Audit, Governance and Standards Committee


2 May 2019

(7:30 pm – 8:55 pm)


         Councillor Yogan Yoganathan (Chair)

         Councillor Kim Bailey (Vice Chair)


            Councillor Zain Abbas

            Councillor Rowena Bass

            Councillor Jaesung Ha



                        Independent Member - Paul Eardley




Declarations of Interest - None



Public Questions


The questions posed by Mr Derek Moss on the contracts associated with the Cambridge Road Estate regeneration project and the prevention of the participation of the non voting advisory member at debate of the Cambridge Road Estate ballot, are set out as an Annex and do not form part of these minutes.




23.         Minutes





The minutes of the meeting of the Committee held on 12 March 2019 were confirmed as a correct record.




24.         Annual Governance Statement Action Plan 2018/19


Appendix A



An update on progress to date against the Action Plan agreed in July 2018 to address the areas of improvement identified in the 2017/18 Annual Governance Statement was presented.


Of the 7 actions in the Plan, 2 are complete and the majority of the remainder are nearing completion. Any outstanding actions will be included within the Annual Governance Statement for 2018/19 which will be reported to Committee in July.


Resolved that progress against the Annual Governance Statement Action Plan (2017/18) set out in Annex 1 to the report is noted.





25.         Update on Fraud Work Undertaken 2018/19


Appendix B



As part of its work in maintaining an overview on the effectiveness of the arrangements for protecting the Council against fraud, the Committee received an update from Kevin Holland the Head of the South West London Fraud Partnership (SWLFP). This covered the work undertaken to date by the Partnership in 2018/19.


Priority areas of coverage for individual partner Councils are agreed through consultation with the Heads of Audit.  The Partnership has the ability to deploy flexible resources with knowledge and experience to provide coverage across a range of counter-fraud activities.


Work with social landlords with property within the SWLFP area through the Social Housing Investigation Partnership (SHIP) continues. This partnership working helps identify tenancy fraud and abuse resulting in the recovery of misused tenancies.  These can then be assigned to those in genuine eligible need thus reducing the call on providing temporary housing.


Over the year 244 fraud/abuse referrals have been investigated, compared to 276 in 2018/19.  96 remain open, 67 were closed without sanctions and 19 cases were closed with sanctions.

The number of referrals received reflects the effectiveness of the implementation of the Council’s Anti-Fraud and Anti-Corruption Strategy; the work done with front line teams and the training made available, on line and through workshops.  There is a reasonable level of general fraud awareness across all the Council’s departments. An online fraud awareness training package has been made available to all Kingston officers.  This links to the Council’s policies and procedure to increase awareness and understanding of fraud and how to report any suspicions of fraud or irregularity.

Categories of cases investigated and sanctions applied were illustrated in Tables 3 and 4. Closed cases and outcomes were summarised in Annex 1 of the report.

The main areas were tenancy fraud – a current fraud trend being tenancy succession rights - housing applications; right to buy applications, permits – parking, Blue Badge, Freedom pass – staff fraud, contractor/supplier fraud.

Savings to March 2019 from sanctions are £1.4m, this includes £180,000 on recovery of housing properties and £900,000 on Right to Buy discounts. A number of ongoing investigations/prosecutions pending will add to this.


Performance against Service Plan targets 2018/19 indicate all targets met.


Surveillance powers were used in 2 cases, one of which involved Blue Badge use.


Points raised by Members concerned the resourcing of the Fraud team and School Admissions fraud.

Whilst there has been a reduction in posts since 2016/17 the increased use of technology and access to intelligence sources and records means that the fraud response capability has been able to manage and address the increase in the number of fraud referrals.  On School Admissions, temporary residences have been uncovered and the Admissions team also deals with a number of cases which arise through complaints, where appropriate it raises these with the Fraud Team.


Resolved that the fraud work undertaken and performance results for 2018/19 are noted.





26.         London Counter Fraud Hub


Appendix C



A report on the proposed establishment of a London Counter Fraud Hub (LCFH) aimed at enhancing fraud prevention and detection through the application of smart data analytics and improved collaborative working was presented.

This included an indication of the additional resources needed to realise the benefits from being a member and additional information was provided in confidential background information.


Following a detailed specification and competitive procurement exercise, in December 2016 the LB Ealing let a nine-year contract (December 2016) to CIPFA to operate the hub.  A 2 year pilot has been carried out by the Camden, Croydon, Ealing and Islington... This suggests that if all 33 boroughs were to sign up, in the first year of operation London would save a net £15m (worst case) to £30m (best case) and recover around 1,500 council homes that are currently illegally sub-let.


The original funding came from a grant from the then Department for Communities and Local Government with the technology being funded by private sector risk capital.  The project remains of interest to the Cabinet Office and the now Ministry of Housing, Communities and Local Government as an opportunity to demonstrate data sharing and collaboration in London. 


The Hub has been developed to respond to the current and future threat of losses from fraud. The pilot focussed on three types of fraud perpetrated against councils: council tax single person discount fraud, business rates fraud, and council housing fraud.

For the Hub to be commercially viable needs 26 of the 33 Boroughs to join on an Invest to Save basis. The joining fee is £75,000 with an annual subscription of £70,000., the intention is that these costs could be offset against future fraud savings once realised. 


Councils would be committing to the remaining 7 years of the contract.  The form of contract does not contain a break clause and the contract terms are currently being reviewed by legal advisers to determine the strength of the safeguards within the contract and the exact form of the Key Performance Indicators.


Members raised a number of issues around the form of contract, absence of a break clause, options if less than 26 Boroughs commit and the robustness of the Hub model.  In noting that the acceptance of the contract falls within the powers delegated to the Director Contract and Commercial, the Committee asked that a further report be submitted to the next meeting on the contract terms.


Resolved that


1.             the report outlining the proposals for utilizing smart data analytics as a fraud prevention measure under the remit of the London Counter Fraud Hub (LCFH) is noted,


2.            it is noted that a decision on joining the LCFH will be subject to the Director Contract and Commercial’s satisfaction that the Key Performance Indicators currently being developed are suitable to protect the Council’s interests. 


3.            further details on the KPI’s and the form of the LCFH arrangement are reported to the next meeting.