plan hearings now programmed for December 2024 and January 2025. Depending on the outcome of these it may be that the threat level can be downgraded at the next review - it is a little early to know the Inspector's precise views.
Target Risk
Medium (5) (Threat; Very Low; Critical)
Current Risks
High (15) (Threat; Medium; Critical)
Responsible Officer
Director of Place
Action Officer
Head of Strategic Planning
010 Data security.
Major data breach or leak of sensitive information to a third party. Risk of significant Information Commissioner's Office (ICO) fine for non-compliance with General Data Protection Regulations (GDPR).
Risk Cause
Managerial / Professional. The Council has a legal obligation to protect personal data. The Information Commissioners powers are much more far reaching since changes in May 2018.
Risk Effects
People and businesses come to harm and suffer loss that might not otherwise have occurred. Complaints / claims / litigation. Resources consumed in defending claims. Financial losses. Fines from regulators. Adverse publicity. Reputation damage.
Controls
- Develop appropriate processes & procedures which underpin the IT Security Policy.
- Provide a programme of Induction and at least annual training on Information Security to all staff.
- Annual Public Services Network (PSN) Accreditation.
- Representatives from each department meet every other month to maintain compliance, updates and training.
Quarterly update
The situation is being monitored and training for phishing attacks has increased and specialist Election training has also been undertaken. A policy on the use of AI has been issued for staff and members. Risk rating has increased though due to the external environment and security concerns associated with it and Council operations.
Target Risk
Low (8) (Threat; Low; Major)
Current Risks
Medium (12) (Threat; Medium; Major)
Responsible Officer
Director of Resources
Action Officer
Head of Customer & Digital Services
011 Cyber security and business continuity.
A malicious attacker exploits a known or unknown security weakness to penetrate the Council’s ICT systems. IT not working due to environmental and economic problems: fire, flood, power cut and issues with the supply chain preventing new infrastructure arriving in a timely manner.
Risk Cause
Technological. Council services are increasingly reliant on IT systems at a time when there are greater opportunities for malicious attackers to exploit security weaknesses.
Risk Effects
Loss of key systems-disruption to Council services. Cost of investigation and recovery of systems. Fraud/theft. Loss of the integrity of Council Records. Penalties from the Information Commissioner's Office (ICO.) Adverse media coverage.
Controls
- Awareness of current threats.
- An effective ICT Service delivery team.
- Effective patching and updates to mitigate known vulnerabilities.
- Compliance with expected security standards. (PSN, PCI-DSS).
- Effective policies in place which outline security requirements for users of ICT.
- Effective back-up and recovery processes in place for Council ICT systems.
- Plan developed, approved internally and being carried out.
- Plan developed, approved internally and being carried out.
Quarterly update
Cyber awareness training is ongoing, as part of induction for new staff/ Members, and refreshed periodically. We are following government advice re heightened Cyber Security Threats. PSN Accreditation for 2024 has been achieved.. Backups have been reviewed and improved. An internal audit in October 2023 gave Reasonable Assurance in respect of Cyber Security – Response & Resilience, identifying one medium issue to test the effectiveness of the Security Incident Procedure through a desk top exercise. This has been achieved and we were found to be doing all necessary items and working on areas highlighted for improvement. A test scenario is planned for November 2024 with relevant Heads of Service, to test Silver and Bronze liaison and operational continuity in a simulated cyber attack.
Target Risk
Medium (12) (Threat; Medium; Major)
Current Risks
Medium (12) (Threat; Medium; Major)
Responsible Officer
Director of Resources
Action Officer
Head of Customer & Digital Services
012 Civil emergency.
The Council is found to have failed to fulfil its obligations under the Civil Contingencies Act in the event of a civil emergency.
Risk Cause
Legal. The Civil Contingencies Act places a legal obligation upon the Council, with partners, to assess the risk of, plan, and exercise for emergencies, as well as undertaking emergency and business continuity management. The Council is also responsible for warning and informing the public in relation to emergencies, and for advising local businesses.
Risk Effects
People and businesses come to harm and suffer loss that might not otherwise have occurred. Complaints / claims / litigation. Resources consumed in defending claims. Financial losses. Censure by regulators. Reputation damaged.
Controls
- Update corporate business continuity plan and regular review.
- Test effectiveness annually through case scenarios at Gold, Silver or Bronze levels.
- Bitesize workshops to address new procedures and processes.
Quarterly update
All plans are up to date. All Neighbourhood Wardens have been trained as Rest Centre Managers and some are earmarked for Incident Liaison Officer training later in the year. A small group of Heads of Service has been established to manage emergencies out-of-hours at 'bronze level', with training by the Police scheduled for October. Training on Resilience Direct was delivered in the last quarter. Hybrid bitesize workshops are being offered for: Response, Business Continuity, Recovery, Rest Centre operations.
Target Risk
Low (8) (Threat; Low; Major)
Current Risks
Medium (10) (Threat; Low; Critical)
Responsible Officer
Director of Resources
Action Officer
Head of HR & OD
014 Climate Change.
Climate change is leading to increasing annual rainfall and more intense rain events. Warmer annual average temperatures including peaks of excessive heat in the summer. This may have an impact on service provision and residents.
Risk Cause
Human driven emissions of carbon dioxide and other greenhouse gases through the burning of fossil fuels, as well as intensive agriculture and habitat destruction have altered the global atmosphere.
Risk Effects
Increase in water logging and surface water. River flooding and surface water flooding. Extreme heat. Wildfires.
Controls
- Evaluate feasibility of climate adaptation through on-site site design and infrastructure changes, such as sustainable urban drainage, and discuss with Members.
- Review Emergency planning approach to extreme weather events.
- Officer training to keep abreast of evolving climate adaptation approaches.
Quarterly update
Update to control 1 to reference sustainable urban drainage. Carbon Literacy training for staff continues, therefore, increasing understanding of climate change. The team are looking at further targeted training to increase understanding of potential adaption to more extreme weather events. Parks and Countryside and Leisure and Culture are due to meet shortly to scope out an approach to dealing with waterlogged football pitches.
Target Risk
Medium (10) (Threat; Very High; Minor)
Current Risks
Medium (10) (Threat; Very High; Minor)
Responsible Officer
Director of Communities
Action Officer
Head of Sustainability & Greenspaces
015 Office move.
Delays in moving to new office space and having the necessary technology in place, whilst ensuring current space is reinstated as required. The expectation is that the risk will reduce throughout the life cycle of the project.
Risk Cause
Relocation of council offices.
Risk Effects
Financial losses. Reputational Damage to the Council. Disruption to services.
Controls
- Continued monitoring of project progression via weekly sub meetings and project team update meetings.
- Weekly onsite progress meetings to be held when works have commenced.
Quarterly update
Estimated costs were received from Designers/Architects for the office fit out. Final plans and drawings agreed and contract signed with the chosen contractor. Works are due to start at the end of October 2024 with a project build completion date of mid-January 2025. A phased move into the new offices is planned before Easter 2025. An office move newsletter has been created to update all members of staff on the project progress.
Target Risk
Low (9) (Threat; Medium; Moderate)
Current Risks
Medium (12) (Threat; High; Moderate)
Responsible Officer
Director of Place
Action Officer
Office Move Project Manager
016 Domestic Food Waste Collection.
Failure to meet the statutory target. Failure to start the service by 31 March 2026.
Risk Cause
Failure of delivery of caddies and food waste vehicles. Recruitment issues. Competing with neighbouring authorities for the same goods and services. Distribution. Storage and extra space needs.
Risk Effects
Failure to meet the deadline. Reputational damage. Lack of buy in from residents. Failure to meet national recycling targets.
Controls
- Fortnightly project meetings with key members of staff and monthly project board meetings.
- External meetings with West Sussex Waste Partnership to share ideas, information and updates.
- Working with a delivery company to manage production and delivery of caddies, and securing early procurement.
- Recruitment plan being developed with HR.
Quarterly update
Caddies have now been ordered. Vehicles are being specified and we will make a direct award to the preferred supplier. Early procurement will again help mitigate and reduce the risk of not being able to implement in time. The O'Licence has been approved. A recruitment plan is also being developed with HR. Depot space and storage options remain a priority.
Target Risk
Low (9) (Threat; Medium; Moderate)
Current Risks
Medium (12) (Threat; High; Moderate)
Responsible Officer
Director of Communities
Action Officer
Head of Waste and Recycling
018 The Capitol Refurbishment project.
Financial. Timescales. Reputation - political and organisational. Environmental. Cultural.
Risk Cause
Financial - lack of financial management and oversight, increasing material costs and inflation. Timescales - lack of project management, slow decision making and availability of materials. Reputational - lack of project management and poor political decision making. Environmental - lack of project management. Cultural - lack of ability to programme cultural offer with confidence.
Risk Effects
Financial - negative impact on the Council's financial reserves beyond agreed figures. Timescales - negative impact on reserves and revenue (and further programme income. Reputational - negative public perception on the Council both politically and organisationally and its ability to manage projects and finances in the future. Environmental - unable to hit the Council's net zero ambition by 2030. Cultural - unable to provide cultural offer to residents of the district for an extended period.
Controls
- The Council's Project Board meet fortnightly to discuss all relevant information and steer the project. The project is planned across RIBA stages with a freeze implemented at the end of every stage where consideration is given to how to proceed. All necessary project documents are in place.
- The Project Design Team (contractors) meet fortnightly with the Council's representation. All relevant decisions and issues presented at fortnightly Project Team Board meetings for discussion.
- Member briefings are scheduled at the end of each RIBA stage plus a fortnightly 'dashboard' update is circulated to all members.
Quarterly update
Current review is looking at how increasing costs associated to materials and inflation are managed.
Target Risk
High (15) (Threat; Medium; Critical)
Current Risks
High (20) (Threat; High; Critical)
Responsible Officer
Director of Communities
Action Officer
Head of Leisure & Culture