Public Administration Committee Contents



MEMORANDUM FROM PAUL FLYNN MP, MEMBER OF THE COMMITTEE

INTRODUCTION

  The use of jargon—bad language—in business and politics is nothing new. John Betjeman nailed it in his poem Executive:

    You ask me what it is I do. Well, actually, you know,

    I'm partly a liaison man, and partly P.R.O.

    Essentially, I integrate the current export drive

    And basically I'm viable from ten o'clock till five.

  But with the advent of new Labour, the tendency towards using jargon has proliferated exponentially to the point that official communications are now largely incomprehensible. If we take BEST PRACTICE, as an example, this phrase now appears as a matter of course in policy documents, regulation, legislation and guidelines for almost every conceivable situation. A blog recently commentated:

    According to the Wikipedia, Best Practice is a management idea which asserts that there is a technique, method, process, activity, incentive or reward that is more effective at delivering a particular outcome than any other technique, method, process, etc. The idea is that with proper processes, checks, and testing, a project can be rolled out and completed with fewer problems and unforeseen complications.

  Yes, just as you and I suspected, it's yet another form of modernspeak designed to state the obvious, and give those stating the obvious an air of undeserved authority. It has found its way into both political and management jargon, and it is completely meaningless.

  Would anyone knowingly pursue the route of worst practice?

  In 2001 the Government introduced legislation designed "to enable provision to be made for the purpose of reforming legislation which has the effect of imposing burdens affecting persons in the carrying on of any activity and to enable codes of practice to be made with respect to the enforcement of restrictions, requirements or conditions."

  The problem with the legislation is that it was so infested with the jargon of regulation that it was virtually incomprehensible to anyone but the parliamentary draughtsmen who wrote it (perhaps not even to them) and in 2006 the Act was repealed by the Legislative and Regulatory Reform Act.

Not content with fouling up the English language the practitioners then decided to rename the DTI the BERR—the Department for Business, Enterprise and Regulatory Reform. The BERR Website announces:

IMPROVING THE PERFORMANCE OF REGULATORS

    — A Code of Practice for national and local regulators was passed by Parliament on 26 November 2007 and will come in to force in April 2008. This makes it legally binding that regulators ensure inspection and enforcement is efficient, both for the regulators themselves and those they regulate.

    — To assess how regulators are performing in delivering proportionate enforcement to ensure compliance, the Better Regulation Executive has worked with the National Audit Office and regulators to develop a review framework published in May 2007. Five major regulators have been reviewed—the Health and Safety Executive, Food Standards Agency, Financial Services Authority, the Environment Agency and the Office of Fair Trading. Reports on each of the regulators will be published in February 2008...

    — The Regulatory Enforcement and Sanctions Bill was introduced to Parliament in November 2007, and if passed, will modernise the penalty regimes which regulators use by giving them access to flexible, efficient and proportionate administrative sanctions.

  The following extracts from the House of Commons Business Plan 2008-09 show how the use of meaningless official language has infiltrated the Commons itself.

  House of Commons Business Plan 2008-09 is produced by the Office of the Chief Executive (OCE).

  The Chief Executive and Clerk of the House is Dr Malcolm Jack.

Extract 1

  This extract from the Business Plan concerns planning for "business resilience" and "risk management" within the House (that is to say how well the House is protected from a terrorist or other attack and how it could continue after such an attack).

3.5 Objective 5

  To ensure that good practice in risk management and business resilience planning is embedded across the House Service.

  Business areas concerned:

  3.5.1 Risk facilitation

  3.5.2 Business resilience planning

  3.5.3 Internal Audit

3.5.1 Risk facilitation

3.5.1.1 FY 2007/08: current year progress

  This year, there has been a re-focus on enhancing risk management activities within the House. The aim has been to match public service standards in risk management by providing support to the Management Board in its management of risk. Progress includes:

    — Regular updates on corporate risk management provided to the Management Board.

    — Risk Management moved to the OCE with effect from January 2008 to strengthen the independence and authority of the risk management process.

    — Assistant risk management facilitator appointed from January 2008.

    — Regular review of departmental risk registers have taken place during the year; in most cases departmental risk registers have continued to develop whilst taking on board any Management Board recommendations made during the year.

3.5.1.2 FY 2008/09: objectives

    — To gain the Management Board's approval for, and then implement, an improved risk management strategy and process, which fits the House and is in line with best practice adopted elsewhere in the public sector

MEASURES

  Risk Management policy, principles and guidance to be documented, published and communicated to staff by Sept 2008.

  Regular liaison with HM Treasury on a quarterly basis to ensure the risk management policy remains up to date and relevant.

    — To ensure a risk management system is embedded within business processes, allowing for risks to be escalated up and down the organisation as necessary

MEASURES

  Regular quarterly meetings with the corporate risk owners (Director Generals) to review risks.

  Departments have up-to-date risk registers based upon functional areas, with any departmental cross-cutting risks identified.

  Feedback from Departments.

  Sufficient assurance is available to meet the requirements of the statement of internal control (SIC) for the Administration Account.

  Risk management to be included within the various management training programmes by September 2008.

  Satisfactory outcome of next internal audit of risk management in 2009/10.

3.5.1.3 FY 2008/09: work planned

    — Risk management process: to continue to develop the House risk management system ensuring that processes are in place for risks to be actively managed and escalated as appropriate through the organisation.

    — Facilitator: to continue to actively support the Management Board and departments in their risk management process.

    — Risk management policy statement/document: ensure the House has a published risk management policy document.

    — Communication: to communicate RM policy to key stakeholders via risk "roadshows", intranet, user friendly guides etc.

    — Corporate risk review: undertake a review of current corporate risks to ensure they remain relevant in light of the recent changes in corporate strategy with particular focus on corporate risk 4 relating to organisational and cultural change.

    — Linking corporate & departmental risk management process: draw closer linkages between corporate and departmental risk management registers; ensuring local departmental/operational risks are identified as well as corporate related risks.

    — Departmental risk registers 08/09: Re-align risk registers to reflect the new unified structure, ensure any management action identified is "SMART", link in with performance measurements. Simplify reporting and monitoring of risks by using risk heat maps to provide a quick visual summary of the critical risks faced by a department.

    — Embed risk management: to ensure that risk management is a fully integrated part of business planning and performance management within the new organisational structure.

3.5.2 Business Resilience Planning

3.5.2.1 FY 2007/08 progress

    — Business Continuity project officer appointed to facilitate creation of standard Parliament-wide Business Continuity plans adaptable to a range of likely contingencies. The work has concentrated on "sub disaster risks" such as the loss of all or part of any building, denial of normal office facilities or staff. Work by the Serjeant-at-Arms on disaster Recovery planning has continued in parallel.

    — The establishment of a Parliamentary Business Continuity Policy Steering Group chaired by the Clerk of the Journals, House of Commons.

    — Preparation of twenty eight departmental Business Continuity plans, in standard format, which will be taken forward in 2008/09 for further iterations and rehearsals.

    — Appointment of a part time consultant to assist in the BC process and a further appointment of a consultancy firm to validate work to date and assist in the delivery of 2008/09 objectives.

3.5.2.2 FY 2008/09 objectives.

    — To ensure that departmental business continuity plans are prepared to a recognised standard, reflect best practice and are consistent across Parliament, with a disciplined and effective update process.

3.6.1.2 FY 2008/09: objectives

    — To deliver systematic review and evaluation of risk management, control and governance through the annual risk based audit programme, in order to give assurance to the Clerk as Accounting Officer, Management Board and Audit Committees on the management of risk and the effectiveness of internal controls and governance processes.

MEASURE

  Delivery of the audit plan (completion of 90% agreed audits in audit plan, to draft report stage).

Extract 2

  This second extract concerns "internal audit" of "the business". What the business is is not clear.

  To add value to the organisation through the Internal Audit process, ensuring the Audit Plan meets the needs of the business and is based on risk

MEASURES

  60% of audit hours spent on high risk areas as agreed and documented in the audit plan.

  Agreement of audit committees and Management Board to the audit plan, before start of Audit plan year.

  Greater than 70% positive response in client satisfaction interviews.

3.6.1.3 FY 2008/09: work planned

  The IAU has already agreed a basis for cooperative working on assurance of services shared with the House of Lords. There is also a new desire on the part of the National Audit Office (NAO) to work more closely with internal audit which has been launched by the joint planning of future audit activities. This will mean information will be shared to a greater extent than hitherto and should enable each assurance partner to rely on the work of the other.

  Internally we are working with the new Parliamentary Director of Estates to establish links between his directorate and internal audit. The objective is for project governance to include an assurance role covering time, quality and cost. In this way the IAU will, in due course, receive assurance on individual major projects and collective assurance on minor projects.

  The concept could also be applied to other areas such as IT, but first there needs to be confidence that the new approach will be thorough, independent and objective. If this can be achieved the IAU will create a library of project assurance evidence that it will use in formulating an overall opinion on project controls. This approach could provide a more efficient way of gathering project assurance evidence, enable a broader coverage of project risks and redirect internal audit review work from the projects themselves to the evidence gathering processes.

  The concept of the IAU gathering evidence from other assurance providers forms the foundation of a model for internal audit's future development as it is presently envisaged. The model assumes that internal audit will collect and take account of a wide range of assurance evidence in formulating opinions on internal controls on an enterprise wide and category basis, for example on governance, projects and financial management.

Looking ahead: The medium and longer term

  On the Members' side there is a clear and growing pressure for more transparency and tighter controls on allowances that could further impact on the scope and governance of internal audit as well as its relationship with Members.

  On the Administration side there is an optimism that the new structure will enable better services to be provided to Members. In parallel the initiatives to improve and professionalise management will demand a more systematic and risk based approach to internal audit combined with an increased need for flexibility to respond to changing priorities and emerging risks. To facilitate this internal audit will need to have closer relations with decision making bodies and better information about projects and initiatives. In return IA will have to provide clear advice and opinion and new ways of communicating these to senior management groups.

  Internal audit is also working very closely with the risk facilitators to ensure that the development of new risk management processes and internal audit develop in harmony.

April 2009





 
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Prepared 30 November 2009