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School governance, risk and control

20th March 2020

With the announcement that schools are to close with the exception of provision for key workers and vulnerable children, focus clearly has to be on the operational application of these directives.
 
It is important that while these critical issues are planned and put into play, trustees continue supporting their leaders, but without interfering and adding to the burden. Do not lose sight however that the purpose of your role, be that trustee or leader, does not change; flexibility will though potentially be required in how you continue to fulfil that role:
 

  • Support your leaders
  • Keep trustees and local governors in the loop with protocol as things develop
  • Your statutory requirement to challenge and keep oversight is still in place
  • As meetings move to the virtual world, any decisions made need to be legal, check your articles of association
  • Ensure a “virtual meetings” policy is in place as soon as possible
  • Maintain the cycle of meetings as far as possible to fulfil AFH requirements 
  • Life will return to normal at some point and your accountability will be considered
  • Ensure your information is up to date on GIAS  

 
Control of public money is crucial, particularly at times of crisis. Financial governance oversight and assurance is even more important in times where the usual systems and capacity are stretched.

Be careful with the operation of key controls over this time. More people remote working will mean payment authorisations, approval of new suppliers on the purchase ledger or for new members of staff on the payroll will by necessity increase over email or other remote means. This increases the risk of fraud (either internal or external/hacking) or indeed simple error. Again, our message is to maintain and where possible expand your usual scrutiny and diligence over the checking and confirming of such requests. 
 
Although there will no doubt be an apparent justification to set aside a number of existing controls / practices over the coming weeks simply to “get the job done” in response to dealing with unprecedented, challenging and frequently changing circumstances, it is important that key potential areas of risk are still properly mitigated. This intervening period carries heightened risks as more routine tasks may be deferred or missed altogether because of a shortage of staff, and the additional response required to the virus, not least with schools now required to change focus and operate as cover for children of local keyworkers.  Whilst the clear reality is that staff are going the extra mile in challenging circumstances, it is important that control frameworks are not allowed to weaken, and sufficient oversight is maintained over activity, risks and related controls/assurances to protect members of staff as well as the children in their care.
 
In simple terms, trusts should seek to:
a) maintain and operate existing control processes where possible;
b) be aware if (and why) they may need to temporarily depart from existing, established procedures, and where possible seek approval / segregation for these, even if it’s a second pair of eyes; and 
c) ensure that a log is maintained so that when life returns to normal, and departures can be reviewed and records updated as appropriate.
 
In so doing, overall effective governance oversight and assurance that key risks remain mitigated will be preserved, and staff protected whilst dealing with whatever the next few weeks will bring.

The DfE have produced guidance 25th March on governance practices within this challenging period.
 
If you need any guidance on what your obligations are, or are looking for support with advice on governance within this challenging period, please contact Alastair Campbell or Sally Timmins who will be able to help you.

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