Attachment 3
Tower Hamlets
02 April 2019
Appendix 6 – Place Directorate Risks
CPT
Responsibility
Total
I
L
Required Control Measures
Total
I
L
Existing Control Measures
Current Risk
Target Risk
Risks
Consequences
Triggers
Risk Ref
DRDH0020
Mark Baigent
Weekly monitoring of arrears performance
Service manager monitors overall performance on weekly basis
Reduce risk of future former tenant debts going statute barred
All homeless applicants with rent arrears required to complete standing order for affordable payments to FTA as condition of receiving permanent offer of accommodation; further instruction has been issued to all staff that offers are only to be approved to applicants in arrears if they are compliant with arrears procedure and they have completed a S/O form. This is now to be monitored by the Income Team; part‑time cover for the Income Team Admin officer is in place; target date for monitoring process put back; recruitment to vacant Admin officer post underway; confirmation of monitoring arrangements pending; Admin officer appointed and due to start in December 2017; management team now actively considering process amendments to improve the submission of standing order forms for people receiving final offers of accommodation. Admin post now filled, team fully staffed for the first time in over a year. Team working on backlog.
May 2018: Completed SO forms are being received by the team and are 
20
15
Strategic approach to write‑off of aged debt
Agreement has been given to full write off of these debts. Awaiting final signatures on the write off cert. from Head of Revenue Services and Legal Services. Docs with Revenue Services, they will process the write offs on the systems/records etc.

statute barred debts identified and report awaiting corporate approval for write‑off; authorisation has not been obtained to date and therefore this has been escalated to Divisional Director; Revenues Services have engaged staff to undertake trace work on the statute barred debts; apparently no progress to date in approving and then actioning the report that was submitted at the end of quarter 3 2016. The lack of progress on this control measure is outside the control of this department and should really be escalated to DLT/CLT; REvenues services have said that around 10% of the debts on the write off report have been identified as 'potentially recoverable' ‑ ie have been traced.  No target yet on how to measure success, and no 
 5
 4
 5
 3

A Dynamic Outcomes‑Based Council Using Digital Innovation And Partnership Working To 

Failure to achieve target on rent collection and write‑off of uncollectable former tenant debt
Failure to reach agreement on payment of discretionary housing payment to benefit capped households
High number of households in temporary accommodation not in receipt of housing benefit
Increased rent arrears
Retention of uncollectable aged debt on balance sheet
Failure to successfully outsource trace, collect and enforcement of former tenant debt
failure by government to exempt temporary accommodation from Universal Credit roll‑out
Increase in level of bad debt and financial loss to the Council
Continued excessive aged debt balances
For more information contact the Risk Management Team on Ext: 0738 or 4051 Email: risk@towerhamlets.gov.uk
Page 1 of 8
Risk & Controls Progress Report (with Control Target Date) 6.rpt

CPT
Responsibility
Total
I
L
Required Control Measures
Total
I
L
Existing Control Measures
Current Risk
Target Risk
Risks
Consequences
Triggers
Risk Ref
being monitored. If no payment is received tenant is written to and warned of referral to debt collection agency if debt not addressed.
action yet taken on recovery.  Service Manager has asked for clarification on what happens now with the remainder of the cases put forward for write off in December 2016. Revenue Services has agreed to process write offs submitted December 2016, not yet actioned.
03/08/2018
Required Control Measure Target Date:
Caroline Fallan
Ensure trace, collect & enforcement of former tenant debt is included in revenues contract
Revenues services is procuring debt collection services; FTAs to be included in the contract specification; Service Manager is now a member of the Income Maximisation Project Board and is contributing to discussion about the debt collection contract; Revenues services have now decided to do their procurement via Request for Quotes (RFQ) process.  Further discussion required on whether it is possible to incorporate the trace/collect/Enforce of FTA into the contract or whether this service must now undertake its own process.  in the interim cases continue to be referred to existing providers. Discussions still on going
31/03/2019
Required Control Measure Target Date:
Caroline Fallan
For more information contact the Risk Management Team on Ext: 0738 or 4051 Email: risk@towerhamlets.gov.uk
Page 2 of 8
Risk & Controls Progress Report (with Control Target Date) 6.rpt

CPT
Responsibility
Total
I
L
Required Control Measures
Total
I
L
Existing Control Measures
Current Risk
Target Risk
Risks
Consequences
Triggers
Risk Ref
PLC0012
Ann Sutcliffe
Effective engagement in processes designed to establish the current position in services

Representation at decision making level

Effective engagement in flow of information from Smarter Together Programme Boards and PMO communications

16
9
Required Control Measure Target Date:
 4
 4
 3
 3

A Dynamic Outcomes‑Based Council Using Digital Innovation And Partnership Working To 

Unplanned and unintended consequences of the Council’s transformation programme negatively impacting on Place Directorate’s capacity to deliver the best outcomes for residents, strategic objectives, or the anticipated level of savings
The change management process is not thorough enough to identify the risks involved, assess the impact or effectively co‑ordinate the changes to minimise negative impacts on ongoing service delivery.
Interdependencies between change initiatives are not sufficiently known, understood or mitigated
Effective Change management processes are not followed including not understanding the current position in services 
Critical aspects of proposed changes are not sufficiently understood or mutually agreed including % transfers of budget, workload and accountability
Centralisation results in the need to carry out a plethora of subsequent restructures 
Decisions are not made transparently
Role(s) affected by more than one reorganisation
Front line services do not receive the level and/or quality of support from ‘back office’ functions to deliver the best outcomes for residents
Missed opportunities to work more efficiently and save money
Uncertainty generated by the scale, scope and number of restructures 
Informed management decisions cannot be made
Dips in performance and/or morale affect service delivery and achievement of objectives
Industrial disputes
Council has to pay compensation (settlement agreement) or is taken to an Employment Tribunal
For more information contact the Risk Management Team on Ext: 0738 or 4051 Email: risk@towerhamlets.gov.uk
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Risk & Controls Progress Report (with Control Target Date) 6.rpt

CPT
Responsibility
Total
I
L
Required Control Measures
Total
I
L
Existing Control Measures
Current Risk
Target Risk
Risks
Consequences
Triggers
Risk Ref
DRDH0001
Mark Baigent
Seek decision, at the earliest opportunity, on procuring temporary accommodation outside London
No agreement to provide additional mayor's fund; all capped households now being called in to reapply for DHP; no decision yet on how DHP is to be deployed
Seek decision, at the earliest opportunity, re Mayor's Temporary Accommodation Support Fund
This fund is currently used to limit further demand by preserving existing temporary accommodation tenancies
Assess the likely impact of the reduced benefit cap on households with existing tenancies
This is complete in respect of tenants living in temporary accommodation; a growth bid for 16/17 has been identified and options for mitigating the risk have been submitted for consideration to CMT.
Seek decision on approaching social housing providers with vacant 'difficult to let' properties
.
15
15
Required Control Measure Target Date:
 5
 3
 3
 5

People Are Aspirational, Independent And Have Equal Access To Opportunities.

The Council is unable to secure sufficient affordable self‑contained accommodation for households in immediate need
1. On July 8 2015 the government announced further reductions to the benefit cap. The total amount a household will be able to claim in benefits is £442 a week in London and £385 a week outside London. The date these changes take effect has yet to be announced. This reduction in level of benefit cap significantly increases the number of affected households. Any amount over the cap is applied as a reduction to Housing Benefit or Universal Credit.
2. Local landlords, of household’s currently in receipt of housing benefit, do not reduce rent levels to the new lower Local Housing Allowance capped rates 
3. Private sector generally shifts away from benefit dependant households
4. Landlords withdraw properties from the temporary accommodation portfolio because the general shortage of supply in London means more people are willing and capable of paying rents above Local Housing Allowance capped rates
1. Rise in homelessness and the temporary accommodation population
2. Eviction of private sector tenants reliant on Housing Benefit
3. Turmoil in the rental market
4. Greater use of B&B (at extra financial cost) and out of borough homeless temporary accommodation
5. Negative impact on initiatives to tackle overcrowding (offering private sector tenancies to overcrowded public sector tenants)
6. Subsidy shortfall of £3 million per annum
For more information contact the Risk Management Team on Ext: 0738 or 4051 Email: risk@towerhamlets.gov.uk
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Risk & Controls Progress Report (with Control Target Date) 6.rpt

CPT
Responsibility
Total
I
L
Required Control Measures
Total
I
L
Existing Control Measures
Current Risk
Target Risk
Risks
Consequences
Triggers
Risk Ref
PR0006
Richard Williams

15
6
Procure vehicles that are compliant with ULEZ before commencement 8/4/19 for area affected
The location affected is limited to Aldgate/Spitalfields.  

Procurement activity has stalled due to personnel changes in Fleet.  We are looking to restart process by engaging a contractor.  Process is being monitored through Mayors AQPB
31/03/2019
Required Control Measure Target Date:
Richard Williams
 5
 3
 2
 3

A Dynamic Outcomes‑Based Council Using Digital Innovation And Partnership Working To 

Ultra-Low Emission Zone (ULEZ) impact on the Tower Hamlets refuse collection and street cleansing contract.
The London Mayor’s office has been consulting recently to expand the ULEZ to the area covered by the north and south circular roads, and also to bring forward the start date to April 2019.
Confirmation from the London Mayor’s office, of the area the Ultra-Low Emission Zone will cover and date of implementation.
For the Tower Hamlets core contract the financial impact of bringing forward and expanding the ULEZ would be circa £3.7m early investment in vehicles (excluding the URS vehicles) if all non‑compliant vehicles were replaced. If we were to ignore the legislation and pay the fines until end of March 2020, the annual additional cost would be £695k per year in fines.

This could have a big impact on the cost of the contract extension.
PLC0009
Ann Sutcliffe

12
6
SUBSTANTIAL Follow Up Audit Rating ‑ Street Lighting
FOLLOW UP
AUDITOR: Jitendra Sheth
DATE: January 2019

FINAL AUDIT
AUDITOR: Heather‑Louise Buckingham
DATE: May 2017
Required Control Measure Target Date:
Dan Jones
LIMITED Audit Rating ‑ Refuse Collection and Street Cleansing Contracts
Internal Audit Final Report issued May 2018
Management Response Provided
 4
 3
 2
 3

A Dynamic Outcomes‑Based Council Using Digital Innovation And Partnership Working To 

Follow Up Audits are assigned an inadequate assurance rating (Limited or Nil)
Agreed Management Action Plans for completed Audits are not implemented or do not effectively mitigate the risks identified
Inadequate Audit Assurance Definitions:

Limited Assurance ‑ Weaknesses in the system of controls are such as to put the systems objectives at risk and from our testing the level of non‑compliance puts the systems objectives at risk

Nil Assurance ‑ Control is generally weak leaving the system open to significant errors or abuse and from our testing there were significant non‑compliance with basic controls which leaves the system open 
For more information contact the Risk Management Team on Ext: 0738 or 4051 Email: risk@towerhamlets.gov.uk
Page 5 of 8
Risk & Controls Progress Report (with Control Target Date) 6.rpt

CPT
Responsibility
Total
I
L
Required Control Measures
Total
I
L
Existing Control Measures
Current Risk
Target Risk
Risks
Consequences
Triggers
Risk Ref
29/03/2019
Required Control Measure Target Date:
Dan Jones
to error or abuse
PLCBR0002
Ann Sutcliffe
Arrange review of Growth and Economic Development Division's bc impact assessments prioritising essential services
Reassess based on 'No Deal' Brexit potential impact on service delivery
Check with Procurement re progress/results of supply chain risk assessment survey and mapping exercise
Emailed Zamil 13 Feb 19 re cross checking our Directorate’s list of Essential Service Provider Contacts (listed in Section 7 of our Business Continuity Operational Procedure) with the work Procurement has already embarked on:
•	supply chain risk assessment survey
•	Supplier and Provider mapping exercise of Tier 1, 2 and 3 contractors
Workforce ‑ Identify number and nature of posts in Place Directorate currently attracting a salary below £30k
Future recruitment will be inhibited by end of freedom of movement and the possible implementation of new immigration rules which would restrict immigration on jobs paying under £30,000 p.a.
12
8
Arrange review of Public Realm business continuity impact assessments prioritising essential services
Reassess based on 'No Deal' Brexit potential impact on service delivery
29/03/2019
Required Control Measure Target Date:
Dan Jones
Arrange review of Housing and Regeneration Division's business continuity impact assessments prioritising essential services
Reassess based on 'No Deal' Brexit potential impact on service delivery
29/03/2019
Required Control Measure Target Date:
Mark Baigent
Arrange review of Planning & Building Control Division's business continuity impact assessments prioritising essential services
Reassess based on 'No Deal' Brexit potential impact on service delivery
29/03/2019
Required Control Measure Target Date:
Owen Whalley
Arrange review of Property and Major Programmes Division' business continuity impact assessments prioritising essential services
Reassess based on 'No Deal' 
 4
 3
 2
 4

A Dynamic Outcomes‑Based Council Using Digital Innovation And Partnership Working To 

Effective business continuity planning for a 'NO‑DEAL BREXIT' is not carried out at the appropriate level or effective mitigation is not possible because of the limited time available, continued political uncertainty and/or inadequate government advice
The UK leaves the European Union without a negotiated withdrawal agreement ('NO‑DEAL BREXIT')
The UK government ask for a further extension of Article 50 and either the EU won't grant a longer delay or the UK and the EU cannot sign off a deal during any extension, then this would still be the default outcome.
Significant service disruption (4)
Adverse local media coverage (3)
GDPR breach ‑  without a deal the UK will no longer be recognised automatically as compliant with the requirements of the General Data Protection Regulation 
Impact on supply chains including those managed directly by the directorate and those indirect contracts managed through commissioned services
For more information contact the Risk Management Team on Ext: 0738 or 4051 Email: risk@towerhamlets.gov.uk
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Risk & Controls Progress Report (with Control Target Date) 6.rpt

CPT
Responsibility
Total
I
L
Required Control Measures
Total
I
L
Existing Control Measures
Current Risk
Target Risk
Risks
Consequences
Triggers
Risk Ref
Brexit potential impact on service delivery
29/03/2019
Required Control Measure Target Date:
Ann Sutcliffe
Check with HR re progress on gathering nationality data of workforce
There are broad concerns that council services which are heavily reliant on a non‑UK EEA workforce will face substantial recruitment and retention issues. 
Extract from HR Intranet 
We are committed to providing whatever support we can to our EU staff. To do that, we need to make sure we know exactly how many of our staff are non‑UK EU citizens and in which areas of the council they work. You can help us gather this information by logging in to your HR Self‑Service portal on the intranet and updating your personal details. On the update page, you will see there is now an option to provide your nationality. Please indicate the nationality that relates to your right to work in the UK. If you are a dual national with British citizenship as well as citizenship in another EU country, therefore not required to apply for settled status, please select UK.
29/03/2019
Required Control Measure Target Date:
Tracey Chadwick
For more information contact the Risk Management Team on Ext: 0738 or 4051 Email: risk@towerhamlets.gov.uk
Page 7 of 8
Risk & Controls Progress Report (with Control Target Date) 6.rpt

CPT
Responsibility
Total
I
L
Required Control Measures
Total
I
L
Existing Control Measures
Current Risk
Target Risk
Risks
Consequences
Triggers
Risk Ref
PMP0007
John Mitchell
MAP Medium Priority Recommendation
Collect process data and examine for future use
MAP Medium Priority Recommendation
Design toolbox 
Write Handbook with Hyperlinks
Scope and launch Intranet Channel
Build revised file sharing
Complete and sign off governance 
Sign off
Publish
MAP Medium Priority Recommendation
Build project plan for published material and action following client group consultation and revisions to current monitoring and reporting protocols.
12
4
Monitoring compliance
Drip feed processes into the governance framework as opportunities present through winding up of old processes 

Provide Monitoring of adoption of the guidance in terms of the use of templates and compliance with the shared file protocol
30/06/2019
Required Control Measure Target Date:
John Mitchell
 3
 4
 2
 2

A Borough That Our Residents Are Proud Of And Love To Live In.

There is a risk that uncoordinated processes within Capital Programme delivery and Client Teams will lead to delays in achieving outputs as set by the Strategic Plan and Mayors priorities covering housing and mixed site developments.
Incomplete business plans and briefs RIBA stage 1 

Duplication of resourcing through RIBA stages 2 ‑ 4.

Direct approaches to procurement with no Business Case, Client Brief or PID in place / delays in design sign off.

Communications plans not in place

The use of non‑standard project and programme documentation
Delays in the delivery of the Council's Housing and mixed site Non Housing development programme.

Negative effect on resource allocation leading to high burn programming

Failure to deliver Capital Projects on time

Reputational risk to the council
For more information contact the Risk Management Team on Ext: 0738 or 4051 Email: risk@towerhamlets.gov.uk
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Risk & Controls Progress Report (with Control Target Date) 6.rpt