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Actions for Service NSW's handling of personal information

Service NSW's handling of personal information

Premier and Cabinet
Finance
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Management and administration
Risk
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The Auditor-General for New South Wales, Margaret Crawford, released a report today examining the effectiveness of Service NSW’s handling of customers’ personal information to ensure its privacy.

The audit found that Service NSW is not effectively handling personal customer and business information to ensure its privacy. Service NSW continues to use business processes that pose a risk to the privacy of personal information. This includes the routine emailing of personal information between Service NSW service centres and other agencies, which is one of the processes that contributed to the data breach earlier this year. The audit found that previously identified risks and recommended solutions had not been implemented on a timely basis.

The Auditor-General made eight recommendations aimed at ensuring improved processes, technologies, and governance arrangements for how Service NSW handles customers’ personal information.

The Hon. Victor Dominello, MP, Minister for Customer Service, requested this audit under section 27(B)(3)(c) of the Public Finance and Audit Act 1983 following public reports in May 2020 of a cyber security attack which had led to a breach of Service NSW customer information. This audit also included the Department of Customer Service which supports Service NSW with privacy, risk and governance functions.

Service NSW was established in 2013 with the intention that it would, over time, 'become the primary interaction point for customers accessing New South Wales Government transaction services'.

Service NSW's functions are set out in the Service NSW (One stop Access to Government Services) Act 2013. This legislation allows for other NSW Government agencies to delegate to and enter into agreements with the Chief Executive Officer of Service NSW in order for Service NSW to undertake service functions for the agency.

Service NSW now has agreements with 36 NSW Government client agencies to facilitate over 1,200 types of interactions and transactions for the community.

The nature of each agreement between Service NSW and its client agencies varies. Some client agencies have delegated authority to allow Service NSW staff to conduct transactions on their behalf in the agencies' systems. Other arrangements do not include the same degree of delegation. In these cases, Service NSW provides services such as responding to enquiries and validating documents.

In addition, Service NSW conducts transactions for its own programs, such as the Seniors Card. Personal information for these programs, as well as information for customers' MyServiceNSW accounts, are stored by Service NSW on its Salesforce Customer Relationship Management (CRM) system.

In March 2020, Service NSW suffered two cyber security attacks in short succession. Technical analysis undertaken by the Department of Customer Service (DCS) concluded that these attacks resulted from a phishing exercise through which external threat actors gained access to the email accounts of 47 staff members. These attacks resulted in the breach of a large amount of personal customer information that was contained in these email accounts. See Section 1.1 for further details.

This audit is being conducted in response to a request from the Hon. Victor Dominello, Minister for Customer Service, under section 27B(3)(c) of the Public Finance and Audit Act 1983. Minister Dominello requested that the Auditor General conduct a performance audit in relation to Service NSW's handling of sensitive customer and business information.

This audit assessed how effectively Service NSW handles personal customer and business information to ensure its privacy.

It addressed the following:

  • Does Service NSW have processes and governance in place to identify and manage risks to the privacy of personal customer and business information?
  • Does Service NSW have policies, processes and systems in place that support the effective handling of personal customer and business information to ensure its privacy?
  • Has Service NSW effectively implemented its policies, processes and systems for managing personal customer and business information?

Conclusion

Service NSW is not effectively handling personal customer and business information to ensure its privacy. It continues to use business processes that pose a risk to the privacy of personal information. These include routinely emailing personal customer information to client agencies, which is one of the processes that contributed to the March 2020 data breach. Previously identified risks and recommended solutions had not been implemented on a timely basis.

Service NSW identifies privacy as a strategic risk in both its Risk Management Guideline and enterprise risk register and sets out a zero level appetite for privacy risk in its risk appetite statement. That said, the governance, policies, and processes established by Service NSW to mitigate privacy risk are not effective in ensuring the privacy of personal customer and business information. While Service NSW had risk identification and management processes in place at the time of the March 2020 data breach, these did not prevent the breach occurring.

Some of the practices that contributed to the data breach are still being followed by Service NSW staff. For example, business processes still require Service NSW staff to scan and email personal information to some client agencies.

The lack of multi factor authentication has been identified as another key contributing factor to the March 2020 data breach as this enabled the external threat actors to gain access to staff email accounts once they had obtained the user account details through a phishing exercise. Service NSW had identified the lack of multi factor authentication on its webmail platform as a risk more than a year prior to the breach and had committed to addressing this by June 2019. It was not implemented until after the breach occurred.

There are weaknesses in the general IT and security controls implemented by Service NSW over its Salesforce Customer Relationship Management (CRM) system, which holds the personal information of over four million NSW residents.

Internal audits carried out by Service NSW, including one completed in August 2020, have identified significant weaknesses in the general IT and security controls implemented by Service NSW over its Salesforce CRM system. These include deficiencies in the management of role based access, monitoring and audit of user access, and partitioning of program specific transaction information. These deficiencies create an increased risk of unauthorised access to the personal information of over four million customers held in the system.

Lines of responsibility for meeting privacy obligations are not clearly drawn between Service NSW and its client agencies.

Service NSW has agreements in place with client agencies. However, the agreements lack detail and clarity about the roles and responsibilities of the agencies in relation to the collection, storage and security of customer's personal information. This lack of clarity raises the risk that privacy obligations will become confused and missed between the agencies.

Service NSW carries out privacy impact assessments for major new projects but does not routinely review existing processes and systems.

Service NSW carries out privacy impact assessments as part of its routine processes for implementing major new projects, ensuring that privacy management is considered as part of project design. Service NSW does not regularly undertake privacy impact assessments or reviews of existing or legacy processes and systems, which has resulted in some processes continuing despite posing significant risks to the privacy of personal information, such as the scanning, emailing, and storing of identification documents.

1. Key findings

Service NSW identifies privacy risks, but the controls and processes it put in place to mitigate these privacy risks were not adequate to prevent or limit the extent of the data breach that occurred in March 2020

Service NSW’s approach to risk management is framed by its Risk Management Guideline, which defines 'privacy and compliance' as one of the key types of risk for the agency. Service NSW's enterprise risk register identifies four strategic privacy related risks. Service NSW has set out a zero level appetite for privacy risk in its risk appetite statement.

Service NSW has assessed the adequacy of its controls for privacy risks as needing improvement. To be fully effective, the Risk Management Guideline says that these controls should have a focus that is ‘largely preventative and address the root causes’.

One of the business processes that was a key contributing factor to the data breach was the emailing of personal information by Service NSW staff to client agencies.

This process had been identified as a risk prior to the breach and some steps had been put in place to mitigate the risk. In particular, staff were required to manually delete emails that contained personal information. However, these measures were ineffective in preventing the breach, as the external threat actors still gained access to 47 staff email accounts that contained a large amount of personal information.

It is unclear why Service NSW did not effectively mitigate this risk prior to the breaches. However, Service NSW has advised that it implemented measures in June and October 2020 to automatically archive emails likely to contain personal information. This is expected to limit the quantity of information retained in email accounts for extended periods.

Service NSW has not put in place any technical or other solutions to avoid Service NSW staff having to scan and email personal information to some client agencies. Urgent action is needed to remove the requirement for staff to email personal information to client agencies, thereby mitigating the risk inherent in sending and storing this information using email.

There are weaknesses in the general IT and security controls implemented by Service NSW over its Salesforce CRM system, which holds the personal information of over four million customers

There are weaknesses in the general IT and security controls implemented by Service NSW over its Salesforce CRM system. These weaknesses include deficiencies in governance of role based access, monitoring and audit of staff access, and partitioning of program specific transaction information. These deficiencies create an increased risk of unauthorised access to the personal information of over four million customers which is stored in this system.

In addition, there is an absence of important controls to safeguard customers' privacy, such as multi factor authentication and reviewable logs of access history to their information. Such controls, when properly implemented, would enhance the control that customers are able to exercise over their personal information.

A privacy impact assessment conducted on Service NSW’s Salesforce CRM system in 2015 recommended that the system include the ability for customers to review access history to their personal information, as well as the option for customers to apply multi factor authentication to their accounts. While both these recommendations appeared positively received by Service NSW, neither have been implemented.

Since its inception, Service NSW’s use of Salesforce has extended to storing transaction data, particularly for transactions for which Service NSW is responsible, such as the Seniors Card. It also holds details of over four million MyServiceNSW account holders, including name, email address and phone number, and optional address details. It was not originally intended for the system to hold this volume and nature of customer information.

Lines of responsibility for meeting privacy obligations are unclear between Service NSW and its client agencies

Service NSW's privacy management plan does not clearly set out the privacy obligations of Service NSW and its client agencies. It sets out that 'compliance with the privacy principles will primarily be the responsibility of that [client] agency'. However, Service NSW has its own obligations under the security principles of the Privacy and Personal Information Protection Act 1998 (PPIP Act) to take reasonable steps to prevent unauthorised access to personal information, which is not made clear in the privacy management plan.

The agreements between Service NSW and client agencies reviewed for this audit only include general and high level references to privacy. Most do not include details of each parties' privacy responsibilities such as: which agency will provide the customer with a privacy notice explaining how their personal information will be handled, how personal information will be kept secure, how long Service NSW will retain information, what processes will be followed for internal reviews, and what specific planning is in place to respond to data breaches.

Service NSW's privacy management plan has not been updated to include new programs and governance changes

Service NSW's privacy management plan includes most of the matters required by law or good practice, with some exceptions. It does not explain any exemptions that the agency commonly relies on under the PPIP Act and does not address any health information that Service NSW may handle. It had also not been updated to reflect governance changes and the fact that, at the time this audit commenced, Service NSW was disclosing the content of internal review applications (the formal expression for 'complaints') to the Department of Customer Service (DCS). These governance changes were part of the centralisation of Service NSW's corporate support functions into DCS in late 2019, though internal review staff were seconded back into Service NSW during the course of this audit.

The current July 2019 privacy management plan has also not been updated since the rollout of a number of major new initiatives in 2020. These include 2019–20 bushfire emergency recovery initiatives (such as small business grants) and COVID 19 pandemic response initiatives (such as small business grants, border permits and the COVID safe check in app).

Service NSW routinely conducts privacy impact assessments for new initiatives, though privacy risks remain in legacy systems and processes

Service NSW routinely conducts privacy impact assessments for major new initiatives and the assessments reviewed for this audit largely accorded with good practice guidance.

Service NSW does not routinely review existing processes and systems to ensure that they are effective in ensuring the privacy of customer personal information. Business processes that create the highest risk to privacy, such as emailing of personal information, are more common in these longstanding legacy systems.

Service NSW's significant and rapid growth has outpaced the establishment of a robust control environment which has exacerbated privacy risks

Since it was established in 2013, Service NSW has experienced significant growth in the number and diversity of the types of transactions it provides, as well as the number of client agencies with which it works. The pace and extent of this growth has contributed to important controls not being properly implemented on a timely basis, which has heightened privacy risks, particularly in regard to existing, legacy systems and processes.

The pace of change and increasing demand for new program implementation has limited the opportunity for Service NSW, in collaboration with its client agencies, to revisit and redesign legacy business practices which pose a greater privacy risk. This includes the scanning and emailing of personal information.

While 2019–20 has seen additional demands placed on Service NSW in responding to the 2019–20 bushfire emergency and COVID 19 pandemic, it is the nature of the agency’s work that it operates in a fast paced and complex environment, where it is required to respond to multiple client agencies and stakeholders. Ensuring customer privacy should be integral to Service NSW’s business as usual operations.

2. Recommendations

Service NSW commissioned a number of external reviews and investigations stemming from the data breaches. The Auditor General's recommendations below have taken these other reviews into account. In order to offer assurance that it is appropriately protecting the privacy of its customers, Service NSW should address the full breadth of findings and recommendations made across all relevant reviews.

As a matter of urgency, Service NSW should:

1. in consultation with relevant client agencies and the Department of Customer Service, implement a solution for a secure method of transferring personal information between Service NSW and client agencies

2. review the need to store scanned copies of personal information and, if still required, implement a more secure method of storing this information and regular deletion of material.

By March 2021, Service NSW should:

3. ensure that all new agreements entered into with client agencies from 1 April 2021 address the deficiencies identified in this audit, including that they provide clarity on:

  • the content and provision of privacy collection notices
  • the terms by which personal information will be retained, stored, archived, and disposed of when no longer required
  • steps that will be taken by each agency to ensure that personal information is kept secure
  • the circumstances in which, and processes by which, applications for internal review will be referred by one agency to the other
  • how identified breaches of privacy will be handled between agencies

4. in collaboration with the Department of Customer Service, review its privacy management plan to address the deficiencies raised in this audit, including:

  • to clarify Service NSW's understanding of how responsibility for meeting privacy obligations are delineated between Service NSW and client agencies
  • to better reflect the full scope and complexity of personal information handled by Service NSW
  • to better explain how applications for internal review are handled between Service NSW and the Department of Customer Service
  • to ensure regular ongoing review, either according to a schedule or when Service NSW experiences substantial change to its programs and handling of personal information

5. in consultation with the Department of Customer Service, review its policies and processes for the management of privacy risks, including to:

  • ensure that there are appropriate mechanisms to escalate identified privacy risks from business units to the Executive Leadership Team
  • ensure that there are action plans to address strategic privacy risks that are assessed as having ineffective controls.
By June 2021, Service NSW should:

6. address deficiencies in the controls over, and security for, its Salesforce customer relationship management and related systems that hold customer personal information, including:

  • establish policies and processes for regular access reviews and monitoring of user activity in these systems, including for privileged users
  • enable partitioning and role based access restrictions to personal information collected for different programs
  • provide customers the choice to use multi factor authentication to further secure their MyServiceNSW accounts
  • enable customers to view the transaction history of their personal information to detect possible mishandling.
By December 2021, Service NSW should:

7. ensure that all existing agreements with client agencies address the deficiencies identified in this audit, including that they provide clarity on:

  • the content and provision of privacy collection notices
  • the terms by which personal information will be retained, stored, archived, and disposed of when no longer required
  • steps that will be taken by each agency to ensure that personal information is kept secure
  • the circumstances in which, and processes by which, applications for internal review will be referred by one agency to the other
  • how identified breaches of privacy will be handled between agencies

8. carry out a risk assessment of all processes, systems and transactions that involve the handling of personal information and undertake a privacy impact assessment for those that:

  • are identified as high risk and have not previously had a privacy impact assessment
  • have had major changes or updates since the privacy impact assessment was completed.

Appendix one – Responses from agencies

Appendix two – About the audit

 

Copyright notice

© Copyright reserved by the Audit Office of New South Wales. All rights reserved. No part of this publication may be reproduced without prior consent of the Audit Office of New South Wales. The Audit Office does not accept responsibility for loss or damage suffered by any person acting on or refraining from action as a result of any of this material.

Published

Actions for Education 2020

Education 2020

Education
Asset valuation
Compliance
Financial reporting
Fraud
Information technology
Internal controls and governance
Management and administration
Procurement

The Auditor-General for New South Wales, Margaret Crawford, released a report today titled Education 2020. This report focuses on key observations and findings from the most recent audits of agencies in the Education cluster.

Unqualified audit opinions were issued for all cluster agencies’ financial statements. However, internal control deficiencies were identified across the cluster agencies, including deficiencies in the management of purchasing cards and 15 internal control issues that were repeated from the previous year.

The 2019–20 natural disasters caused widespread damage in both Northern and Southern NSW. The COVID‑19 pandemic further challenged agencies, requiring social distancing and other infection control measures which disrupted the traditional means of teaching students. Agencies have adjusted their operations to respond to these emergency events.

The TAFE Commission’s revenues 2019–20 were impacted by the pandemic. Lower enrolments and an increase in fee-free short courses offered during the year contributed to the result.

Read the PDF report

This report analyses the results of our audits of financial statements of entities within the Education cluster for the year ended 30 June 2020. The table below summarises our key observations and recommendations.

1. Financial reporting 

Audit opinions Unqualified audit opinions were issued for all cluster agencies' 30 June 2020 financial statements audits.
New accounting standards

Agencies implemented three new accounting standards during the year.

Our financial statement audits of the Department of Education (the Department) and NSW Education Standards Authority (NESA) identified issues with the leasing information provided by Property NSW (PNSW). Despite the outsourcing arrangement, both the Department and NESA remain ultimately responsible for the completeness and accuracy of this information, which would have benefited from a more thorough quality assurance, validation and review process before they placed reliance upon it.

Recommendation:

We recommend the Department and NESA:

  • quality assure and validate the information provided by PNSW
  • ensure changes made by PNSW to lease data are supported and that assumptions and judgements applied are appropriate
  • document their review of the data supplied.
Changes were made to the financial reporting requirements this year to account for the impact of the pandemic

Emergency legislation was enacted during the year in response to the COVID-19 pandemic. The legislation revised the statutory reporting deadlines for agencies to submit their financial statements and allowed the Treasurer to continue authorising payments from the consolidated fund until the enactment of the 2020–21 budget.

All cluster agencies prepared their financial statements on a going concern basis and submitted their financial statements within the revised statutory deadlines.

The State provided $159.0 million in stimulus funding to support the operations of cluster agencies during emergency events. Nearly half of this funding was to support cleaning activities by the Department and the Technical and Further Education Commission (the TAFE Commission) during the COVID-19 pandemic.

Quality and timeliness of financial reporting

The number of monetary misstatements identified in agencies' financial statements decreased to 14 (23 in 2018–19).

While the number of corrections made to the financial statements after the submission date increased to eight (two in 2018–19), it is important to note these corrections provide parliament and other users of the financial statements increased confidence in the accuracy and presentation of agencies' performance and financial position.

Sustainability of cluster agencies The TAFE Commission's enrolments declined, and operating margins reduced, both being impacted by the COVID-19 pandemic.

2. Audit observations

Internal control deficiencies

We identified 33 internal control issues, including 15 findings that were repeated from previous years.

A high-risk issue was reported at the Department relating to the inadequate monitoring and follow up of privileged user activity in its enterprise resource planning system – SAP.

Repeat findings relate to ongoing deficiencies in information technology controls and management policies, practices and procedures.

Recommendation:

Cluster agencies should:

  • prioritise and action recommendations to address internal control deficiencies
  • review and confirm the appropriateness of existing privileged user access accounts
  • implement a rigorous monitoring regime to ensure that any improper use of privileged user accounts can be detected in a timely manner.
Agency responses to emergency events

The Department established a separate bushfire relief directorate and COVID-19 Taskforce to assist and support school communities in response to recent emergencies.

Other cluster agencies have established committees or response teams to oversee and address all aspects of the impact of COVID-19.

Schools review 2019 We continue to identify instances of non-compliance in relation to cash management and procurement at schools.
Use of purchasing cards at the Department of Education

Since 2015, the NSW Government has encouraged the use of purchasing cards by public sector agencies. Purchasing cards are efficient to transact low value, high volume procurement of goods and services, but the use must be effectively monitored.

Our review of the Department's purchasing cards identified weaknesses in its oversight and monitoring controls, including the issue and cancellation of purchasing cards

Opportunities exist for the Department to better monitor card use. Tools such as data analytics are an efficient and effective detective control to identify irregular activity or misuse by cardholders.

Recommendation:

The Department should:

  • improve the accuracy and completeness of exit procedures for terminated employees to ensure cards are returned and cancelled
  • perform periodic reviews to ensure active cards are held only by current employees
  • set transaction limits that do not exceed the limits of the user’s financial delegation
  • establish a data analytics regime to help analyse and identify high risk patterns and anomalies in their purchasing card usage, augmenting their existing monitoring and detective controls.

 

This report provides parliament and other users of the Education cluster’s financial statements with the results of our audits, our observations, analysis, conclusions and recommendations in the following areas:

  • financial reporting
  • audit observations
  • the impact of emergencies and the COVID-19 pandemic.

Financial reporting is an important element of good governance. Confidence and transparency in public sector decision making are enhanced when financial reporting is accurate and timely.

The COVID-19 Legislation Amendment (Emergency Measures–Treasurer) Act 2020 amended legislation administered by the Treasurer to implement further emergency measures as a result of the COVID-19 pandemic. These amendments:

  • allowed the Treasurer to authorise payments from the consolidated fund until the enactment of the 2020–21 budget – supporting the going concern assessments of cluster agencies
  • revised budgetary, financial and annual reporting time frames – impacting the timeliness of financial reporting
  • exempted certain statutory bodies and departments from preparing financial statements.

This chapter outlines our audit observations related to the financial reporting of agencies in the Education cluster for 2020, including any financial implications from the recent emergency events.

Section highlights 

Unqualified audit opinions were issued on the financial statements of cluster agencies.

All cluster agencies met the revised statutory deadlines for completing early close procedures and submitting their financial statements.
 
Emergency legislation allowing the Treasurer to continue authorising payments from the consolidated fund under the existing Appropriations Act enabled cluster agencies to prepare financial statements on a going concern basis.

Appropriate financial controls help ensure the efficient and effective use of resources and administration of agency policies. They are essential for quality and timely decision making.

This chapter outlines our:

  • observations and insights from our financial statement audits of agencies in the Education cluster. It also comments on our review of elements of the financial control framework applied by schools in NSW whose financial results form part of the Department of Education's (the Department) financial statements.
  • assessment of how well cluster agencies adapted their systems, policies and procedures, and governance arrangements in response to recent emergencies.

Section highlights

  • A high-risk issue regarding inadequate monitoring of privileged user access was identified at the Department.
  • We continue to observe issues by schools in relation to cash management and non-compliance with procurement guidelines and purchasing card use.
  • Opportunities exist for the Department and cluster agencies to enhance their monitoring and review of purchasing card activities. Tools such as data analytics procedures provide an efficient and effective detective control, particularly when used in conjunction with independent spot-checks.

Appendix one – List of 2020 recommendations

Appendix two – Status of 2019 and 2018 recommendations

Appendix three – Financial data

 

Copyright notice

© Copyright reserved by the Audit Office of New South Wales. All rights reserved. No part of this publication may be reproduced without prior consent of the Audit Office of New South Wales. The Audit Office does not accept responsibility for loss or damage suffered by any person acting on or refraining from action as a result of any of this material.

Published

Actions for Support for regional town water infrastructure

Support for regional town water infrastructure

Industry
Environment
Local Government
Infrastructure
Management and administration
Regulation
Risk

The Auditor-General for New South Wales, Margaret Crawford, released a report today examining whether the Department of Planning, Industry and Environment has effectively supported the planning for, and funding of, town water infrastructure in regional NSW.

The audit found that the department has not effectively supported or overseen town water infrastructure planning since at least 2014. It does not have a clear regulatory approach and lacks internal procedures and data to guide its support for local water utilities that service around 1.85 million people in regional NSW.

The audit also found that the department has not had a strategy in place to target investments in town water infrastructure to the areas of greatest priority. A state-wide plan is now in development.

The Auditor-General made seven recommendations to the department, aimed at improving the administration and transparency of its oversight, support and funding for town water infrastructure, and at strengthening its sector engagement and interagency coordination on town water planning issues and investments.

According to the Auditor-General, ‘A continued focus on coordinating town water planning, investments and sector engagement is needed for the department to more effectively support, plan for and fund town water infrastructure, and to work with local water utilities to help avoid future shortages of safe water in regional towns and cities.’ 

This report is part of a multi-volume series on the theme of water. Refer to ‘Water conservation in Greater Sydney’ and ‘Water management and regulation – undertaking in 2020-21’.

Read full report (PDF)

Safe and reliable water and sewer services are essential for community health and wellbeing, environmental protection, and economic productivity. In 2019, during intense drought, around ten regional New South Wales (NSW) cities or towns were close to ‘zero’ water and others had six to 12 months of supply. In some towns, water quality was declared unsafe.

Ensuring the right water and sewer infrastructure in regional NSW to deliver these services (known as 'town water infrastructure') involves a strategic, integrated approach to water management. The NSW Government committed to ‘secure long-term potable water supplies for towns and cities’ in 2011. In 2019, it reiterated a commitment to invest in water security by funding town water infrastructure projects.

The New South Wales’ Water Management Act 2000 (WM Act) aims to promote the sustainable, integrated and best practice management of the State’s water resources, and establishes the priority of town water for meeting critical human needs.

The Department of Planning, Industry and Environment (the department) is the lead agency for water resource policy, regulation and planning in NSW. It is also responsible for ensuring water management is consistent with the shared commitments of the Australian, State and Territory Governments under the National Water Initiative. This includes the provision of healthy, safe and reliable water supplies, and reporting on the performance of water utilities.

Ninety-two Local Water Utilities (LWUs) plan for, price and deliver town water services in regional NSW. Eighty-nine are operated by local councils under the New South Wales’ Local Government Act 1993, and other LWUs exercise their functions under the WM Act. The Minister for Water, Property and Housing is the responsible minister for water supply functions under both acts.

The department is the primary regulator of LWUs. NSW Health, the NSW Environment Protection Authority (EPA) and the Natural Access Resource Regulator (NRAR) also regulate aspects of LWUs' operations. The department’s legislative powers with respect to LWUs cover approving infrastructure developments and intervening where there are town water risks, or in emergencies. In this context, the department administers the Best Practice Management of Water Supply and Sewerage Guidelines (BPM Guidelines) to support its regulation and to assist LWUs to strategically plan and price their services, including their planning for town water infrastructure.

Under the BPM Guidelines, the department supports LWU’s town water infrastructure planning with the Integrated Water Cycle Management (IWCM) Checklist. The Checklist outlines steps for LWUs to prepare an IWCM strategy: a long-term planning document that sets out town water priorities, including infrastructure and non-infrastructure investments, water conservation and drought measures. The department's objective is to review and approve (i.e. give ‘concurrence to’) an IWCM strategy before the LWU implements it. In turn, these documents should provide the department with evidence of town water risks, issues and infrastructure priorities.

The department also assesses and co-funds LWU's town water infrastructure projects. In 2017, the department launched the $1 billion Safe and Secure Water Program to ensure town water infrastructure in regional NSW is secure and meets current health and environmental standards. The program was initially established under the Restart NSW Fund.

This audit examined whether the department has effectively supported the planning for and funding of town water infrastructure in regional NSW. It focused on the department’s activities since 2014. This audit follows a previous Audit Office of NSW report which found that the department had helped to promote better management practices in the LWU sector, up to 2012–13.

Conclusion

The Department of Planning, Industry and Environment has not effectively supported or overseen town water infrastructure planning in regional NSW since at least 2014. It has also lacked a strategic, evidence-based approach to target investments in town water infrastructure.

A continued focus on coordinating town water planning, investments and sector engagement is needed for the department to more effectively support, plan for and fund town water infrastructure, and work with Local Water Utilities to help avoid future shortages of safe water in regional towns and cities.

The department has had limited impact on facilitating Local Water Utilities’ (LWU) strategic town water planning. Its lack of internal procedures, records and data mean that the department cannot demonstrate it has effectively engaged, guided or supported the LWU sector in Integrated Water Cycle Management (IWCM) planning over the past six years. Today, less than ten per cent of the 92 LWUs have an IWCM strategy approved by the department.

The department did not design or implement a strategic approach for targeting town water infrastructure investment through its $1 billion Safe and Secure Water Program (SSWP). Most projects in the program were reviewed by a technical panel but there was limited evidence available about regional and local priorities to inform strategic project assessments. About a third of funded SSWP projects were recommended via various alternative processes that were not transparent. The department also lacks systems for integrated project monitoring and program evaluation to determine the contribution of its investments to improved town water outcomes for communities. The department has recently developed a risk-based framework to inform future town water infrastructure funding priorities.

The department does not have strategic water plans in place at state and regional levels: a key objective of these is to improve town water for regional communities. The department started a program of regional water planning in 2018, following the NSW Government’s commitment to this in 2014. It also started developing a state water strategy in 2020, as part of an integrated water planning framework to align local, regional and state priorities. One of 12 regional water strategies has been completed and the remaining strategies are being developed to an accelerated timeframe: this has limited the department’s engagement with some LWUs on town water risks and priorities.

Regional New South Wales (NSW) is home to about a third of the state's population. Infrastructure that provides safe and reliable water and sewer services (also known simply as 'town water infrastructure') is essential for community health and wellbeing, environmental protection, and economic productivity. Planning for and meeting these infrastructure needs, as well as identifying when non-infrastructure options may be a better solution, involves a strategic and integrated approach to water resource management in regional NSW.

We examined whether the department has effectively supported planning for town water infrastructure since 2014. This assessment was made in the context of its current approach to LWU sector regulation. The findings below focus on whether the department has an effective framework including governance arrangements for town water issues to inform state-wide strategic water planning, and whether (at the local level) the department has effectively overseen and facilitated town water infrastructure planning through its Integrated Water Cycle Management (IWCM) planning guidance to LWUs.

We examined whether the department has effectively targeted town water infrastructure funding to policy objectives, with a focus on the design and implementation of the Safe and Secure Water Program (SSWP) since its commencement in 2017. The program’s aim was to fund town water infrastructure projects that would deliver health, social and environmental benefits, and support economic growth and productivity. We also assessed the department’s capacity to demonstrate the outcomes of the SSWP funding and the contributions of its town water infrastructure investments more broadly. Finally, we identified risks to the effectiveness of the department’s work underway since 2018–19, which is intended to enhance its strategic water planning and approach to prioritising investments in reducing town water risks.

Appendix one – Response from agency

Appendix two – Key terms

Appendix three – About the audit

Appendix four – Performance auditing

 

Copyright notice

© Copyright reserved by the Audit Office of New South Wales. All rights reserved. No part of this publication may be reproduced without prior consent of the Audit Office of New South Wales. The Audit Office does not accept responsibility for loss or damage suffered by any person acting on or refraining from action as a result of any of this material.

Parliamentary reference - Report number #341 - released 24 September 2020

Published

Actions for Credit card management in Local Government

Credit card management in Local Government

Local Government
Internal controls and governance
Management and administration
Procurement
Risk

The Auditor-General for New South Wales, Margaret Crawford, released a report today examining credit card management in Local Government.

The audit was in response to a letter from the then Minister for Local Government in November 2018. The audit assessed the effectiveness of credit card management practices in six councils, including in the areas of policies, procedures, compliance and monitoring.

The audit found that all six councils had gaps in their credit card policies and procedures. The Auditor-General recommended that the Department of Planning, Industry and Environment publish guidelines on credit card management for the Local Government sector. The report also generated insights for the Local Government sector with respect to credit card management.

Read full report (PDF)

In 2018–19, all councils responding to an Audit Office survey (representing over 90 per cent of the sector) indicated they issued credit cards to staff members to make work-related purchases. As there are no sector-wide requirements or policies for credit card use and management in Local Government, councils have developed their credit card management frameworks to suit their own needs. The quality of credit card policies and procedures may therefore vary across the sector.

Credit cards are an efficient means of payment, especially for low-value purchases. Compared to the use of petty cash, credit card transactions provide better transparency and accountability for expenditure. By using credit cards, councils only need to make one payment each month, which can reduce the time spent on paying separate vendors, as in the case of purchase orders.

This audit assessed the effectiveness of credit card management practices in six councils: Dubbo Regional Council, Junee Shire Council, Lane Cove Council, Nambucca Valley Council, Penrith City Council and Shellharbour City Council. The councils selected represent a mix of rural, regional and metropolitan councils. They were also among the top ten users of credit cards within their geographical classification, in terms of the number of credit cards issued or the number of transactions per credit card.

This audit referenced the NSW Treasury's Policy and Guidelines Paper TPP17–09 'Use and Management of NSW Government Purchasing Cards', as its principles and recommendations for NSW Government agencies are relevant for councils.

The Audit Office of New South Wales Report on Local Government 2019 provided a high-level overview of credit card management across the sector. While over 90 per cent of councils reported that they had a credit card policy and a credit card acquittal process, the quality of these policies and procedures may vary across the sector as there is no standardised or recommended approach to credit card management for Local Government. This audit complements the Report on Local Government 2019 by providing a detailed discussion of the effectiveness of credit card management practices in councils.

Audit conclusion

All six audited councils had important gaps in their credit card policies and procedures. Their reconciliation of credit card transactions needs to be enhanced to enable detection of potential misuse or fraud.
 
The audit found important gaps in each of the six audited councils' credit card management practices. Their policies and procedures covered the essential aspects of credit card use and management, but a lack of coverage or clarity in some areas could lead to inconsistent and inappropriate use of credit cards. These areas included: eligibility to hold a credit card, aligning credit card limits with financial delegations, and the reconciliation procedures.
 
While all six councils conducted reconciliations of credit card transactions, the processes need to be enhanced to enable detection of potential misuse or fraud. Reconciliations had focused solely on verifying receipts, and did not require evidence of business-related purposes, even for transactions such as alcohol purchases or spending at entertainment venues. Five of the six councils also did not include compliance checks in their reconciliation process, such as checking that purchases were not for restricted items.
 
The level of senior management involvement in monitoring credit card use varied across the six councils. Three of the six councils did not generate regular reports for management oversight. Five of the six councils had no plans for internal audits or targeted reviews of credit card management and use.

Council staff provided with a credit card can purchase from a wide range of businesses, including online transactions with overseas vendors. However, councils may limit the types of purchases that staff can make through their policies and procedures or by setting controls that block certain transaction types such as cash advances. To examine credit card usage, the audit obtained credit card transaction data from 1 July 2016 to 30 June 2019 for the six councils in this review. The data included:

  • transaction date
  • amount
  • merchant category code (MCC)
  • merchant name.

The audit analysed the number and value of transactions by each council, and the types of purchases made using credit cards.

The existence of a documented approach to managing credit cards ensures transparency and consistency of use within the council. A credit card management framework that contains preventative and detective controls can also minimise risks of fraud, misuse and wastage.

There is no prescribed credit card management framework for Local Government, but typical components of a credit card management framework include:

  • policies and procedures
  • guidance for staff
  • monitoring and reporting.

With no detailed guidance notes similar to those in TPP17–09 for NSW Government, councils have developed their own credit card management framework based on their size, structure, resources and intended credit card usage. For instance, the size of a council has implications for the number of credit cards issued, which in turn influences the arrangements for training and guidance provided to cardholders and approvers.

The intended level of credit card usage may determine whether a council adopts a manual or electronic credit card management system and councils should identify the system that best meets their needs. For instance, a council with few credit cards may not be able to justify investment in an electronic system. On the other hand, a manual system may only be viable for councils with a low number of credit cards and a low number of transactions.

Among the six councils audited, the three councils with fewer cards and a lower number of transactions had a manual credit card management system, while the three councils with more cards and a higher number of transactions used an electronic system.

Exhibit 10 summarises the six councils' policies on use of credit cards.

Exhibit 10: Overview of the six councils' policies on credit card use
Council Audit Office classification Number of staff (full-time equivalent) Number of credit cards issued (current at August 2019) Policy on credit card use
Dubbo Regional Council Regional 453 77 Purchase cards are used for official council business up to $5,000 and the policy allows cardholders to delegate the use of their purchase cards to other staff members.
Junee Shire Council Rural 71 1 Corporate credit cards are for council business activities and minor purchases where a purchase order is not accepted. Items that can be purchased via a purchase order should not be purchased on a corporate credit card.
Lane Cove Council Metropolitan 192 6 Corporate credit cards are for official council business, but should not be used when there is an alternative form of payment that aligns with the council's purchasing process.
Nambucca Valley Council Rural 110 37 Purchase cards are used for the payment of goods and services associated with council businesses.
Penrith City Council Metropolitan 1,031 167 Purchase cards are used for ‘low value and low risk procurement of goods and services’, while corporate cards are held by senior staff for ‘non-routine low value work related purchases’.
Shellharbour City Council Regional 372 65 Credit cards are for purchases up to $9,999 and the preferred payment method for transactions under $1,000.
Source: Audit Office of New South Wales analysis of council credit card registers, policies and procedures 2020; staff numbers from Office of Local Government's 'Your Council' website, except for Junee Shire Council which comes from their Workforce Plan 2020–24.

While it is important for councils to have an established credit card management framework, it is equally important that they ensure compliance in practice. This chapter examines councils' credit card management practices – how well staff members were complying with policies and procedures, and how effective their credit card controls were. The chapter is structured to cover:

  • preventative controls (embedded in the issuance, use and cancellation of cards) that prevent fraud and misuse
  • detective controls (embedded in reconciliation and record keeping) that assist in detecting fraud and misuse.

Where ineffective credit card management practices are identified, councils should reflect on whether they need to more closely monitor compliance, or whether there are fundamental deficiencies in their policies and procedures that need to be refined.

Dubbo Regional Council had gaps in its credit card policy and procedures. It allowed cardholders to share their credit card with other staff members, which complicated credit card management, increased the risk of misuse and fraud, and breached its agreement with the credit card issuer. The council's reconciliation of credit card transactions needs to be enhanced to ensure it can review compliance with policy and detect potential misuse or fraud.

Dubbo Regional Council had 77 credit cards at the time of the audit. The council's policy on credit card sharing violated its agreement with the card issuer that each credit card should be for the respective cardholder's use only. Credit card sharing also increases the risk of misuse and fraud.

The council's credit card policy and procedures lacked clarity in several areas. The eligibility criteria were broad and there was a risk of inconsistency in granting approvals, especially since the council gave approval delegations to multiple senior staff members. The policy and procedures also lacked guidance on the reconciliation of the general manager's credit card and the management of Cabcharge.

The audit identified gaps in the council's credit card management practices. While the council had a clear policy on financial delegations, there was no evidence that credit card limits were monitored in line with financial delegations. The credit card register contained inaccurate information, and the council was also unable to provide records of certain transactions requested for review by the audit.

The council's credit card reconciliation process needs to be enhanced to enable detection of potential misuse or fraud. It did not include compliance checks or reviewing the business-related purpose of transactions. Purchases of restricted items such as fuel, meals and entertainment were not accompanied by evidence of need or exemption. Travel expenses were not checked against travel pre-approval forms. The audit also identified instances of split transactions. The council provided no evidence of the finance team's involvement in the reconciliation of credit card transactions.

Senior management oversight of credit card use was lacking, as the council did not produce reports on credit card use. There was also no evidence that the internal auditor had undertaken monitoring activities as required in the credit card policy.

Recommendations

Dubbo Regional Council should immediately:

1. amend its credit card policy to prevent cardholders from sharing their credit card with other staff.

By December 2020, Dubbo Regional Council should:

2. clarify in the credit card policy and procedures:

  • eligibility criteria for a credit card
  • reconciliation arrangements for the general manager’s credit card
  • Cabcharge management policy and procedures

3. ensure that credit card management practices include:

  • monitoring credit card limits in line with financial delegations
  • considering the use of credit card blocks
  • keeping the credit card register are up-to-date, accurate and complete
  • maintaining complete and accurate records

4. ensure reconciliation involves:

  • scrutinising business-related purposes and incident details of transactions
  • keeping a record of the finance team's review of transactions
  • reviewing transactions against travel pre-approval forms (where applicable)
  • recording vehicle details and mileage when credit cards are used in place of fuel cards
  • checking that there are no split transactions

5. ensure there is ongoing senior management oversight of credit card use

6. ensure the internal auditor undertakes monitoring activities as specified in the credit card policy.

 

Junee Shire Council had gaps in its credit card policy and procedures. The council's reconciliation of credit card transactions needs to be enhanced to ensure it can review compliance with policy and detect potential misuse or fraud.

Junee Shire Council had only one credit card, held by the general manager, at the time of the audit. Staff members could seek approval from the general manager to purchase using the credit card. This raises concerns of credit card sharing, which would be a violation of the council's agreement with its credit card issuer. Credit card sharing also increases the risk of misuse and fraud.

The council had fuel cards and store cards for use by staff members. However, its credit card policy and procedures did not cover the management of these types of cards. The lack of documented rules and guidance increases the risk of misuse and fraud.

The audit identified other gaps in the council's credit card management practices:

  • the credit card limit was not monitored in line with financial delegation
  • there was a lack of targeted guidance for the approver (the mayor) in reconciliation
  • the council was unable to provide records of certain transactions requested for review by the audit
  • the council did not review its credit card policy according to schedule.

The council's credit card reconciliation process needs to be enhanced to enable detection of potential misuse or fraud. It did not include reviewing the business-related purpose of transactions. The council also provided no evidence of the finance team's involvement in the reconciliation of credit card transactions.

As the cardholder, the general manager reviewed all transactions every month. As the approver, the mayor (or deputy mayor) had to sign off on these transactions. Hence, there was sufficient management oversight of the council's credit card use. However, there was a lack of periodic review of the council's credit card use, as it was not included in the council's forward program of internal audits.

Recommendations

Junee Shire Council should immediately:

1. amend its credit card policy to prevent cardholders from sharing their credit card with other staff.

By December 2020, Junee Shire Council should:

2. clarify in the credit card policy and procedures:

  • fuel card management policy and procedures
  • store card management policy and procedures

3. ensure that credit card management practices include:

  • monitoring credit card limits in line with financial delegations
  • considering the use of credit card blocks
  • providing approvers with targeted guidance
  • maintaining complete and accurate records

4. ensure reconciliation involves:

  • scrutinising business-related purposes and incident details of transactions
  • keeping a record of the finance team's review of transactions
  • checking travel pre-approval forms (where applicable)
  • recording vehicle details and mileage when credit cards are used in place of fuel cards
  • checking that there are no split transactions

5. develop a plan for periodic reviews (e.g. internal audit) of credit card use and management

6. ensure its credit card policy and procedures are reviewed according to schedule.

 

Lane Cove Council had gaps in its credit card policy and procedures. The council's reconciliation of credit card transactions needs to be enhanced to ensure it can review compliance with policy and detect potential misuse or fraud.

Lane Cove Council had six credit cards, held by the most senior staff members, at the time of the audit. During our interviews, cardholders advised that they had shared their credit card with reporting staff. Credit card sharing is a violation of the council's agreement with its credit card issuer, and it also increases the risk of misuse and fraud.

The council's credit card policy lacked clarity in several areas. While the general manager had delegation to authorise the issue of credit cards, the policy did not specify any eligibility criteria. The policy and procedures also lacked guidance on the reconciliation of the general manager's credit card and the management of fuel cards and store cards.

The audit identified gaps in the council's credit card management practices. There was no evidence that credit card limits were monitored in line with financial delegations. The credit card register contained inaccurate information, and the council was also unable to provide records of certain transactions requested for review by the audit.

The council's credit card reconciliation process needs to be enhanced to enable detection of potential misuse or fraud. The process also did not include compliance checks or reviewing the business-related purpose of transactions. Purchases of restricted items such as fuel and fine payments were not accompanied by adequate justification. There was a lack of targeted guidance for approvers in reconciliation, and the council only evidenced the finance team's involvement in an administrative capacity (i.e. entering data into the journals).

Senior management oversight of credit card use was lacking. Although the credit card policy referred to management reporting, the council had not been producing such reports at the time of the audit. Management reporting was implemented in December 2019 following our discussions. There was a lack of periodic review of the council's credit card use, as it was not included in the council's forward program of internal audits.

The council has adopted a new Management Directive in January 2020, which has clarified the eligibility criteria for credit cards.

Recommendations

Lane Cove Council should immediately:

1. amend its credit card policy to prevent cardholders from sharing their credit card with other staff.

By December 2020, Lane Cove Council should:

2. clarify in the credit card policy and procedures:

  • reconciliation arrangements for the general manager’s credit card
  • fuel card management policy and procedures
  • store card management policy and procedures

3. ensure that credit card management practices include:

  • monitoring credit card limits in line with financial delegations
  • considering the use of credit card blocks
  • providing approvers with targeted guidance
  • keeping the credit card register up-to-date, accurate and complete
  • maintaining complete and accurate records

4. ensure reconciliation involves:

  • scrutinising business-related purposes and incident details of transactions
  • keeping a record of the finance team's review of transactions
  • checking travel pre-approval forms (where applicable)
  • recording vehicle details and mileage when credit cards are used in place of fuel cards

5. develop a plan for periodic reviews (e.g. internal audit) of credit card use and management.

 

Nambucca Valley Council had gaps in its credit card policy and procedures. The council's reconciliation of credit card transactions needs to be enhanced to ensure it can review compliance with policy and detect potential misuse or fraud.

Nambucca Valley Council had 37 credit cards at the time of the audit. During our interviews, cardholders described instances of credit card sharing within the council. Credit card sharing is a violation of the council's agreement with its credit card issuer, and it also increases the risk of misuse and fraud.

The council's credit card policy lacked clarity in several areas. While the general manager had delegation to authorise the issue of credit cards, the policy did not specify any eligibility criteria. The policy and procedures lacked guidance on the management of fuel cards, store cards and Cabcharge. The policy also lacked coverage of the reconciliation arrangements for the general manager's credit card as the general manager did not hold a credit card. While the policy did not preclude the mayor and the general manager from holding a credit card, both opted not to do so.

The audit identified gaps in the council's credit card management practices. There was no evidence that credit card limits were monitored in line with financial delegations. The credit card register contained inaccurate information, and there was insufficient control in handling staff departures, as the audit identified one incident where a credit card was returned after the staff member's last day.

The council's credit card reconciliation process needs to be enhanced to enable detection of potential misuse or fraud. The process also did not include adequate compliance checks or reviewing the business-related purpose of transactions. Purchases of restricted items such as fuel and the use of third-party travel websites were not accompanied by adequate justification. Travel expenses were not checked against travel pre-approval forms. The audit also identified instances of split transactions.

Senior management oversight of credit card use was insufficient, as the council had been producing reports for only one manager for his department at the time of the audit. Management reporting for the Chief Finance Officer was implemented following our discussions. There was a lack of periodic review of the council's credit card use, as it was not included in the council's forward program of internal audits.

The audit acknowledges that the council had revised its credit card procedures following our discussions to address our preliminary findings. The council has also set additional credit card blocks in response to this audit. The recommendations below contain only the outstanding items.

Recommendations

Nambucca Valley Council should immediately:

1. ensure cardholders stop sharing their credit card with other staff.

By December 2020, Nambucca Valley Council should:

2. clarify in the credit card policy and procedures:

  • reconciliation arrangements for the general manager’s credit card (should the policy continue to allow the general manager to have one)
  • fuel card management policy and procedures

3. ensure that credit card management practices include:

  • monitoring credit card limits in line with financial delegations
  • keeping the credit card register up-to-date, accurate and complete

4. ensure reconciliation involves:

  • scrutinising business-related purposes and incident details of transactions
  • checking travel pre-approval forms (where applicable)
  • recording vehicle details and mileage when credit cards are used in place of fuel cards
  • checking that there are no split transactions

5. develop a plan for periodic reviews (e.g. internal audit) of credit card use and management.

 

Penrith City Council had gaps in its credit card policy and procedures. The council's reconciliation of credit card transactions needs to be enhanced to ensure it can review compliance with policy and detect potential misuse or fraud.

Penrith City Council had 167 credit cards at the time of the audit. During our interviews, cardholders described instances of credit card sharing within the council. Credit card sharing is a violation of the council's agreement with its credit card issuer, and it also increases the risk of misuse and fraud.

The audit identified gaps in the council's credit card policy and procedures. There was no documented arrangement for the reconciliation of the general manager's credit card. There was also no guidance on the management of Cabcharge. The credit card register contained inaccurate information, and the council was also unable to provide records of certain transactions requested for review by the audit.

The council's credit card reconciliation process needs to be enhanced to enable detection of potential misuse or fraud. The process did not include adequate compliance checks or reviewing the business-related purpose of transactions. The council's policy required prior approval for conferences, accommodation or meal expenses. However, there was no evidence that such approvals were checked during credit card reconciliation. The audit also identified instances of split transactions.

The council implemented monthly reporting for managers in July 2019.

There was a lack of periodic review of the council's credit card use, as it was not included in the council's forward program of internal audits.

Recommendations

Penrith City Council should immediately:

1. ensure cardholders stop sharing their credit card with other staff.

By December 2020, Penrith City Council should:

2. clarify in the credit card policy and procedures

  • reconciliation arrangements for the general manager’s credit card
  • Cabcharge management policy and procedures

3. ensure that credit card management practices include:

  • considering the use of credit card blocks
  • keeping the credit card register up-to-date, accurate and complete
  • maintaining complete and accurate records

4. ensure reconciliation involves:

  • scrutinising business-related purposes and incident details of transactions
  • keeping a record of the finance team's review of transactions
  • checking travel pre-approval forms (where applicable)
  • recording vehicle details and mileage when credit cards are used in place of fuel cards
  • checking that there are no split transactions

5. develop a plan for periodic reviews (e.g. internal audit) of credit card use and management.

 

Shellharbour City Council had gaps in its credit card policy and procedures. The council's reconciliation of credit card transactions needs to be enhanced to ensure it can review compliance with policy and detect potential misuse or fraud.

Shellharbour City Council had 65 credit cards at the time of the audit. During our interviews, cardholders described instances of credit card sharing within the council. Credit card sharing is a violation of the council's agreement with its credit card issuer, and it also increases the risk of misuse and fraud.

The council's credit card policy lacked clarity in several areas. While the general manager had delegation to authorise the issue of credit cards, the policy did not specify any eligibility criteria. The council did not align credit card limits with financial delegations, and while blocking codes were used, there was no explanation in the policy or procedures. Although the mayor and general manager's credit card transactions were reviewed during the council's monthly Executive Leadership Team meetings, the policy and procedures lacked guidance on the reconciliation of their credit cards. The council also did not have sufficiently detailed documentation for the management of fuel cards.

The audit identified gaps in the council's credit card management practices:

  • The council's training material had not been updated following the review of its credit card policy and procedures.
  • The credit card register contained inaccurate information.
  • The council was unable to provide records of certain transactions requested for review by the audit.
  • The council did not review its credit card policy according to schedule.

The council's credit card reconciliation process needs to be enhanced to enable detection of potential misuse or fraud. The process did not include compliance checks or reviewing the business-related purpose of transactions. Purchases of restricted items, such as fuel and fine payments, were not accompanied by adequate justification. The audit identified instances of split transactions, and travel or conference approval forms were also not checked during reconciliation. There was a lack of targeted guidance for approvers in reconciliation, and the council also provided no evidence of the finance team's involvement in the reconciliation of credit card transactions.

The council's Executive Leadership Team was involved in the monthly review of credit card transactions, hence there was management oversight of credit card use. However, there was a lack of periodic review of the council's credit card use, as it was not included in the council's forward program of internal audits.

Recommendations

Shellharbour City Council should immediately:

1. ensure cardholders stop sharing their credit card with other staff.

By December 2020, Shellharbour City Council should:

2. clarify in the credit card policy and procedures:

  • eligibility criteria for a credit card
  • the use of blocking codes
  • reconciliation arrangements for the general manager’s credit card
  • fuel card management policy and procedures (with more details)

3. ensure that credit card management practices include:

  • monitoring credit card limits in line with financial delegations
  • providing approvers with targeted guidance
  • keeping the credit card register up-to-date, accurate and complete
  • maintaining complete and accurate records
  • updating the training material to reflect the latest policy and procedures

4. ensure reconciliation involves:

  • scrutinising business-related purposes and incident details of transactions
  • keeping a record of the finance team's review of transactions
  • checking travel pre-approval forms (where applicable)
  • recording vehicle details and mileage when credit cards are used in place of fuel cards
  • ensuring no split transactions

5. develop a plan for periodic reviews (e.g. internal audit) of credit card use and management

6. ensure its credit card policy and procedures are reviewed according to schedule.

Appendix one – Responses from councils and the Department of Planning, Industry and Environment

Appendix two – About the audit

Appendix three – Performance auditing

 

Copyright notice

© Copyright reserved by the Audit Office of New South Wales. All rights reserved. No part of this publication may be reproduced without prior consent of the Audit Office of New South Wales. The Audit Office does not accept responsibility for loss or damage suffered by any person acting on or refraining from action as a result of any of this material.

Parliamentary reference - Report number #340 - released 3 September 2020

Published

Actions for Integrity of data in the Births, Deaths and Marriages Register

Integrity of data in the Births, Deaths and Marriages Register

Justice
Premier and Cabinet
Whole of Government
Cyber security
Fraud
Information technology
Internal controls and governance
Management and administration

This report outlines whether the Department of Customer Service (the department) has effective controls in place to ensure the integrity of data in the Births, Deaths and Marriages Register (the register), and to prevent unauthorised access and misuse.

The audit found that the department has processes in place to ensure that the information entered in the register is accurate and that any changes to it are validated. Although there are controls in place to prevent and detect unauthorised access to, and activity in the register, there were significant gaps in these controls. Addressing these gaps is necessary to ensure the integrity of information in the register.

The Auditor-General made nine recommendations to the department, aimed at strengthening controls to prevent and detect unauthorised access to, and activity in the register. These included increased monitoring of individuals who have access to the register and strengthening security controls around the databases that contain the information in the register.

The NSW Registry of Births Deaths and Marriages is responsible for maintaining registers of births, deaths and marriages in New South Wales as well as registering adoptions, changes of names, changes of sex and relationships. Maintaining the integrity of this information is important as it is used to confirm people’s identity and unauthorised access to it can lead to fraud or identity theft.

Read full report (PDF)

The NSW Registry of Births Deaths and Marriages (BD&M) is responsible for maintaining registers of births, deaths and marriages in New South Wales. BD&M is also responsible for registering adoptions, changes of name, changes of sex and relationships. These records are collectively referred to as 'the Register'. The Births, Deaths and Marriages Registration Act 1995 (the BD&M Act) makes the Registrar (the head of BD&M) responsible for maintaining the integrity of the Register and preventing fraud associated with the Register. Maintaining the integrity of the information held in the Register is important as it is used to confirm people's identity. Unauthorised access to, or misuse of the information in the Register can lead to fraud or identity theft. For these reasons it is important that there are sufficient controls in place to protect the information.

BD&M staff access, add to and amend the Register through the LifeLink application. While BD&M is part of the Department of Customer Service, the Department of Communities and Justice (DCJ) manages the databases that contain the Register and sit behind LifeLink and is responsible for the security of these databases.

This audit assessed whether BD&M has effective controls in place to ensure the integrity of data in the Births, Deaths and Marriages Register, and to prevent unauthorised access and misuse. It addressed the following:

  • Are relevant process and IT controls in place and effective to ensure the integrity of data in the Register and the authenticity of records and documents?
  • Are security controls in place and effective to prevent unauthorised access to, and modification of, data in the Register?

Conclusion

BD&M has processes and controls in place to ensure that the information entered in the Register is accurate and that amendments to the Register are validated. BD&M also has controls in place to prevent and detect unauthorised access to, and activity in the Register. However, there are significant gaps in these controls. Addressing these gaps is necessary to ensure the integrity of the information in the Register.

BD&M has detailed procedures for all registrations and amendments to the Register, which include processes for entering, assessing and checking the validity and adequacy of source documents. Where BD&M staff have directly input all the data and for amendments to the Register, a second person is required to check all information that has been input before an event can be registered or an amendment can be made. BD&M carries out regular internal audits of all registration processes to check whether procedures are being followed and to address non-compliance where required.

BD&M authorises access to the Register and carries out regular access reviews to ensure that users are current and have the appropriate level of access. There are audit trails of all user activity, but BD&M does not routinely monitor these. At the time of the audit, BD&M also did not monitor activity by privileged users who could make unauthorised changes to the Register. Not monitoring this activity created a risk that unauthorised activity in the Register would not be detected.

BD&M has no direct oversight of the database environment which houses the Register and relies on DCJ's management of a third-party vendor to provide the assurance it needs over database security. The vendor operates an Information Security Management System that complies with international standards, but neither BD&M nor DCJ has undertaken independent assurance of the effectiveness of the vendor's IT controls.

Appendix one – Response from agency

Appendix two – About the audit

Appendix three – Performance auditing

 

Copyright notice

© Copyright reserved by the Audit Office of New South Wales. All rights reserved. No part of this publication may be reproduced without prior consent of the Audit Office of New South Wales. The Audit Office does not accept responsibility for loss or damage suffered by any person acting on or refraining from action as a result of any of this material.

 

Parliamentary reference - Report number #330 - released 7 April 2020.

Published

Actions for Report on Local Government 2019

Report on Local Government 2019

Local Government
Asset valuation
Cyber security
Financial reporting
Information technology
Infrastructure
Internal controls and governance
Management and administration
Procurement
Project management
Service delivery
Shared services and collaboration
Workforce and capability

I am pleased to present my third report to the Parliament on the 2019 audits of local government councils in New South Wales.

This report notes that unqualified audit opinions were issued on the 2018–19 financial statements of 134 councils and 11 joint organisations. The opinion for one council was disclaimed and three audits are yet to complete.

The report also highlights improvements I have seen in financial reporting and governance arrangements across councils. Fewer errors were identified. More councils have audit, risk and improvement committees and internal audit functions. Risk management practices, including fraud control systems, have also improved.

These are very pleasing indicators of the gradual strengthening of governance and financial oversight of the sector. I want to acknowledge the investment councils have made in working with the Audit Office to improve consistency of practice and accountability generally.

Of course there is more work to do, particularly to prepare for new accounting standards and to strengthen controls over information technology and cyber security management. Asset management practices can also be improved. This report provides some guidance to council on these matters and we will continue to partner with the Office of Local Government in the Department of Planning, Industry and Environment to support good practice.

Margaret Crawford

Auditor-General
5 March 2020

This report focuses on key observations and findings from the 2018–19 financial audits of councils and joint organisations.

Unqualified audit opinions were issued on the financial statements for 134 councils and 11 joint organisations. The audit opinion for Bayside’s 2017–18 and 2018–19 financial statements were disclaimed. Three audits are still in progress and will be included in next year’s report.

The report highlights a number of areas where there has been improvement. There was a reduction in errors identified in council financial statements and high risk issues reported in audit management letters. More councils have audit, risk and improvement committees and internal audit functions. Risk management practices and fraud control systems have also improved.

The report also found that councils could do more to be better prepared for the new accounting standards, asset management practices could be strengthened, and information technology controls and cyber security management could be improved.

The Auditor-General recommended that the Office of Local Government within the Department of Planning, Industry and Environment develop a cyber security policy by 30 June 2021 to ensure a consistent response to cyber security risks across councils.

Read the PDF Report

Financial reporting is an important element of good governance. Confidence in and transparency of public sector decision making is enhanced when financial reporting is accurate and timely. Strong financial performance provides the platform for councils to deliver services and respond to community needs.

This chapter outlines our audit observations on the financial reporting and performance of councils and joint organisations.

Section highlights
  • There was a reduction in the number and dollar value of errors identified in councils' financial statements.
  • We continue to identify prior period errors, which are predominantly asset-related.
  • Unqualified audit opinions were issued for 99 per cent of completed audits for councils and joint organisations.
  • Three audits remain outstanding, with the outcomes to be reported in next year's Report to Parliament.
  • Seventy-nine per cent of councils and joint organisations lodged their financial reports by 31 October 2019.
  • Councils that performed some early reporting procedures achieved better outcomes in terms of the quality and timeliness of financial reporting.
  • Councils are at various levels of preparedness to implement the new accounting standards for the 2019–20 financial year. Some have made the necessary modifications to systems and processes, but others are still assessing impacts.
  • Most councils met the prescribed benchmarks for the liquidity and working capital performance measures over the past three years.
  • More councils reported negative operating performance compared with the prior year, meaning their operating expenditure exceeded their operating revenue.

Strong governance systems and internal controls help councils to operate effectively and efficiently, produce reliable financial reports, comply with laws and regulations and support ethical government.

This chapter outlines the overall trends related to governance and internal control issues across councils and joint organisations for 2018–19.

Section highlights
  • While the total number of issues reported in our management letters increased compared with the prior year, the total number of high risk issues have decreased. Of the high-risk issues, 41 per cent were deficiencies in information technology controls.
  • More councils have established audit, risk and improvement committees and internal audit functions.
  • Councils have improved risk management practices, with over 75 per cent of councils now having a risk management policy and register.
  • While most councils have policies and processes to manage gifts and benefits, we identified some instances of non-compliance with the Model Code of Conduct.
  • Most councils have policies and processes to manage the use of credit cards.
  • Councils can strengthen policies and practices for managing fraud controls and legislative compliance.
  • There are further opportunities for councils to improve internal controls over revenue, purchasing, payroll, cash, financial accounting and governance processes.

Councils rely on information technology (IT) to deliver services and manage information. While IT delivers considerable benefits, it also presents risks that council needs to address.

In prior years, we reported that councils need to improve IT governance and controls to manage key financial systems. This chapter outlines the progress made by councils in the management of key IT risks and controls, with an added focus on cyber security.

Section highlights
  • We continue to report deficiencies in information technology controls, particularly around user access management. These controls are key to ensuring IT systems are protected from inappropriate access and misuse.
  • Many councils do not have IT policies and procedures and others do not identify, monitor or report on IT risks.
  • Cyber security management requires improvement, with some basic elements of governance not yet in place for many councils.

Councils are responsible for managing a significant range of assets to deliver services on behalf of the community.

This chapter outlines our asset management observations across councils and joint organisations.

Section highlights
  • There was an increase in the total number of issues reported in our management letters for asset management processes.
  • There were less high-risk issues reported compared to the previous year.
  • We continue to identify discrepancies between the council's Crown land asset records and the Crown Land Information Database (CLID) managed by the former Department of Industry (DOI).
  • Inconsistent practices remain across the Local Government sector in accounting for landfill sites.

Appendix one – Response from the Office of Local Government within the Department of Planning, Industry and Environment

Appendix two – Status of 2018 recommendations

Appendix three – Status of audits 

 

Copyright notice

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Published

Actions for Education 2018

Education 2018

Education
Asset valuation
Financial reporting
Information technology
Infrastructure
Service delivery
Shared services and collaboration
Workforce and capability

The Auditor-General for New South Wales, Margaret Crawford, released her report today on the results of the financial audits of agencies in the Education cluster. The report focuses on key observations and findings from the most recent financial audits of these agencies. 'I am pleased to report that unqualified audit opinions were issued on the financial statements of both agencies in the Education cluster', the Auditor-General said. Statements were submitted and audited within statutory deadlines.

This report analyses the results of our audits of financial statements of the Education cluster for the year ended 30 June 2018. The table below summarises our key observations.

This report provides parliament and other users of the Education cluster’s financial statements with the results of our audits, our observations, analysis, conclusions and recommendations in the following areas:

  • financial reporting
  • audit observations
  • service delivery.

Financial reporting is an important element of good governance. Confidence and transparency in public sector decision making are enhanced when financial reporting is accurate and timely.

This chapter outlines our audit observations related to the financial reporting of agencies in the Education cluster for 2017–18.

Observation Conclusions and recommendations
2.1 Quality of financial reporting
Unqualified audit opinions were issued on the financial statements of both cluster agencies. Sufficient audit evidence was obtained to conclude the financial statements were free of material misstatement.
2.2 Timeliness of financial reporting
Both cluster agencies met the statutory deadlines for completing early close procedures and submitting financial statements. Early close procedures continue to facilitate the timely preparation of cluster agencies’ financial statements and completion of audits, but scope exists to improve outcomes by resolving issues and supplying supporting documentation earlier.
2.3 Key issues from financial audits
Inconsistencies in the Department’s annual leave and long service leave data, identified over the past three audits, remain unresolved. This issue impacts the Department’s liability estimates for annual leave and long service leave, including associated on-costs. It also on-flows to the Crown Entity, which assumes the Department's liability for long service leave. Recommendation: The Department should confirm leave data and review assumptions following deployment of the new HR/Payroll system to better estimate the liability for employee benefits and the amount to be assumed by the Crown Entity.
2.4 Key financial information
Cluster agencies recorded net deficits in 2017–18.

The Department recorded a net deficit of $30.7 million in 2017–18 against a budgeted surplus of $122 million.

The NSW Education Standards Authority recorded a net deficit of $4.1 million against a budgeted deficit of $4.7 million.

Appropriate financial controls help ensure the efficient and effective use of resources and administration of agency policies. They are essential for quality and timely decision making.

This chapter outlines our observations and insights from:

  • our financial statement audits of agencies in the Education cluster for 2018
  • the areas of focus identified in the Audit Office work program.

The Audit Office Annual Work Program provides a summary of all audits to be conducted within the proposed time period as well as detailed information on the areas of focus for each of the NSW Government clusters.

Observation Conclusions and recommendations
3.1  Internal controls
Twenty internal control deficiencies were identified during our audits of cluster agencies. We assessed one as a high risk finding.  
Eight internal control weaknesses were repeat issues from previous financial audits that had not been fully addressed by management. Recommendation: Management should prioritise and action recommendations to address internal control weaknesses.
3.2 Information technology
Delivery of the Learning Management and Business Reform (LMBR) program is complete.

The LMBR program has been a major project for the Department since it was established in 2006.

A staged approach was adopted for implementing the Department’s new HR/Payroll system to manage the risks associated with this large-scale roll-out.

3.3 Valuation of the Department’s land and buildings
The Department completed a revaluation of land and building assets during 2017–18.

A market approach was used to revalue the Department’s land, resulting in a revaluation increment of $2.3 billion.

A current replacement cost approach was used to revalue the Department’s school buildings, resulting in an increment of $6.2 billion.

3.4 Maintenance of school facilities
The Department regularly assesses the condition of school buildings and uses Life Cycle Costing to predict maintenance and capital renewal, and to prioritise maintenance activities. The Life Cycle Costing assessment conducted by the Department in 2017–18 rated 70 per cent of school buildings as being in either as new or good condition. No school buildings were rated as being in end-of-life condition.
3.4 School asset delivery
The Department’s School Assets Strategic Plan is designed to ensure that there are sufficient fit-for-purpose places for students up to 2031. The Department created a new division, School Infrastructure NSW, to oversee the planning, supply and maintenance of schools and implement major school infrastructure projects.

This chapter provides service delivery outcomes for the Education cluster for 2017–18. It provides important contextual information about the cluster's operation, but the data on achievement of these outcomes is not audited. The Audit Office does not have a specific mandate to audit performance information.

Published

Actions for Family and Community Services 2018

Family and Community Services 2018

Community Services
Compliance
Financial reporting
Information technology
Management and administration
Project management
Risk
Service delivery
Workforce and capability

The Auditor-General for New South Wales, Margaret Crawford released her report today on the Family and Community Services cluster. The report focuses on key observations and findings from the most recent financial audits of agencies in the cluster. Cluster entities received unqualified audit opinions for their 30 June 2018 financial statements. Opportunities to improve the quality of financial reporting were identified and reported to management.

This report analyses the results of our audits of financial statements of the Family and Community Services cluster for the year ended 30 June 2018. The table below summarises our key observations.

This report provides NSW Parliament and other users of the financial statements of Family and Community Services' agencies with the results of our audits, our observations, analysis, conclusions and recommendations in the following areas:

  • financial reporting
  • audit observations
  • service delivery.

Financial reporting is an important element of good governance. Confidence and transparency in public sector decision making are enhanced when financial reporting is accurate and timely.

This chapter outlines our audit observations related to the financial reporting of agencies in the Family and Community Services cluster for 2018.

Observation Conclusions and recommendations
2.1 Quality of financial reporting
Unqualified audit opinions were issued for all cluster agencies' financial statements. Conclusion: Sufficient audit evidence was obtained to conclude the financial statements were free of material misstatement.
Agencies complied with NSW Treasury’s mandatory early close requirements.

Completing other early close procedures was inconsistent and not always supported by adequate evidence.
Conclusion: There are opportunities for agencies to improve the quality of financial reporting by:
  • documenting all significant judgements and assumptions used when preparing the financial statements
  • regularly reconciling inter-agency balances and transactions
  • reconciling key account balances on a timely basis
  • quantifying the impact of new and revised accounting standards.
2.2 Timeliness of financial reporting
Agencies completed revaluations of property, plant and equipment and submitted 31 March 2018 financial statements by the due date as required by NSW Treasury.

Agencies submitted year-end financial statements by the statutory deadline.
Conclusion: Early revaluations of property, plant and equipment contributes to agencies meeting the year-end statutory reporting deadline.

Appropriate financial controls help ensure the efficient and effective use of resources and administration of agency policies. They are essential for quality and timely decision making.

This chapter outlines our observations and insights from:

  • our financial statement audits of agencies in the Family and Community Services cluster for 2018
  • the areas of focus identified in the Audit Office annual work program.

The Audit Office Annual Work Program provides a summary of all audits to be conducted within the proposed time period as well as detailed information on the areas of focus for each NSW Government cluster.

Observation Conclusions and recommendations
3.1 Internal controls
The 2017–18 audits reported 47 internal control weaknesses. While none were high risk, there were 15 repeat issues.

Conclusion: Management accepted audit findings and advised they are actioning recommendations. Timely action is important to ensure internal controls operate effectively.

Twenty-two of these internal control weaknesses related to information technology processes and control environment. Conclusion: Control weaknesses in information systems may compromise the integrity and security of financial data used for decision making and financial reporting.

Recommendation: Agencies should strengthen user access administration to prevent inappropriate access to key IT systems by:
  • ensuring privileged user access is limited to those requiring access to maintain the IT systems
  • monitoring privileged user access to address risks from unauthorised activity
  • ensuring IT password settings comply with password policies
  • ensuring timely removal of access to business systems for terminated and casual employees.
The Department, NSW Land and Housing Corporation (LAHC) and three other cluster agencies’ contract registers are incomplete and/or inaccurate. Recommendation: Agencies should ensure their contract registers are complete and accurate so they can more effectively govern contracts and manage compliance obligations.
3.2 Audit Office annual work program
Financial impact of the commissioning approach.

The transfer of disability services to the National Disability Insurance Scheme and other commissioning of service delivery has contributed to a 36 per cent decrease in frontline employee numbers since 2015–16. Similarly, corporate services’ employee numbers reduced by 34 per cent.

The Department’s salary costs have reduced by $232 million or 18 per cent from 2016–17.
Conclusion: The ratio of corporate services employee numbers to support frontline and support services has remained at 1:10 since 2015–16, which indicates restructures have been planned to align with the transfer of disability services.
Impact of the new social housing maintenance contract

Maintenance expenses have increased by about 40 per cent since the new maintenance contract commenced in April 2016. LAHC measures the benefits of the new maintenance contract such as improved tenant satisfaction.
Conclusion: The new maintenance contract has contributed to some positive social outcomes such as tenants being employed by the contractors to conduct maintenance, as call centre operators and in administration. However, more can be done to ensure value for money is being achieved.
ChildStory IT Project

Whilst phase one of the ChildStory IT project went 'live' in 2017–18, the planned timetable has not been met and the revised date for full implementation is end of 2018.

According to the 2014–15 NSW Budget, the budget for ChildStory was $100 million over a four-year period. During the design and implementation stage, this amount was revised to $128 million, with approval of the Expenditure Review Committee. The actual cost incurred over the four years until 30 June 2018, is approximately $131 million.

We identified issues with the data migration from the legacy systems to ChildStory.
Conclusion: To inform future IT projects, we understand the Department is capturing our findings, along with the findings from the Department of Finance, Services and Innovation’s ‘Healthchecks’.

This chapter outlines certain service delivery outcomes for 2017–18. The data on activity levels and performance is provided by Cluster agencies. The Audit Office does not have a specific mandate to audit performance information. Accordingly, the information in this chapter is unaudited.

In our recent performance audit, Progress and measurement of Premier's Priorities, we identified 12 limitations of performance measurement and performance data. We recommended that the Department of Premier and Cabinet ensure that processes to check and verify data are in place for all agency data sources.

Published

Actions for Central Agencies 2018

Central Agencies 2018

Treasury
Premier and Cabinet
Finance
Financial reporting
Internal controls and governance
Management and administration
Risk

The Auditor-General for New South Wales, Margaret Crawford, released her report today on the results of the financial audits of NSW Government central agencies. The report focuses on key observations and findings from the most recent financial statement audits of agencies in the Treasury, Premier and Cabinet, and Finance, Services and Innovation clusters. While clear audit opinions were issued on all agency financial statements, the report notes that some complex accounting requirements caused significant errors in agency financial statements submitted for audit, which were corrected before the financial statements were approved. 

This report analyses the results of our audits of the Treasury, Premier and Cabinet and Finance, Services and Innovation cluster agencies for the year ended 30 June 2018. The table below summarises our key observations.

This report provides parliament and other users of the NSW Government's central agencies and their cluster agencies financial statements with the results of our audits, our observations, analysis, conclusions and recommendations in the following areas:

  • financial reporting
  • audit observations
  • liquidity risk management
  • government financial services.

The central agencies and their key responsibilities are set out below.

Central agencies Key central agency responsibilities Cluster responsibilities
The Treasury
  • Financial and economic advisor to NSW Government
  • Manages the NSW Government’s financial resources.

The cluster:

  • provides investment and debt management services though TCorp
  • manages residual business arising from privatisation of government businesses
  • provides insurance and compensation cover, including workers compensation insurance
  • includes NSW Government superannuation funds.
Department of Premier and Cabinet
  • Drives NSW Government’s objectives and sets targets
  • Works with clusters to coordinate policy and achieve NSW Government priorities.

The cluster:

  • includes integrity agencies, such as the Independent Commission Against Corruption, Audit Office of NSW and Ombudsman’s Office
  • other agencies, such as Barangaroo Delivery Authority and Infrastructure NSW.
Department of Finance, Services and Innovation
  • Supports agency service delivery in relation to the key enabling functions of NSW Government, including procurement, property and asset management, ICT and digital innovation.

The cluster:

  • is responsible for state revenue and rental bond administration
  • regulates statutory insurance schemes, workplace safety and consumer protection
  • provides access to a range of NSW Government services via Service NSW
  • manages the NSW Government communications network.
Public Service Commission
  • Works to promote and maintain a strong ethical culture across the government sector and improve the capabilities, performance and configuration of the sector’s workforce to deliver better services to the public.
  • The Public Service Commission is an independent agency within the Premier and Cabinet cluster.

Note: The Audit Office of NSW is an independent agency included in the Premier and Cabinet cluster for administrative purposes, but not commented on in this report.


A full list of agencies that this report covers by relevant cluster is included in Appendix three.

Financial reporting is an important element of good governance. Confidence and transparency in public sector decision making are enhanced when financial reporting is accurate and timely.

This chapter outlines our audit observations related to the financial reporting of agencies in the Treasury, Premier and Cabinet and Finance, Services and Innovation clusters for 2018.

Observation Conclusions and recommendations
2.1 Quality of financial reporting
Unqualified opinions were issued for all agencies' financial statements submitted to the Audit Office.

Complex accounting requirements caused significant errors in some agency financial statements, which were corrected before the financial statements were approved.
Sufficient audit evidence was obtained to conclude the financial statements were free of material misstatement.
Recommendation: Agencies should respond to key accounting issues when they are identified by preparing accounting papers and engaging with Treasury, the Audit Office and their Audit and Risk Committee when these matters are identified.
2.2 Timeliness of financial reporting
Most agencies complied with the statutory timeframe for completion of early close procedures, 48 agencies in the Treasury cluster did not comply with the statutory requirement to prepare financial statements, and the audits of nine agencies in the Treasury cluster were not completed within the statutory timeframe.
All financial statement information of the 48 agencies that did not prepare financial statements has been captured in the consolidated financial statements of their parent entity, which was subject to audit.
Early close procedures allow financial reporting issues and risks to be addressed early in the audit process. The timeliness of financial reporting can be improved by performing more robust early close procedures.

Appropriate financial controls help ensure the efficient and effective use of resources and administration of agency policies. They are essential for quality and timely decision making.

This chapter outlines our observations and insights from:

  • our financial statement audits of agencies in the Treasury, Premier and Cabinet and Finance, Services and Innovation cluster for 2018
  • the areas of focus identified in the Audit Office work program.

The Audit Office work program provides a summary of all audits to be conducted within the proposed time period as well as detailed information on the areas of focus for each of the NSW Government clusters.

Observation Conclusions and recommendations
3.1 Internal controls
The 2017–18 audits found one high risk issue and 83 moderate risk issues across the agencies. Nineteen per cent of all issues were repeat issues. Agencies should focus on rectifying repeat issues.
The high risk issue at Service NSW related to several deficiencies in procurement and contract management processes. Service NSW may not be achieving value-for-money
from their procurement and contract management activities. The high risk issue should be rectified as a matter of priority. This includes updating and implementing its procurement, vendor and contract management frameworks and delivering training to key staff involved in procurement and contract management activities.
Property NSW has implemented several controls during the year to rectify the high risk issue identified last year related to its transition to a new property and facility management service provider. However, the service providers performance remains below expectations and there are further opportunities to improve oversight and lift performance. Property NSW can better define roles and accountabilities with the service provider and formalise policies and processes associated with its monitoring and oversight of the service provider.

Implementing relevant KPIs, receiving timely reports and providing timely review and feedback to the service provider may help to lift performance.
GovConnect received unqualified opinions from their service auditor on all business process controls, except for information technology controls provided by Unisys, where a qualified opinion was received from the service auditor. A qualified opinion was received because of several deficiencies in user access controls. These internal control deficiencies increase the risk of unauthorised access to key business systems, and increase audit effort and costs associated with addressing the risks arising from the deficiencies.
3.2 Audit Office annual work program

Remediation of the Barangaroo site is now estimated to cost the Barangaroo Delivery Authority in excess of net $400 million.
 
The increase in the estimate over the last five years is mainly due to the extent of remediation required, as more evidence of contamination has become known.

Measuring the remaining costs to remediate requires the use of estimation techniques and judgements, making the actual outcome inherently uncertain. We reviewed evidence to support the provision for remediation, including future costs estimates and this evidence supported management’s estimate.
The State Insurance Regulatory Authority have administered the refund of $138 million in Green slip refunds to policy holders through Service NSW during 2017–18. At 30 June 2018, $112 million in refunds are yet to be claimed.
 
We reviewed the systems and processes supporting the refund process. While we found that this supports the disbursement of refunds to policyholders there were some deficiencies in Service NSW’s project controls when the program was being developed.

 
Service NSW should apply the lessons learnt from this program to other programs it is delivering or will be delivering for agencies.
Revenue NSW recorded $30.4 billion from taxes, fines and fees in 2017–18 ($30.0 billion in 2016–17) to support the State’s finances. 
 
Crown revenue has steadily increased over the last five years predominately driven by rises in payroll tax and land tax and responsibility for collection of the Emergency Services Levy transferring to Revenue NSW under the Emergency Services Levy Act 2017 effective from July 2017. 
3.3 Managing maintenance
Place Management NSW manages significant commercial and retail leases and maintains public domain spaces and other assets around the harbour foreshore. It has consistently underspent its asset maintenance budget. In 2017–18, asset maintenance expenses were only 34 per cent of budgeted maintenance expense.

Currently, Place Management NSW does not use any ratios or benchmarks to determine the adequacy of its maintenance spend or to monitor whether it is achieving its budgeted maintenance program. 
This may be contributing to a high proportion of unplanned maintenance, which Place Management NSW reports was 38 per cent of total maintenance expense in 2017–18.

Place Management NSW is outsourcing its property and facilities management function from 1 December 2018 to an external service provider. 
 

This chapter outlines our audit observations, conclusions and recommendations specific to NSW Government agencies providing financial services.

Observation Conclusions and recommendation
5.1 Superannuation funds
The SAS Trustee Corporation (STC) Pooled Fund and the Parliamentary Contributory Superannuation (PCS) Fund are not required to comply with the prudential and reporting standards issued by the Australian Prudential Regulation Authority (APRA). 
However, legislation allows the responsible Minister to prescribe prudential standards, reporting and audit requirements. 
Structured and comprehensive prudential oversight of these Funds is important as they operate in a volatile financial sector, have 103,000 members and manage investments of $43.3 billion.
Recommendation: Treasury should consult with the Trustees of the STC Pooled Fund and PCS Fund to prescribe appropriate prudential standards and requirements, including oversight arrangements.
5.2 Insurance and compensation
Nominal Insurer and NSW Self Insurance Corporation investment performance marginally exceeded benchmark over the past five years. Investment returns can impact on the premiums required to maintain an adequate funding ratio in addition to other factors such as claims experience and discount rates.
The Workers Compensation Nominal Insurer (Nominal Insurer) and NSW Self Insurance Corporation's net collected premiums and contributions decreased over the past five years.  The insurance schemes' investment performance and stable claim payments have enabled less reliance on net collected premiums and contributions as a source of funding, over the past five years. 
Reforms were introduced to manage the Home Warranty Scheme's financial sustainability risks.  The Home Warranty Scheme has not collected sufficient premiums to fund expected claims costs, since commencing operations in 2011. In 2017–18, the Crown contributed $181 million for historical shortfalls. New reforms started on 1 January 2018 enabling the Scheme to price premiums based on risk. 

Published

Actions for Internal Controls and Governance 2018

Internal Controls and Governance 2018

Education
Community Services
Finance
Health
Industry
Justice
Planning
Premier and Cabinet
Transport
Treasury
Whole of Government
Environment
Compliance
Cyber security
Financial reporting
Fraud
Information technology
Internal controls and governance
Management and administration
Procurement
Project management

The Auditor-General for New South Wales Margaret Crawford found that as NSW state government agencies’ digital footprint increases they need to do more to address new and emerging information technology (IT) risks. This is one of the key findings to emerge from the second stand-alone report on internal controls and governance of the 40 largest NSW state government agencies.

This report analyses the internal controls and governance of the 40 largest agencies in the NSW public sector for the year ended 30 June 2018.

This report covers the findings and recommendations from our 2017–18 financial audits that relate to internal controls and governance at the 40 largest agencies (refer to Appendix three) in the NSW public sector.

This report offers insights into internal controls and governance in the NSW public sector

This is our second report dedicated to internal controls and governance at NSW State Government agencies. The report provides insights into the effectiveness of controls and governance processes in the NSW public sector by:

  • highlighting the potential risks posed by weaknesses in controls and governance processes
  • helping agencies benchmark the adequacy of their processes against their peers
  • focusing on new and emerging risks, and the internal controls and governance processes that might address those risks.

Without strong governance systems and internal controls, agencies increase the risks associated with effectively managing their finances and delivering services to citizens. The way agencies deliver services increasingly relies on contracts and partnerships with the private sector. Many of these arrangements deliver front line services, but others provide less visible back office support. For example, an agency may rely on an IT service provider to manage a key system used to provide services to the community. The contract and service level agreements are only truly effective where they are actively managed to reduce risks to continuous quality service delivery, such as interruptions caused by system outages, cyber security attacks and data security breaches.

Our audits do not review all aspects of internal controls and governance every year. We select a range of measures, and report on those that present heightened risks for agencies to mitigate. This report divides these into the following five areas:

  1. Internal control trends
  2. Information technology (IT), including IT vendor management
  3. Transparency and performance reporting
  4. Management of purchasing cards and taxis
  5. Fraud and corruption control.

The findings in this report should not be used to draw conclusions on the effectiveness of individual agency control environments and governance arrangements. Specific financial reporting, controls and service delivery comments are included in the individual 2018 cluster financial audit reports, which will be tabled in Parliament from November to December 2018.

The focus of the report has changed since last year

Last year's report topics included asset management, ethics and conduct, and risk management. We are reporting on new topics this year. We plan to introduce new topics and re-visit our previous topics in subsequent reports on a cyclical basis. This will provide a baseline against which to measure the NSW public sectors’ progress in implementing appropriate internal controls and governance processes to mitigate existing, new and emerging risks in the public sector.

Agencies selected for the volume account for 95 per cent of the state's expenditure

While we have covered only 40 agencies in this report, those selected are a large enough group to identify common issues and insights. They represent about 95 per cent of total expenditure for all NSW public sector agencies.

Internal controls are processes, policies and procedures that help agencies to:

  • operate effectively and efficiently
  • produce reliable financial reports
  • comply with laws and regulations
  • support ethical government.

This chapter outlines the overall trends for agency controls and governance issues, including the number of findings, level of risk and the most common deficiencies we found across agencies. The rest of this volume presents this year’s controls and governance findings in more detail.

Observation Conclusions and recommendations
2.1 High risk findings
We found six high risk findings (seven in 2016–17), one of which was repeated from both last year and 2015–16. Recommendation: Agencies should reduce risk by addressing high risk internal control deficiencies as a priority.
2.2 Common findings
We found several internal controls and governance findings common to multiple agencies. Conclusion: Central agencies or the lead agency in a cluster can play a lead role in helping ensure agency responses to common findings are consistent, timely, efficient and effective.
2.3 New and repeat findings
Although internal control deficiencies decreased over the last four years, this year has seen a 42 per cent increase in internal control deficiencies. The increase in new IT control deficiencies and repeat IT control deficiencies signifies an emerging risk for agencies.
IT control deficiencies feature in this increase, having risen by 63 per cent since last year. The number of repeat IT control deficiencies has doubled and is driven by the increasing digital footprint left by agencies as government prioritises on-line interfaces with citizens, and the number of transactions conducted through digital channels increases

Recommendation: Agencies should reduce IT risks by:

  • assigning ownership of recommendations to address IT control deficiencies, with timeframes and actions plans for implementation
  • ensuring audit and risk committees and agency management regularly monitor the implementation status of recommendations.

 

Government agencies’ financial reporting is now heavily reliant on information technology (IT). IT is also increasingly important to the delivery of agency services. These systems often provide the data to help monitor the efficiency and effectiveness of agency processes and services they deliver. Our audits reviewed whether agencies have effective controls in place to manage both key financial systems and IT service contracts.

Observation Conclusions and recommendations
3.1 Management of IT vendors
Contract management framework 
Although 87 per cent of agencies have a contract management policy to manage IT vendors, one fifth require review.
 

Conclusion: Agencies can more effectively manage IT vendor contracts by developing policies and procedures to ensure vendor management frameworks are kept up to date, plans are in place to manage vendor performance and risk, and compliance with the framework is monitored by:

  • internal audit focusing on key contracting activities
  • experienced officers who are independent of contract administration performing spot checks or peer reviews
  • targeted analysis of data in contract registers.
Contract risk management
Forty-one per cent of agencies are not using contract management plans and do not assess contract risks. Half of the agencies that did assess contract risks, had not updated the risk assessments since the commencement of the contract.
 
Conclusion: Instead of applying a 'set and forget' approach in relation to management of contract risks, agencies should assess risk regularly and develop a plan to actively manage identified risks throughout the contract lifecycle - from negotiation and commencement, to termination.

Performance management
Eighty-six per cent of agencies meet with vendors to discuss performance. 

Only 24 per cent of agencies sought assurance about the accuracy of vendor reporting against KPIs, yet sixty-seven per cent of the IT contracts allow agencies to determine performance based payments and/or penalise underperformance.

Conclusion: Agencies are monitoring IT vendor performance, but could improve outcomes and more effectively manage under-performance by:

  • a more active, rigorous approach to both risk and performance management
  • checking the accuracy of vendor reporting against those KPIs and where appropriate seeking assurance over their accuracy
  • invoking performance based payments clauses in contracts when performance falls below agreed standards.

Transitioning services
Forty-three per cent of the IT vendor contracts did not contain transitioning-out provisions.

Where IT vendor contracts do make provision for transitioning-out, only 28 per cent of agencies have developed a transitioning-out plan with their IT vendor.

Conclusion: Contract transition/phase out clauses and plans can mitigate risks to service disruption, ensure internal controls remain in place, avoid unnecessary costs and reduce the risk of 'vendor lock-in'.
Contract Registers
Eleven out of forty agencies did not have a contract register, or have registers that are not accurate and/or complete.

Conclusion: A contract register helps to manage an agency’s compliance obligations under the Government Information (Public Access) Act 2009 (the GIPA Act). However, it also helps agencies more effectively manage IT vendors by:

  • monitoring contract end dates and contract extensions, and commence new procurements through their central procurement teams in a timely manner
  • managing their contractual commitments, budgeting and cash flow requirements.

Recommendation: Agencies should ensure their contract registers are complete and accurate so they can more effectively govern contracts and manage compliance obligations.

3.2 IT general controls
Governance
Ninety-five per cent of agencies have established policies to manage key IT processes and functions within the agency, with ten per cent of those due for review.
 
Conclusion: Regular review of IT policies ensures risks are considered and appropriate strategies and procedures are implemented to manage these risks on a consistent basis. An absence of policies can lead to ad-hoc responses to risks, and failure to consider emerging IT risks and changes to agency IT environments. 

User access administration
Seventy-two deficiencies were identified related to user access administration, including:

  • thirty issues related to granting user access across 43 per cent of agencies
  • sixteen issues related to removing user access across 30 per cent of agencies
  • twenty-six issues related to periodic reviews of user access across 50 per cent of agencies.
Recommendation: Agencies should strengthen the administration of user access to prevent inappropriate access to key systems.
Privileged access
Forty per cent of agencies do not periodically review logs of the activities of privileged users to identify suspicious or unauthorised activities.

Recommendation: Agencies should:

  • review the number of, and access granted to privileged users, and assess and document the risks associated with their activities
  • monitor user access to address risks from unauthorised activity.
Password controls
Twenty-three per cent of agencies did not comply with their own policy on password parameters.
Recommendation: Agencies should ensure IT password settings comply with their password policies.
Program changes
Fifteen per cent of agencies had deficient IT program change controls mainly related to segregation of duties and authorisation and testing of IT program changes prior to deployment.
Recommendation: Agencies should maintain appropriate segregation of duties in their IT functions and test system changes before they are deployed.

 

This chapter outlines our audit observations, conclusions and recommendations from our review of how agencies reported their performance in their 2016–17 annual reports. The Annual Reports (Statutory Bodies) Regulation 2015 and Annual Reports (Departments) Regulation 2015 (annual reports regulation) currently prescribes the minimum requirements for agency annual reports.

Observation Conclusion or recommendation
4.1 Reporting on performance

Only 57 per cent of agencies linked reporting on performance to their strategic objectives.

The use of targets and reporting performance over time was limited and applied inconsistently.

Conclusion: There is significant disparity in the quality and consistency of how agencies report on their performance in their annual reports. This limits the reliability and transparency of reported performance information.

Agencies could improve performance reporting by clearly linking strategic objectives to reported outcomes, and reporting on performance against targets over time. NSW Treasury may need to provide more guidance to agencies to support consistent and high-quality performance reporting in annual reports.

There is no independent assurance that the performance metrics agencies report in their annual reports are accurate.

Prior performance audits have noted issues related to the collection of performance information. For example, our 2016 Report on Red Tape Reduction highlighted inaccuracies in how the dollar-value of red tape reduction had been reported.

Conclusion: The ability of Parliament and the public to rely on reported information as a relevant and accurate reflection of an agency's performance is limited.

The relevance and accuracy of performance information is enhanced when:

  • policies and guidance support the consistent and accurate collection of data
  • internal review processes and management oversight are effective
  • independent review processes are established to provide effective challenge to the assumptions, judgements and methodology used to collect the reported performance information.
4.2 Reporting on reports

Agency reporting on major projects does not meet the requirements of the annual reports regulation.

Forty-seven per cent of agencies did not report on costs to date and estimated completion dates for major works in progress. Of the 47 per cent of agencies that reported on major works, only one agency reported detail about significant cost overruns, delays, amendments, deferments or cancellations.

NSW Treasury produce an annual report checklist to help agencies comply with their annual report obligations.

Recommendation: Agencies should comply with the annual reports regulation and report on all mandatory fields, including significant cost overruns and delays, for their major works in progress.

The information the annual reports regulation requires agencies to report deals only with major works in progress. There is no requirement to report on completed works.

Sixteen of 30 agencies reported some information on completed major works.

Conclusion: Agencies could improve their transparency if they reported, or were required to report:

  • on both works in progress and projects completed during the year
  • actual costs and completion dates, and forecast completion dates for major works, against original and revised budgets and original expected completion dates
  • explanations for significant cost overruns, delays and key project performance metrics.

 

This chapter outlines our audit observations, conclusions and recommendations, arising from our review of agency preventative and detective controls over purchasing card and taxi use for 2017–18.

Observation Conclusion or recommendation
5.1 Management of purchasing cards
Volume of credit card spend
Purchasing card expenditure has increased by 76 per cent over the last four years in response to a government review into the cost savings possible from using purchasing cards for low value, high volume procurement.
 
Conclusion: The increasing use of purchasing cards highlights the importance of an effective framework for the use and management of purchasing cards.
Policy framework
We found all agencies that held purchasing cards had a policy in place, but 26 per cent of agencies have not reviewed their purchasing card policy by the scheduled date, or do not have a scheduled revision date stated within their policy.
Recommendation: Agencies should mitigate the risks associated with increased purchasing card use by ensuring policies and purchasing card frameworks remain current and compliant with the core requirements of TPP 17–09 'Use and Management of NSW Government Purchasing Cards'.
Preventative controls
We found that:
  • all agencies maintained purchasing card registers
  • seventy-six per cent provided training to cardholders prior to being issued with a card
  • eighty-nine per cent appointed a program administrator, but only half of these had clearly defined roles and responsibilities
  • thirty-two per cent of agencies place merchant blocks on purchasing cards
  • forty-seven per cent of agencies place geographic restrictions on purchasing cards.

Agencies have designed and implemented preventative controls aimed at deterring the potential misuse of purchasing cards.

Conclusion: Further opportunities exist for agencies to better control the use of purchasing cards, such as:

  • updating purchasing card registers to contain all mandatory fields required by TPP17–09
  • appointing a program administrator for the agency's purchasing card framework and defining their role and responsibility for the function
  • strengthening preventive controls to prevent misuse.

Detective controls
Ninety-two per cent of agencies have designed and implemented at least one control to monitor purchasing card activity.

Major reviews, such as data analytics (29 per cent of agencies) and independent spot checks (49 per cent of agencies) are not widely used.

Agencies have designed and implemented detective controls aimed at identifying potential misuse of purchasing cards.

Conclusion: More effective monitoring using purchasing card data can provide better visibility over spending activity and can be used to:

  • detect misuse and investigate exceptions
  • analyse trends to highlight cost saving opportunities.
5.2 Management of taxis
Policy framework
Thirteen per cent of agencies have not developed and implemented a policy to manage taxi use. In addition:
  • a further 41 per cent of agencies have not reviewed their policies by the scheduled revision date, or do not have a scheduled revision date
  • more than half of all agencies’ policies do not offer alternative travel options. For example, only 36 per cent of policies promoted the use of general Opal cards.
Conclusion: Agencies can promote savings and provide more options to staff where their taxi use policies:
  • limit the circumstances where taxi use is appropriate
  • offer alternate, lower cost options to using taxis, such as general Opal cards and rideshare.
Detective controls
All agencies approve taxi expenditure by expense reimbursement, purchasing card and Cabcharge, and have implemented controls around this approval process. However, beyond this there is minimal monitoring and review activity, such as data monitoring, independent spot checks or internal audit reviews.
Conclusion: Taxi spend at agencies is not significant in terms of its dollar value, but it is significant from a probity perspective. Agencies can better address the probity risk by incorporating taxi use into a broader purchasing card or fraud monitoring program.

 

Fraud and corruption control is one of the 17 key elements of our governance lighthouse. Recent reports from ICAC into state agencies and local government councils highlight the need for effective fraud control and ethical frameworks. Effective frameworks can help protect an agency from events that risk serious reputational damage and financial loss.

Our 2016 Fraud Survey found the NSW Government agencies we surveyed reported 1,077 frauds over the three year period to 30 June 2015. For those frauds where an estimate of losses was made, the reported value exceeded $10.0 million. The report also highlighted that the full extent of fraud in the NSW public sector could be higher than reported because:

  • unreported frauds in organisations can be almost three times the number of reported frauds
  • our 2015 survey did not include all NSW public sector agencies, nor did it include any NSW universities or local councils
  • fraud committed by citizens such as fare evasion and fraudulent state tax self-assessments was not within the scope of our 2015 survey
  • agencies did not estimate a value for 599 of the 1,077 (56 per cent) reported frauds.

Commissioning and outsourcing of services to the private sector and the advancement of digital technology are changing the fraud and corruption risks agencies face. Fraud risk assessments should be updated regularly and in particular where there are changes in agency business models. NSW Treasury Circular TC18-02 NSW Fraud and Corruption Control Policy now requires agencies develop, implement and maintain a fraud and corruption control framework, effective from 1 July 2018. 

Our Fraud Control Improvement Kit provides guidance and practical advice to help organisations implement an effective fraud control framework. The kit is divided into ten attributes. Three key attributes have been assessed below; prevention, detection and notification systems.

This chapter outlines our audit observations, conclusions and recommendations, arising from our review of agency fraud and corruption controls for 2017–18.

Observation Conclusion or recommendation
6.1 Prevention systems

Prevention systems
Ninety-two per cent of agencies have a fraud control plan in place, 81 per cent maintain a fraud database and 79 per cent report fraud and corruption matters as a standing item on audit and risk committee agendas.

Only 54 per cent of agencies have an employment screening policy and all agencies have IT security policies, but gaps in IT security controls could undermine their policies.

Conclusion: Most agencies have implemented fraud prevention systems to reduce the risk of fraud. However poor IT security along with other gaps in agency prevention systems, such as employment screening practices heightens the risk of fraud and inappropriate use of data.

Agencies can improve their fraud prevention systems by:

  • completing regular fraud risk assessments, embedding fraud risk assessment into their enterprise risk management process and reporting the results of the assessment to the audit and risk committee
  • maintaining a fraud database and reviewing it regularly for systemic issues and reporting a redacted version of the database on the agency's website to inform corruption prevention networks
  • developing policies and procedures for employee screening and benchmarking their current processes against ICAC's publication ‘Strengthening Employment Screening Practices in the NSW Public Sector’
  • developing and maintaining up to date IT security policies and monitoring compliance with the policy.
Twenty-three per cent of agencies were not performing fraud risk assessments and some agency fraud risk assessments may not be as robust as they could be.  Conclusion: Agencies' systems of internal controls may be less effective where new and emerging fraud risks have been overlooked, or known weaknesses have not been rectified.
6.2 Detection systems
Detection systems
Several agencies reported they were developing a data monitoring program, but only 38 per cent of agencies had already implemented a program.
 

Studies have shown data monitoring, whereby entire populations of transactional data are analysed for indicators of fraudulent activity, is one of the most effective methods of early detection. Early detection decreases the duration a fraud remains undetected thereby limiting the extent of losses.

Conclusion: Data monitoring is an effective tool for early detection of fraud and is more effective when informed by a comprehensive fraud risk assessment.

6.3 Notification systems
Notification system
All agencies have notification systems for reporting actual or suspected fraud and corruption. Most agencies provide multiple reporting lines, provide training and publicise options for staff to report actual or suspected fraud and corruption.
Conclusion: Training staff about their obligations and the use of fraud notification systems promotes a fraud-aware culture