Au Garda Siochziua Freedom of Information Of?ce An Garda Stochana, Athlumney House IDA Business Park ohnstown, Navan Oi?g Saort?tla Faisn?ise An Garda Siochana, Teach ath Luimnigh L?rionad Gno Udaras Forbartha Tionscail Baile Sheain An Uaimh Contae na Mi Co Meath C15 DR90 C15 DR90 Teileafonll" El: {046) 90363 50 Laithrean Gr?asainlWebsite: ww.gardn.ie Bl linntJoin us .a Riomh-phoist:lEmaii: follicugardaje Mr. Ken Forte keu@righttoknow.ie Re: Freedom of Information Request Request Partially Granted Dear Mr. Foxe, I refer to your request, dated 151 July 2017 and received on 3rd July, 201?, which you have made under the Freedom of Information Act (F01) 2014 for records held by An Gerda Siochana. Part 1(a) of Schedule 1 of the FOI Act states that An Garda Stochana is listed as a partially included agency "insofar as it relates to administrative records relating to human resources, or finance or procurement matters Therefore, only administrative records that relate to human resources, ?nance or procurement shall be considered. Your request, after clari?cation was provided, sought: Second Review A udit Dubi in North Central DMR Report to Commissioner in relation to Financial Controls 2016 Audit Report DMR West Division Review Audit Report DMR North Division Report to the Commissioner in relation to Financial Controls in 2015 Enrol-?LN?" I wish to inform you that have decided to partially gent your request on the 1??111 July 2017 with regard to part 2 of your request: Report to Commissioner in relation to Financial Controls 20! 6 The purpose of this letter is to explain my decision. gainmulo pl'uhncachla agus stand-eta a Ic muunn agus [acumcht na ndaomc or a l'o poll-cm; and securlt} 5UP. Ices the trim. con?dence and support of the people we acne 1. Findings, particulars and reasons for decision to deny access This audit report was requested from the Garda Internal Audit Section (GIAS). Part Schedule 1 - Out of Scepe In accordance with Part Schedule 1 of the FOI Act certain records or parts of records have been redacted as they do not come within the scope of the FOI Act insofar as An Garda Siochana is concerned. Part 1(a) of Schedule 1 of the FOI Act states that An Garda Siochana is listed as a partially included agency "insofar as it relates to administrative records relating to human resources, or finance or procurement matters". Therefore, only administrative records that relate to human resources, ?nance or procurement shall be considered. Records relating to operational matters such as general risk management frameworks or evidential property management are exempted as part of Part 1 Schedule 1 as these are neither considered administrative records (as set out in Office of the Information Commissioner: OIC case reference number 160276) or records relating to human resources, ?nance or procurement. The vast majority of this audit relates to the operational matters concerning property and evidence management thus the redaction is signi?cant as per Part] (11) of Schedule 1 of the FOI Act. 2. Right of Appeal In the event that you are not happy with this decision you may seek an Internal Review of the matter by writing to the address below and quoting reference number FBI-000292- 2017. Freedom of Information Of?ce, An Garda Stochana, Athlumney House, IDA Business Park, Johnstown, Navan, Co. Meath C15 DR90 Please note that a fee applies. This fee has been set at ?30 10 for a Medical Card holder). Payment should be made by way of bank draft, money order, postal order or personal cheque, and made payable to Accountant, Garcia Finance Directorate, Garda Headquarters, Phoenix Park, Dublin 8. Payment can be made by electronic means, using the following details: Account Name: Garda Siochana Finance Section Public Bank Account Account Number: 10026896 Sort Code: 900017 IBAN: IE86BOF190001710026896 BIC: BOFIIE2D You must ensure that your FOI reference number is included in the payment details. siuntlaln. :1 lL' ?hump :qus [nunucl?it 1::1 or in pr-nt'cwtunai [win-111:: and ?warm mm m? 11E: the tram con?dent-c and dipper! at the: people or You should submit your request for an Internal Review within 4 weeks from the date of this noti?cation. The review will involve a complete reconsideration of the matter by a more senior member of An Garcia Siochana and the decision will be communicated to you within 3 weeks. The making of a late appeal may be permitted in appropriate circumstances. Please be advised that An Garda Siochana replies under Freedom of Information may be released in to the public domain via our website at . Personal details in respect of your request have, where applicable, been removed to protect con?dentiality. Should you have any questions or concerns regarding the above, please contact me by telephone at (046) 9036350. Yours sincerely, . . SUPERINTENDENT HELEN FREEDOM OF INFORMATION OFFICER 20TH JULY 2017 '51;th :l mun-1m Hg?: lacamgm l'lit ndamnc {If Ll [u prutL-ssmxial policing and serum) sen Ices Ith the trust con?dence and u: peoplu dc Hum,- Requester Name: Mr. Ken Foxe File Re: - Repot to Comm. in Relation to Financial Controls 2016 Page No ?escription of Demuons Relevant Section of FOI Reason far denim" Personls} Objections document Acts Consulted YeslNo . . decision 1 Cover Sheet 0 l1l'E-i nla Granted 2 Table of Contents 2 Part 1(n) Schedule 1 Out of Scope Part-Grant 3 to 4 22:33:?? RISK 0 nla Granted Table 2 - Priority One 5 Recommendations 4 Part 1(n) Schedule 1 Out of Scope Part-Grant Oustanding to 9 4 Part 1(n) Schedule 1 Out of Scope Part-Grant Collaboration with 1D to 11 Gerda Professional 3 Part 1(n) Schedule 1 Out of Scope Part-Grant Standards Unit 12 Main Audit Findings 1 Part1(n) Schedule 1 Out of Scope Part-Grant 13 Main Audit Findings 0 nla nla Granted 14 Main Audit Findings 1 Part 1(n) Schedule 1 Out of Scope Refused 15 to 18 Main Audit Findings 3 Part 1(n) Schedule 1 Out of Scope Part-Grant 17 Main Audit Findings 0 nla nfa Granted 18 to 19 Conclusion Part1an Schedule 1 Out of Scope Part-Grant List of Audits 20 completed in 2016 l] nla nla Granted 21 to 22 Blank Sheets 0 nla rile Granted 23 List of Publications 0 nla nfa Granted Total number of pages 23 Total number of pages for full release 9 Total number of pages for partial release 13 Total number of pages being withheld 1 Report to the Garda Commissioner in relation to Financial Control in 2016 March 2017 Table of Contents Introduction 3 Work Completed 3 Risk Reduction 4 Value Added from Audit Process 6 Coilaboration with Garda Professional Standards Unit 9 Anti-Fraud Policy 11 Main Audit Findings 11 1. Financial Control Environment 11 2 Administrative Control and Management Reporting ll 3. Internal Audit 12 4 Signi?cant Issues Identi?ed from the Audit 13 4.1 Financial Controls in the Gerda College 13 4.2 Failure of the Risk Management Framework. . . . 3 4.3 Awareness of Public Financial Procedures 15 4.5 Recouprnent of Overpayments on Salary and Pensions 16 4.6 Procurement l? 4.7 Sick Absence Management and Staff Resource Allocation 17 Conclusion Appendix E: Audits Completed in 2016 and Quarter 20] 20 Gerda Internal Audit Section Introduction This Report documents issues identi?ed, or brought to the attention of lntemal Audit, during 2016 and the ?rst quarter in 2017, that are relevant to the Financial Control Framework in An Gerda Sioch?na. It will form part of the analysis informing the Commissioner in relation to whether she should sign the Statement of Internal Financial Controll in relation to Vote 20, An Gerda Siochana, Appropriation Account 2016. The opinions expressed in this Report are those of the Gerda Internal Audit Section (GIAS) in its role as an independent oversight of the ?nancial control framework within An Garda Stochana. Work Completed Fifteen audit reports were completed in 2016 and the ?rst quarter 2017 (see Appendix 1). See table below; Table 1 Audit Reports Completed Audit Reports Completed 2015 2016 Audits of DivisionsiDistricts/Specialist Units 7 5 Review Audits 4 6 Joint Audits with GPSU 1 Thematic Audits 1 2 Expenditure Reviews 0 0 Reports to Commissioner/Annual Report 1 1 Total I3 15 The Statement of Internal Financial Control is required as part of the implementation of the Mullarkey Report Department of Finance (2002). Seirhhisi gairmiula poilineachta agus slandala a sholathar Ie hiontaoibh, muinin agus tacaiocht na ndaoine ar abhfreastalaimid To deliver professional policing and security services with the trust, con?dence and support of the people we serve 3 Garda Internal Audit Section Approximately 79% of the Audit Plan 2016 recommended by the Audit Committee was completed. The remaining 21% of the plan could not be completed due to staff vacancies in GIAS, the unavailability of auditees and because priority areas identified during 2016 changed with consequential changes to audit priorities. The approved strength of GIAS is eleven staff but eight are currently assigned to the Section. In 2016, a Garda Inspector and Sergeant transferred from the Section and were replaced. The Professional Accountant position vacant for approximately six years was ?lled in October 2016. In addition considerable time was spent dealing with legal issues surrounding the Audit of the Garda College to ensure fair procedures were followed. Notwithstanding the foregoing, 1 am confident that the major high risk areas contained in the 2016 Audit Plan and emerging risks which overshadowed in terms of importance some of the original risks, have been examined and reported on. An Audit plan for 2017 has been drawn up which includes audits that could not be concluded in 2016. Risk Reduction lntemal Audit Reports have identi?ed and reported on risks to the ?nancial management and reputation of the Gerda Organisation. The reports classify the recommendations made as priorities 1 to 3. Priority one recommendations are those where both the impact of the control weaknesses on the operations of the organisation as a whole or on Divisionstnits within the Garda Organisation and the likelihood of occurrence is considered to be high. Priority one issues require immediate attention by management. There are currently 3? priority one recommendations from lntemal Audit Reports outstanding or not fully implemented. These can be broken down into the following general categories; Seirbhisi gairmi?la poilineachta agus slandala a sholathar ie hiontaoibh, mainin agus tacaiocht na ndaoine ar abh?-eastalaimid To deliver professional policing and security services with the trust, con?dence and support of the people we serve 4 Garda Internal Audit Section Table 2: Priority One Recommendations Outstanding; Category Number Resource Allocation and Absence Management 7 Procurement Procedures 4 Overpayments of Pay and Pension 4 Overtime and Allowances 1 Authorisation of Travel and Subsistence 1 Vehicle Records Fuel I Total 37 While 3? priority one recommendations remain to be resolved it should be noted that 15 other priority one recommendations were resolved or were revised to priority 2 or 3 during the last year on foot of management actions in relation to the recommendations from Internal Audit Reports. The outstanding recommendations are reported to each meeting of the Audit Committee. Review Audits are conducted within six months to one year after the original audit report has been concluded. in two Divisions in 2016 a second review audit was required because the issues were not resolved when examined at the ?rst review audit stage. [n this way risks are identi?ed, recommendations for improvement made and a review conducted in order to provide assurance that these risks are being managed appropriately. Seirbhisi gairmitila poilineachta agus sis?mdtila a shola'thar le hiontaoibh. muinin agus tacaiocht na ndaoine ar abhf'reastalaimid To deliver professional policing and security services with the trust con?dence and support of the people we serve 5 Gerda Internal Audit Section Value Added from Audit Process The recommendations from audits which have been veri?ed as implemented through the review audits conducted in 2016 contributed to a reduction in risk and an improvement in ?nancial control as follows: Seirbhisi gainnit'lla poilineachta agus sl?nd?la a shol?thar 1e. hiontaoihhl muinin agus tacaiooht na ndaoine at abhfreastalaimid To deliver professional policing and security services with the trust, con?dence and support ofthe people we serve 6 Garcia Internal Audit Section 2. Approximately 90% of the total Garda Vote relates to ?staff costs? (cg. basic pay, overtime, allowances and pensions). It is therefore essential that this expenditure is managed effectively and represents value for money. 'In line with the Policing Plan, and recommendations from the Gerda inspectorate Report {November 2015f, it is recommended that the maximum number of Gardai are assigned to high visibility policing duties with ?direct contact with the public?. Administrative roles should he undertaken by Civil Servants to the fullest extent possible to allow Gerda members to perform high visibility policing roles. During 2016, GIAS audited the deployment of Garcia Members at Gerda and Sergeant grades as part of the Divisional Audits. The table below combines the ?ndings from three Divisional Audits namely; I Wexford Cork West a DMR West Table 3: Resource Allocation (Sergeants 3: Ga rdai} on the day of the audit ?eld work Non Strength Pntrolling and Front Desk Roster Detective Gardai High Visibility Duties Specialist Duties Sergeant Policing Duties Total 435 102 37 195 23% 23% 9% 45% This demonstrates that only 45% of the Gardai and Sergeants on duty in these Divisions on the day of the audit were available for patrolling and high visibility policing. it is however acknowledged that some of the roles under the heading Non Roster Specialist Duties relate to vital policing roles with direct contact with the public Juvenile Liaison Offices}. Nonetheless all positions under the heading Non Roster Specialist Duties should be examined with role pro?les set out to determine the most appropriate skill set to carry 2 Gerda Stochana Inspectorate; November 2015; Changing Policing in Ireland. Seirblu?si gairmit'lla agus sltindtila a sholathar [e hiontaoibh, muinin agus tacaiocht na ndsoinc a: abhfreastajaimid To deliver professional policing and security services with the trust, con?dence and support oft?e people we serve 7 Garda Internal Audit Section out each specialist or administrative role. It is essential in line with the Policing Plan and the Garda Inspectorate Report that more uniformed staff are moved to the normal roster of patrolling, crime prevention and high visibility policing. It is unsatisfactory that administrative roles continue to be assigned to Garda Members that could more be undertaken by Civil Servants. This is partially as a result of Civil Service staff particularly at grades higher than Executive Of?cer not being available for deployment due to a lack of training and staff development for Civil Service staff over many years in An Garda Siochana. In recent weeks an Organisation Deployment Survey has been circulated to identify positions for civilianisation and deployment of Garda Members to policing roles. GIAS is of the view that this work to identify posts for redeployment should have been prioritised following the recommendations of the Garda Inspectorate Report (20] 5)3. Seirbhisi gainnit?zla poilineachta ages standala a sholathar le hiontaoibh, muinin ages na ndaoine ar abhfreastalaimid To deliver professional policing and security services with the trust, confidence and support of the people we serve 8 Garda Intemal Audit Section 4. In the course of Divisional Audits in 2016 issues relating to the procedures regarding long?term sick absences of members and staff were examined including policies and procedures to assist staff to return to work including ?light duties? and ?reduced hours?. Recommendations were made regarding the need for Local Management to liaise closely with the Garda Human Resources and People Development Directorate and the Occupational Health Service in relation to such cases and to continuously review cases where ?light duties? or ?reduced hours? have been recommended. 5. While much work has been done to enhance compliance with public procurement requirements leading to greater transparency, improved oversight, accountability and ef?ciency, GIAS found outstanding issues in regard to procurement in four Garda Divisions! Business Units and also in the Garda College. Collaboration with Garda Professional Standards Unit GIAS, as part of the overall governance and control environment within An Garda Siochana, provides reasonable audit assurance that signi?cant risks are identi?ed, managed and controlled effectiver throughout the Organisation. GPSU examines and reviews operational, administrative and management performance. GIAS and GPSU make recommendations and propose measures to enhance controls and improve performance. Both units have developed competences in certain areas of audit and examination. It is recognised that there is a overlap of responsibilities and roles between Garda Internal Audit Sectioo and Garda Professional Standards Unit. in some complex audits the skill set of both units is required working collaboratively. Seirbhisi gairmiula poilineachta agus slandala a sholathar le hiontaoibh, muinin agus tacaiocht na ndaoine ar abh?eastalaimid To deliver professional policing and securityI services with the trust, con?dence and support of the people we serve 9 Garda Internal Audit Section During 2016, a Joint Review Audit of the Serious Crime Review Team was completed by GIAS and GPSU. This review report recognises that substantial improvements that have been made in the Unit since the original audit and identifies no signi?cant de?cits or Organisational Risks. The Joint Review found the following: a Speci?c recommendations detailed in the SCRT Improvement Plan have been addressed by local management. I Compliance with Gerda Regulations, Code and Directives has improved. 0 Controls in place in SCRT were strengthened to prevent anomalies and illustrated overall improved supervision and management. 0 There was limited risk to the Garda Vote. 0 Given the speci?c specialist nature of the SCRT, the combined effect was an overall reduced risk to the reputation of An Garda Stochana. The two units continued in 2016 the work on the audit of the Special Crime Operations (formerly National Support Services} which encompasses audits of the following Units l. SCO Regional Of?ce, II. Garda National Economic Crime Bureau Garda Drugs and Organised Crime Bureau, IV. Garda National Immigration Bureau and V. Garda Technical Bureau. These audits have been completed and are awaiting management responses. Seirbhisi gainni?la poilineachta agus 51511an a sholathar 1e hiontanibh, muinin agus tacaiocht na ndaoine ar abhfreastalaimid To deliver professional policing and securityr services with the trust, con?dence and support of the people we serve 10 Garda Internal Audit Section Main Audit Findings 1. Financial Control Environment In general, An Garda Siochana has well developed systems for setting out ?nancial responsibilities and ?nancial reporting. These systems are documented in the Garda Finance Code and the Public Financial Procedures5 An Audit of Financial Controls in the Garda College conducted in 2016, found signi?cant control failure and issue of non- compliance with Public Financial Procedures (see below, 4 Signi?cant Audit Findings). The audit process has established with the exception of the Garda College that:6 5 Public Financial Procedures Department of Finance 5 Bullet points are taken from the Statement of internal Financial Control included in DPE Circular l7ll3 Section C. Seirbhisi gairmitila pollineachta agus slandala a sholathar le hiontaoibh, muinin agus tacaiocht na ndaoine ar ahhfreastalaimid To deliver professional policing and security services with the trust, con?dence and support of the people we serve l1 Gerda Internal Audit Section Financial responsibilities have been assigned at management level with corresponding accountability, Reporting arrangements have been established at all levels where responsibility for ?nancial management has been assigned, Formal procedures have been established for reporting signy?icant control failures and ensuring appropriate corrective action, 0 An Audit Committee was appointed in 2014 to advise the Accounting O?icer in discharging her responsibilities for the internal ?nancial control system. 2. Administrative Controls and Management Reporting A framework of administrative procedures and regular management reporting is in place including segregation of duties and a system of delegation of responsibility and accountability and in particular the audit process has established that: 0 There is an adequate budgeting system with an annual budget which is kept under review by senior management, II There are regular reviews by senior management of periodic and annual financial reports which indicate ?nancial performance against forecasts, - There are appropriate capital investment control guidelines and formal project management disciplines, II An Garda Siochana has systems and procedures to enable compliance with all relevant guidelines and circulars regarding procurement including a Central Procurement O?ce and Divisional Procurement Committees throughout the country. However difficulties, legal issues and delays in placing and replacing contract in some Divisions remain as highlighted in the four Divisions found not be complaint (free Page 7 point 5) The wording of this bullet point has been amended from that shown in DPE Circular 17ll3, Section 13, as full compliance cannot be claimed at this point in time. The wording shown more accurately re?ects the situation within An Garda Siochiina. Seirbhisi gairmirila pollineachta ages sl?ndala a sholathar le hiontaoibh, muinin agus tacaiocht na ndaoine er abhfreastalaimid To deliver professional policing and security services with the trust, con?dence and support of the people we serve 12 Garda Internal Audit Section 3. Internal Audit Garda Intemal Audit Section has appropriately trained staff operating under a Charter agreed with the Gerda Commissioner. Audit work informed by an analysis of the financial risks to which An Garcia Siochana is exposed and it?s Annual Audit Plan to approved by the Audit Committee and the Commissioner in 2016 is based on this analysis. The Internal Audit function is reviewed periodically by the Audit Committee and the Commissioner. Procedures are in place to ensure that the recommendations from the lntemal Audit Reports are implemented. An external review of in line with the requirements of the Professional Standards of the Chartered Institute of Internal Auditors was carried out by [(081 Corporation a ?rm of accountants and management consultants from Newry, Co Down. KOSI concluded that the Garda Internal Audit Service ?generally conforms to the De?nition of IA, the International Standards for the Professional Practice of Internal Auditing and the Code of Conduct and is wet! piaced to have a?trther positive impact on AGS. We have assigned GIAS with an overall adequate assurance level 4. Signi?cant issues identi?ed from the Audit Process 4.1 Financial Controls in the Garda College An audit of the Financial Controls in the Garda College could not provide assurance that the financial controls in operation at the Garda College are compliant with the Public Financial Procedures.' or the Garda Finance Code, and only limited assurance that the financial controls at the Garda College are compliant with Public Procurement Legislation? Recommendations of a Report written by the Finance Directorate in 2008 and instructions from the then Garcia Commissioner were not followed through. The issues may give rise to tax liability and tax experts are being engaged to advise as to whether a voluntary disclosure to the Revenue is required. Seirbhisi gairmit'lla poilineachta agus slandala a sholathar le hiontaoibh, muinin agus tacaiocht na ndaoinc ar abh?'eastalaimid To deliver professional poiicing and security services with the trust, con?dence and support of the people we serve 13 Gerda Internal Audit Section Seirbhisi gairmi?ia p?ilineachta agus sl?nd?la a shol?ths: 1e hiontaoibh, muinin agus tacaioeht na ndaoine at abhfreaslalaimid To deliver professional policing and security services with the trust, confidence and support of the people we serve 14 Garda Internal Audit Section In addition the Audit of Financial Controls in the Garda College found that signi?cant risks identified by the Finance Directorate in 2008, were not included in the Gerda College Risk Register, the Finance Directorate Risk Register or the Corporate Risk Register. 4.3 Awareness of Public Financial Procedures The basic framework of ?nancial procedures in Central Government Votes is contained in the Public Financial Procedures (2008) colloquially referred to as the Blue Book. This together with Department of Public Expenditure and Reform (DPER) Circulars and Guidance and Frameworks issued by Seirbhisi gairmi?la poilineachta agus slandala a sholatbar le hiontaoibh, muinr?n agus tacaiocht na ndaoine ar abh??eastalaimid To deliver professional policing and security services with the trust, con?dence and support of the people we serve l5 Garda Internal Audit Section Government Accounting Unit DPER comprise the main standard against which public bodies are required to maintain their accounting systems and against which the Of?ce of the Comptroller and Auditor General conduct their audits. The Garda Siochana Act 2005 placed the An Garda Siochana centrally within the central government ?nancial control structure when it made the Garda Commissioner the Accounting Of?cer for the Garda Voted expenditure and income. The Garda Finance Code contains most but not all of the requirements set out in the Public Financial Procedures and is an internal Financial Procedures Manual which was last revised in 2005 and amended since by the issue of HQ Directives. The Garda Finance Code is not the primary standard for ?nancial control. Despite this Garda staff perceive that the Garda Finance Code is the primary standard. The confusion relating to the status of the Garda Finance Code lead to management in the Garda College unwittingly ignoring some requirements of the Public Financial Procedures. 4.5 Recoupment of Overpayments on Salary and Pensions lnforrnation provided to from Gerda Human Resource and People Development show balances outstanding in relation to overpayments of Salary and Pensions at the at 30th June 2016 amounted to ?1,906,213 an increase of ?376,238 (or 25%) on the balance at the end of September 2015. The total increase in this ?gure from 31St March 2013 to 30th June 2016 is 8,291,742 or Seirbhisl gainnit?ila poilineachta agus slandala a shola?rthar le hiontaoibh, muinin agus tacaiocht na ndaoine ar abhfreastalajrnid To deliver professional policing and security services with the trust, con?dence and support of the people we serve 16 Garda Internal Audit Section an increase of 210%. GIAS attribute this increase to greater scrutiny resulting in more cases being discovered. Repayment plans were in place for 36% of the cases of overpayments at the end of 20l6. are concerned that adequate human resources are not being provided to the Recoupment Unit. It is not satisfactory that the Recoupment Unit set up as a result of the previous audit had dissipated to no staff from October 20I6 and one half-time member of staff at HBO level was provided a?er proposed that another review audit was required. It is essential that as a matter of urgency and until the balances have been reduced to a more acceptable level that a staff complement of at least three full time equivalent staff at the level of HEO, E0 and CO should be provided to this Unit on a permanent basis. It is likely that write-offs for some of this debt will be required but every effort should be made to recoup as much of this outstanding balance as possible. Overpayments were found by lntemal Audit to have occurred for four main reasons, namely; 1. Late notifications regarding deaths, the payment of pensions in advance contributes to the cause of overpayments in this area 2. Late noti?cations regarding payroll adjustment events such as unpaid leave, allowances, sick leave and rates of pay 3. Incorrect points of scale 4. Social Welfare Benefit Retention. This refers to members who had social welfare payments paid directly to themselves when it should have been paid to An Garda Siochana. 4.6 Procurement Continuous improvements in the procurement process were evident in 2016. However, GIAS found outstanding issues with regard to procurement in four Garda Divisions and in the Garda College. Progress in this area should continue to be monitored. It is somewhat disappointing that the Medical Service Contract has not been put in place and that there continues to be problems Seirbhisi gain-niula poilineachta agus slandala a sholathar le hiontaoibh, muinin agus tacaiocht na ndaoine at abhfreastalaimid To deliver professional policing and security services with the trust, con?dence and support of the people we serve 17 Garda Internal Audit Section associated with the placing of contracts for the towing and storage of seized vehicles in some parts of the country. 4.7 Sick, Absence Management and Staff Resource Allocation. GIAS continued in 2016 to scrutinize issues relating to absence management particularly in relation to long term sick leave cases and how employees are encouraged to return to full employment. As staff absences represent a major cost to the Garda Vote, this issue will continue to be reviewed by GIAS. Conclusion Seirbhisi gairmi?la pdilineachta agus slendala a sholathar le hiontaoibh, muinin agus tacaiocht na ndaoine ar abh?'eastalaimid To deliver professional policing and security services with the trust, con?dence and support of the people we serve 18 Garda Internal Audit Section As a result of the audit work conducted in 2016!]? I am required by professional audit standards to highlight ?ndings of signi?cant risk exposure in relation to It is recommended that a detailed note is included in the Statement of Internal Financial Control in relation to the failure of the Financial Management Procedures in the Garda College over many years. This note should set out the breaches of the Public Financial Procedures identi?ed in the GIAS Report and set out the controls with regard to the administration of the Garda College that are being put in place to resolve the issues and mitigate against the risks. Given the above mentioned continuous improvements and the recommended notes to be included in the Statement'it is reasonable for the Commissioner to sign the Statement of Internal Financial Control in relation to the Gerda Vote in 2016. Niall Kelly Head oflnternal Audit 31?11 March 2017 Seirbhisi gairrnit?tla pcilineachta agus slandala a sholiithar 1e hiontaoibh, muinin agus tacaiocht na ndaoine a: abhfreastalaimid To deliver professional policing and security services with the trust, con?dence and support of the people we serve 19 Appendix 1: Audit Reports Completed in 2016 and 15? Quarter 2017. 3 9 1 1. Report to the Commission in relation to Financial Controls in 2016 2. Review Audit of Overpayments of Pay and Pension (March 2016) 3. First Review Audit DMR North Central (April 2016) 4. 5 6 "i Second Review Audit DMR North Central (January 201?) . First Review Audit DMR South Central (May 2016) . Second Review Audit DMR South Central (January 201?) . Audit Report Wexford Division (September 2016) . Audit of West Cork Division (March 201?) b. Audit Report Dublin Metropolitan Region West Division (March 2017) Joint Review Examination of the Serious Crime Review Team by GPSU and GJAS (October 2016) 'itJnterim Audit Report of Financial Procedures in the Gerda Coilege, Templemore February 201?) 12.Audit of the Risk Management Framework (March 201?) 13.Review Audit DMR North Division (March 201?) 14.Audit Report DMR West Division (March 2017) 15.Audit of Risk Management Framework (March 201?). Garcia Internal Audit Section gairmi?la p?i?neachta agus sl?nd?la a shol?thar Ie hianlauibh, muim'n agus tacaiecht m1 ndaoine ar abhfmastalaimid To deliver pmfessinnai puiicing and security services with the trust, con?dence and of the penple We serve 22 Garcia Internal Audit Section 1 Public Financial Procedures; (the Blue Book) Department of Public Expenditure and Reform (2008) . 2 Public Procurement Legislation; 81. No. 192112015 - European Communities (Public Authorities Contracts] {Review Procedures) (Amendment) Regulations 2015. SJ. No. 193l2015 - European Communities {Award of Contracts by Utility Undertakings) (Review Procedures) (Amendment) Regulations 2015. mus:llprocu rem ent. ielrequlations-si-1 30-201 O?european-comm uni?es-public- SJ. No. 200 of 2016 European Union (Award of Contracts by Utility Undertakings) Regulations 2016 Date Published: 2016 Download SJ. No. 234 of 2016 European Union (Award of Public Authority Contracts) Regulations 2016 Date Published: 2010 Download I SJ. No. 192 of 2015 European Communities (Public Authorities? Contracts) (Review Procedures) (Amendment) Regulations 2015 Date Published: 2015 Download SJ. No. 193 European Communities {Award of Contracts by Utility Undertakings) {Review Procedures) (Amendment) Regulations 2015 Date Published: 2015 Download EU Directive 2014125 - Procurement by entities operating in the water, energy, transport and postal services sectors (Utilities Directive) Date Published: 2014 Download EU Directive 2014024 - EU Procurement Directive Date Published: 2014 Download] EU Directive 2014123 - Award of Concession Contracts Date Published: 2014 Download Seirbhisi gait-midis agus sland?la a shol?thar le hiontaoibh. muinin ages tacaiocht na ndaoine a: abhfreastalaimid To deliver professional policing and security services with the trust, con?dence and support of the people we serve 23 An Garda Siochana Freedom of Information Of?ce An Garda Siochana, Athlumney House Oi?g Sacrala Faisn?ise An Garda Siochana, Teach ath Lnimnigh Larionad Gno Udaras Forbartha Tionscail IDA Business Park Baile Sheain An Uaimh Johnstown, Navan Contae na Mi Co Meath C15 DR9U C15 DR90 Teileaf?onfl?el: (046] 903635 0 Laithrean GreasainiWebsite: m.gnrda.ie Bi iinanoin us .a Riomh-phoistziEmail: Mr. Ken Foxe ken@righttoknow.ie Re: Freedom of Information Request FOI-000292-2017 Request Partially Granted Dear Mr. oxe, I refer to your request, dated 151 July 2017 and received on 3rd July, 2017, which you have made under the Freedom of Information Act (F01) 2014 for records held by An Gerda Siochana. Part 1(n) of Schedule 1 of the FOI Act states that An Gerda Stochana is listed as a partially included agency "insofar as it relates to administrative records relating to human resources, or finance or procurement matters Therefore, only administrative records that relate to human resources, ?nance or procurement shall be considered. Your request, after clari?cation was provided, sought: Second Review Audit Dublin North entrai DMR Report to Commissioner in relation to Financial Controls 2016 Audit Report DMR West Division Review Audit Report DMR North Division Report to the Commissioner in relation to Financial Controls in 2015 I wish to inform you that I have decided to partially grant your request on the 17th July 2017 with regard to part 5 of your request: Report to the Commissioner in relation to inanciai Controls in 2015 The purpose of this letter is to explain my decision. agus siandaln a shulmhur Ic hwmamhh mumm egos iacamchi ua ndaolne at a hhi'rcasialanmd l?u ilekucr proi'mmnal policing semi-cs the Ernst, con?dence and support ut'thc people no scru- 1. Findings, particulars and reasons for decision to deny access This audit report was requested from the Garda Internal Audit Section (GIAS). Part Schedule 1 - Out of Scope In accordance with Part Schedule 1 of the FOI Act certain records or parts of records have been redacted as they do not come within the scope of the FOI Act insofar as An Garda Siochana is concerned. Part 1(n) of Schedule 1 of the FOI Act states that An Garda Siochana is listed as a partially included agency "insofar as it relates to administrative records relating to human resources, or ?nance or procurement matters Therefore, only administrative records that relate to human resources, ?nance or procurement shall be considered. Records relating to operational matters such as warrants or evidential property management are exempted as part of Part 1 (11), Schedule 1 as these are neither considered administrative records (as set out in Of?ce of the Information Commissioner: OIC case reference number 160276) or records relating to human resources, ?nance or procurement. The vast majority of this audit relates to the operational matters concerning property and evidence management thus the redaction is signi?cant as per Part1 of Schedule 1 of the FOI Act. 2. Right of Appeal In the event that you are not happy with this decision you may seek an Internal Review of the matter by writing to the address below and quoting reference number Fill-000292- 2017. Freedom of Information Of?ce, An Garda Stochana, Athlumney House, IDA Business Park, ohnstown, Navan, Co. Meath C15 DR90 Please note that a fee applies. This fee has been set at ?30 (?10 for a Medical Card holder). Payment should be made by way of bank draft, money order, postal order or personal cheque, and made payable to Accountant, Garda Finance Directorate, Gerda Headquarters, Phoenix Park, Dublin 8. Payment can be made by electronic means, using the following details: Account Name: Garcia Siochana Finance Section Public Bank Account Account Number: 10026896 Sort Code: 900017 IBAN: IE86BOF190001710026896 BIC: BOFIIEZD You must ensure that your FOI reference number is included in the payment details. You should submit your request for an Internal Review within 4 weeks from the date of this noti?cation. The review will involve a complete reconsideration of the matter by a more 2 {J-?HrmrulJ :Iglis xlmulnin .1 sliuintimr Ic mannin .-1billrui-ddimmld pull-rm; anti ?mum ?on recs. Ith and support the us: son :3 senior member of An Garda Siochana and the decision will be communicated to you within 3 weeks. The making of a late appeal may be permitted in appropriate circumstances. Please be advised that An Garcia Siochana replies under Freedom of Information may be released in to the public domain 1ria our website at . Personal details in respect of your request have, where applicable, been removed to protect con?dentiality. Should you have any questions or concerns regarding the above, please contact me by telephone at (046) 90363 50. Yours sincerely, Ute-em. Dce?. HELEN DEELY FREEDOM INFORMATION OFFICER 20?" JULY 2017 sammula anus mumin anus taeamehl no ndamne or a hhl'reastalainnd To deliver prol'esszonal pnheme and set-um} sen lees the mm, eunlilienee anti slippurl urme people we sene Requester Name: Mr. Ken Foxe File Re: FOl?tlu0292-2tll7 - Report to the Comm. in rotation to Financial Controls in 2015 . . . . . Decision Page ?a Description of Quotations Relevant Section of Reason for decision Person(s) Objections Make r?s document Acts Consulted Yesmo . . decision 1 Cover Sheet 0 nia nia Granted 2 Table of Contents 3 Part 1{n} Schedule 1 Out of Scope Part-Grant 3 to 4 introduction 8? Work 0 nla nla Granted Completed Table 2 - Priotity 5 Recommendation 5 Part 1(n} Schedule 1 Out of Scope Part?Grant Outstanding Value Added from to 8 Audit Process 3 Part 1(a) Schedule 1 Out of Scope Part-Grant Collaboration with 9 Gerda Professional 1 Part 1(n) Schedule 1 Out of Scope Part-Grant Standards Unit 10 to 12 Main Audit Findings 3 Part 1th) Schedule 1 Out of Scope Part~Grant 13 Conclusion 4 Part 1(n) Schedule 1 Out of Scope Part-Grant Signature List of 1-4 to 15 Audits completed 2015 0 Ma nfa Granted 16 to 3? Blank Sheets 0 nia nla Granted Total number of pages 1? Total number of pages for fuii release Total number of pages for partial release 1o Total number of pages being withheld 0 Report to the Garda Commissioner in relation to Financial Control in 2015 March 2016 Garda Internal Audit Section Table of Contents Introduction 3 Work Completed 3 Risk Reduction 5 Value Added from Audit Process 6 Collaboration with Garcia Professional Standards Unit 8 Anti-Fraud Policy 9 Main Audit Findings 9 1. Financial Control Environment 9 2. Administrative Control and Management Reporting 10 3. Internal Audit 11 4. Signi?cant Issues Identified from the Audit Process ll 4.2. Overpayments of Salary and Pensions 1 4.3. Procurement 12 Conclusion 13 Appendix 1: Audits Completed in 2015 and 15t Quarter 15 Ag ohair 1e Pobail ehun iad a ehesaint ages chun ?eastnl onhu Working with Communities to Protect and Serve Garda Internal Audit Section Introduction This Report documents issues identi?ed by Internal Audit or brought to the attention of Internal Audit during 2015 and the ?rst quarter in 2016. that are relevant to the Financial Control Framework in An Garda Siochana. It will form part of the analysis informing the Commissioner in relation to whether she should sign the Statement of Internal Financial Controli in relation to Vote 20, An Garda Siochana, Appropriation Account 2015. The opinions expressed in this Report are those of the Garda Internal Audit Section (GIAS) in its role as an independent oversight of the ?nancial control framework within An Garda Siochana. Work Completed Thirteen audit reports were completed in 2015 and the ?rst quarter 2016 (see Appendix 1). These included; I Seven Audits of Garda Divisions! Units. I One Thematic Audit. I Four Review Audit Reports which focused on the implementation of recommendation from previous audits. I One Report, to the Garda Commissioner in relation to Financial Control and encompassing the Annual Report of the Garda lntemal Audit Section. This does not include the Joint Audit with Garda Professional Standards Unit of the National Support Service (NBS) Region which comprises of ?ve sub-audits of; 1. Of?ce of the Assistant Commissioner N85 2. Garda National Immigration Bureau The Statement of Internal Financial Control is required as part of the implementation of the Mullarkey Report Department of Finance (2002). Ag obair le Pobail chun iad a chosaint agus chun ?eastal orthu 3 Working with Communities to Protect and Serve 3. Garda Bureau of Fraud Investigation 4. Technical Bureau 5. Garda Drugs and Organised Crime Bureau This audit is not yet completed and to date has taken up 202 audit days in the second half of 2015 and the ?rst quarter of 20 16. Audit Reports Completed 2014 2015 Audits of 6 7' Units Review Audits 4 4 Joint Audits with GPSU 2 0 Thematic Audits 4 Expenditure Reviews 2 0 Reports to CommissionerfAnnual 1 I Report Total 19 13 Approximately 75% of the Audit Plan 2015 recommended by the Audit Committee was completed. The other 25% of the plan could not be completed due to staff vacancies in GIAS, the unavailability of auditees and because priority areas identi?ed during 2015 changed with consequential changes to audit priorities. The approved strength of GIAS is eleven staff but only seven are currently employed in the Section. The capacity was reduced by vacancies at Sergeant and Executive Of?cer and Accountant grades. Notwithstanding the foregoing, I am con?dent that the major high risk areas contained in the 2015 Audit Plan and emerging risks which overshadowed in terms of importance some of the original risks, have been examined and reported on. An Audit plan for 2016 has been drawn up which includes audits that could not be concluded in 2015. Ag obair 1e Pobai] chun iad a chosaint agus chun freasta] orthu Working with Communities to Protect and Serve Risk Reduction Internal Audit Reports have identi?ed and reported on risks to the ?nancial management and reputation of the Garda Organisation. The reports classify the recommendations made, as priorities 1 to 3. Priority one recommendations are those where both the impact of the control weaknesses on the operations of the organisation as a whole or on Divisionstnits within the Garda Organisation and the likelihood of occurrence is considered to be high. Priority one issues require immediate attention by management. There are currently 44 priority one recommendations from Internal Audit Reports outstanding or not fully implemented. These can be broken down into the following general categories; Priority One Recommendations Outstanding; Category Number Procurement Procedures 4 Sick Absence and Resource Management 5 Overtime and Allowances 1 Local Management Inspections/Oversight 2 Authorisation of Overtime and Allowances 3 Total 44 Ag obair le Pobail chun iad a chosaint agus chun freastal orthu Working with Communities to Protect and Serve While 44 priority one recommendations remain to be resolved it should be noted that 21 other priority one recommendations have been resolved or were revised to priority 2 or 3 over the last year on foot of management action in relation to the recommendation from lntemal Audit Reports. The outstanding recommendations are reported to the Audit Committee at each meeting. Review Audits are conducted within six months to one year after the original audit report has been concluded. In this way risks are identified, recommendations for improvement made and a review conducted in order to provide assurance that these risks are being managed appropriately. Value Added from Audit Process The recommendations from audits which have been veri?ed as implemented through the review audits conducted in 2015 contributed to a reduction in risk and an improvement in ?nancial control as follows: Ag obair le Pobail chun iad a chosaint agus chun ?'easta] orthu Working with Communities to Protect and Serve 3. In the course of Divisional Audits in 2015 issues relating to the procedures regarding long-term sick absences of members and staff were examined including policies and procedures to assist staff to return to work including ?light duties? and ?reduced hours?. Recommendations were made regarding the need for Local Management to liaise closely with the Garda Human Resources and People Development Directorate and the Occupational Health Service in relation to such cases and to continuously review cases where ?light duties? or ?reduced hours" have been recommended. 4. Audit recommendations were made in regard to more effective allocation of staf?ng resources and re-organisation of administrative functions to better ?t our strategic and operational goals. 5. While much work has been done to enhance compliance with public procurement requirements leading to transparency, improved oversight, 2 HQ Directive 59fl4; Garda Inspections and Reviews; July 2014. Ag obair le Fobail chum iad a chosaint agus chun ?'eastal orthu Working with Communities to Proteat and Serve accountability and greater efficiency, GIAS found outstanding issues in regard to procurement in four Garda Divisions. Collaboration with Garda Professional Standards Unit GIAS, as part of the overall governance and control environment within An Garda Siochana, provides reasonable audit assurance that signi?cant risks are identi?ed, managed and controlled effectively throughout the Organisation. GPSU examines and reviews operational, administrative and management performance. GIAS and GPSU make recommendations and propose measures to enhance controls and improve performance. Both units have developed competences in certain areas of audit and examination. It is recognised that there is a crossover of responsibilities and roles between Garda internal Audit Section and the Garcia Professional Standards Unit. in some complex audits the skill set of both units is required working collaboratively. During 2015 one joint audit was undertaken between GPSU and GIAS as follows; I. National Support Service Region, which encompasses audits of the following Units 1. N58 Regional Of?ce, II. Garda Bureau of Fraud Investigations, Garda Drugs and Organised Crime Bureau, Ag obair 1e Pobail chun iad a chosaint agus chun freastal orthu Working with Communities to Protect and Serve IV. Garda National Immigration Bureau and V. Garda Technical Bureau. These audits are still being worked on and have consumed considerable resources to date (202 audit days by GIAS staff to date). During 2015 this collaboration with GPSU has worked well with joint teams working together under the direction of Chief Superintendent GPSU and the Head of lntemal Audit. This collaboration will continue in 2016. Main Audit Findings 1. Financial Control Environment In general An Garda Siochana has well developed systems for setting out ?nancial responsibilities and ?nancial reporting. These systems are documented in the Garda Finance Code and the Public Financial Procedures3. The audit process has established that:4 3 Public Financial Procedures Department of Finance 4 Bullet points are taken from the Statement of Internal Financial Control included in DPE Circular 17f13 Section C. Ag chair 1e Pobail chun iad a chosaint agus chun ??eastal orthu Working with Communities to Protect and Serve 0 Financial responsibilities have been assigned at management level with corresponding accountability, Reporting arrangements have been established at all levels where responsibility for ?nancial management has been assigned, 9 Formal procedures have been established for reporting significant control failures and ensuring appropriate corrective action, 0 An Audit Committee was appointed in 2014 to advise the Accounting Of?cer in discharging her responsibilities for the internal ?nancial control system. 2. Administrative Controls and Management Reporting A framework of administrative procedures and regular management reporting is in place including segregation of duties and a system of delegation of responsibility and accountability and in particular the audit process has established that: I There is an adequate budgeting system with an annual budget which is kept under review by senior management, There are regular reviews by senior management of periodic and annual mancial re arts which indicate inancial er ormance a ainst orecasts - There are appropriate capital investment control guidelines and formal project management disciplines, I An Garda Siochtina has systems and procedures to enable compliance with all relevant guidelines and circulars regarding procurement including a Central Procurement O?ice and Divisional Procurement Committees throughout the country. However di?iculties, legal issues and delays in placing and replacing contract in some Divisions remain as highlighted in the four Divisions found not be complaint (see Page 7 point 5 5 5 The wording ofthis bullet point has been amended from that shown in DPE Circular Section 13, as full compliance cannot be claimed at this point in time. The wordng shown more accurately re?ects the situation within An Garda Siochana. 10 Ag chair to Pobai] chun iad a chosaint agus chun ?-easta] orthu Working with Communities to Protect and Serve Internal Audit Garda Internal Audit Section has appropriately trained staff operating under a Charter agreed with the Garda Commissioner. Audit work is informed by analysis of the ?nancial risks to which An Garda Siochana is exposed and it?s Annual Audit Plan which was approved by the Audit Committee and the Commissioner in 2015 is based on this analysis. The Internal Audit function is reviewed periodically by the Audit Committee and the Commissioner. Procedures are in place to ensure that the recommendations from the Internal Audit Reports are implemented. Signi?cant issues identi?ed from the Audit Process 4.2 Recoupment of Overpayments on Salary and Pension Balances outstanding in relation to overpayments of Salary and Pensions at the at September 2015 amounted to approximately 61,529,998 an increase of ?390,984 (or 34%) on the balance at the end of 2014. This represents a significant increase which attribute to increased scrutiny resulting in more cases being discovered. Repayment plans were in place for 47% of the cases of overpayments at the end of 2015. These cases are being pursued by the Reeoupment Unit in HR PD Directorate. it is likely that write-off for some of this debt will be required but every effort is being made to recoup as much of this amount as possible. Overpayments were found by Internal Audit to have occurred for four main reasons, namely; 11 Ag obair le Pobaii chun led a chosaint agus chun ??eastal orthu Working with Communities to Protect and Serve 1. late noti?cations regarding Deaths, the payment of pensions in advance contributes to the cause of overpayments in this area 2. late noti?cations regarding payroll adjustment events such as unpaid leave, allowances, sick leave and rates of pay 3. Incorrect points of scale 4. Social Welfare Bene?t Retention. This refers to members who had social welfare payments paid directly to themselves when it should have been paid to An Garda Siochana. GIAS are concerned that adequate human resources are not being provided to the Recoupment Unit. 4.3 Procurement Continuous improvements in the procurement process were evident in 2015. However, GIAS found outstanding issues in regard to procurement in four Garda Divisions. Progress in this area should continue to be monitored. 4.5 Sick, Absence Management and Staff Resource Allocation. During 2015, there was increased scrutiny of issues relating to absence management particularly in relation to long term sick leave cases and how employees are encouraged to return to full employment. As staff absences represent a major cost to the Garda Vote, this issue will continue to be reviewed by GIAS. Audit recommendations were also made in regard to more effective allocation of staffing resources and re-organisation of administrative functions to better fit our strategic and operational goals. 12 Ag obair le Pobail chun iad a chosaint agus chun ?eastal orthu Working with Communities to Protect and Serve Conclusion Improvements in the ?nancial control environment were made in relation to guidelines for local management inspections, at Gerda Stations. greater compliance with competitive procurement requirements, and control of overtime and allowances. Given the number of outstanding audit recommendations and priority one issues identi?ed in the audit process that remain to be addressed in relation to the management of property and evidence including drugs (see page 5). GIAS can provide limited assurance in regard to the effectiveness of the controls in relation to property and evidence in the possession of An Garda Siochana in 2015. It is encouraging however that this issue has been prioritised within the Strategic Transformation Agenda (TRUST). GIAS are advising the Strategic Transformation Office to ensure that the issues highlighted from the audit process in this area are adequately addressed within the speci?cation for new systems and controls. The Risk Management Unit has revised the risk management procedures during 2015 and a Deputy Commissioner was appointed as the Chief Risk Of?cer. This is moving towards more timely identi?cation, reporting of and response to risks and facilitating consideration of current and emerging risks as well as risks that we have known about for some time. The risk management processes will continue to be reviewed by GIAS in 2016. As Head of lntemal Audit I am required by professional audit standards to highlight the signi?cant risk exposure nonetheless 1 can report that strategies are in place to ensure a continuous quality improvement in and more generally in regard to the financial control framework. It is therefore not unreasonable for the Commissioner to sign the Statement of Internal Financial Control in relation to the Garda Vote in 2015. 13 Ag chair 1e Pobail chun iad a chosaint agus chun ?eastal orthu Working with Communities to Protect and Serve Niall Kelly Head of Internal Audit 24th March 2016 Ag obair le Pobail chum lad a chosnint agus chun ?'eastnl orthu Working with Communities to Protect and Serve 14 Garda Internal Audit Section Appendix 1: Audit Reports Completed in 2015 and 1St Quarter 2016. Report to the Commission in relation to Financial Controls in 2015 Audit Report Cork North Division Review Audit Report Mayo Division Joint Audit with Internal Audit Unit of the Department of Justice of the Irish Naturalisation and Immigration Service; Stamp 4 Process. Audit Report Cavan Monaghan Division Review Audit Report National Bureau of Criminal Investigation Review Audit Laois Offaly Division Review Audit Roseommon Longford Division Audit of the Regional Support Unit Eastern Region . Audit of the Regional Support Unit South Eastern Region . Audit of Regional Support Unit Western Region . Audit of Regional Support Unit Northern Region . Audit of Regional Support Unit Southern Region Ag obair le Pobai! chun iad a chosaint agus ehun ?eastal orthu 5 Working with Communities to Ptotmt and Serve Garda Internal Audit Section Ag ubair la Pubail chun iad a chosaim agus shun ?'eastal urthu Working with Cammunitias to Protect and Serve 16 Garcia Internal Audit Section Ag ohair It: Pobail chum ind a chusaint agus chm: ?easta! orthu Waddng with Communities to Protect and Serve 17'