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Ethical governance programme

Information about the ethical governance programme.

The Ethical Governance Programme is available to all managers and staff and is an awareness training programme covering the various ethical governance procedures and practices applicable to Cumberland Council.

The following information identifies the areas where awareness / training is required and a brief overview of the aims and objectives.  In time, it may be that face-to-face workshops will be provided for all or some of the topics and you will be notified in due course.

Combined Impact Assessment (CIA) and Equality Impact Assessment (EIA)

Combined Impact Assessment (CIA)

The Combined Impact Assessment (CIA) is a simple self-assessment tool to help officers think about how their policies, strategies, projects, procurements, commissioning and services might impact on our communities. It helps officers to critically assess whether a proposal has wider impacts beyond its intended outcomes, and if it impacts differentially on different communities or places. It will also allow consideration of how any positive impacts of a particular proposal may be increased and any negative impacts reduced.

The tool covers a range of categories including equalities, climate and sustainability, health and other socio-economic factors that all contribute to thriving, healthy communities.

Undertaking a CIA supports good decision making based on evidence and consideration of how our decisions will impact on the community and wider objectives. The CIA helps us:

  • To plan services and develop policies which meet the needs of our diverse communities, especially those who are known to have poorer outcomes.
  • To meet our legal requirements under the Equality Act 2010, and our ambitions to improve health and wellbeing, address inequalities, tackle the climate emergency and improve local economies as set out in the Council Plan.
  • To challenge ourselves to ask if we are doing enough to reduce inequality and improve health and wellbeing.

A CIA should be an integral part of any decision or policy making process and should be undertaken for all reports, including Officer Key Decision reports, Executive reports as well as for all decisions relating to service improvements or major changes to services.

If the initial screening through the CIA points to evidence of substantial impacts in a particular area then the toolkit provides fuller impact assessment tools that can be used to ensure that a more comprehensive assessment of those impacts is carried out.

Equality Impact Assessment (EIA)

The People Screening Assessment in the CIA is designed to ensure that decisions and changes do not discriminate against people protected by the Equality Act (protected characteristics) and other groups who the Council has voluntarily given protected characteristic status.

The Screening and Full EqIA looks at adverse treatment. This is where someone (or a group) is adversely affected by a decision compared to another group. For instance – a housing policy that assumes a fixed address and does not account for many in the Gypsy Roma and Traveller community.

Adverse treatment can be conscious (direct discrimination) and not conscious (indirect discrimination). All direct discrimination is unlawful. Indirect discrimination is also unlawful unless the adverse treatment is assessed and justified.

A Full EqIA is carried out where there is a reasonable concern that a decision, policy, service or function may have a substantial impact on one or more protected characteristics.

Complaints procedure

Cumberland Council believes passionately in the delivery of excellent public services and is committed to putting our customers first. The authority is dedicated to listening, involving and engaging residents and using feedback to drive change, learning and improvement.

We accept that sometimes things go wrong or are not as good as they should be and as such, we believe that effectively managing complaints is central to improving our services. We also know that compliments provide us with valuable insight into what is going well and sharing this best practice throughout the authority is part of our culture.

We will always try to resolve most complaints at the first point of contact. This gives our services a chance to address issues on an informal basis and in an efficient manner. If this is not possible, this procedure explains how matters can be dealt with formally through the Corporate Complaints Policy.

Cumberland Council has a new Corporate Complaints policy and process which came in to force on 29 July 2024. 

Contract management

This part of the Contract Management Process will provide officers who are responsible for the day-to-day management of goods, works or services contract, with guidance on contract management procedures.

Support and guidance can be sought from the procurement team (procurement.mailbox@cumberland.gov.uk )

Corporate health and safety

Cumberland Council has duties under the Health & Safety at Council constitution | Cumberland CouncilWork Act 1974 to protect the health and safety of its employees and other people (e.g. service users and members of the public) who may be affected by Council activities.

Access to the Corporate Health and Wellbeing SharePoint site where all information on health and safety, including a copy of the Corporate H&S Policy 2023, can be found on the health and safety pages.

Corporate risk management

The Risk Management Framework sets out how we will manage risk across the council. It is a set of practices and principles which staff and elected members are required to implement to help Cumberland Council deliver its vision.

The Council’s risk management framework is in place to ensure managers feel empowered to manage risk through ambitious and innovative risk responses, which also take full advantage of working collaboratively both internally and with our key partners to deliver compassionate services that meet our corporate objectives. The Risk Management Framework supports the consistent and robust management of risks and opportunities across the Council. 

There is an eLearning module available on iLearn that covers Risk Management.

Council constitution

Cumberland Council’s Constitution sets out how we operate, how we make decisions and the procedures we follow to ensure that we are efficient, transparent and accountable.  Some of the processes are required by law, others ensure we operate effectively.

To view a copy of the Constitution, visit the Cumberland Council website.

Cumberland appraisal

We recognise that our employees are integral to achieving our council priorities, vision, values and target operating model. Everyone needs to be able to perform to their best and have the opportunity to learn, grow and progress in their careers and feel valued for their contribution to the overall success of the council. In order to thrive at work, all employees need to be involved in regular strength-based conversations with their manager throughout the year about the work they do, how they feel about it and where they may need help, support and guidance.

The introduction of this new Cumberland employee appraisal process across Cumberland Council provides a simple structure to support an annual review and summary of these regular conversations, capture progress and key achievements against personal, team and service priorities and look towards new ones for the following 12 months.

The new appraisal process adopts a cascade approach whereby employees receive their appraisal only once their own line manager has had an appraisal. The launch of the appraisal process begins with the chief executive and cascades through directors, assistant directors, managers and employees by 30 June 2024 to create a shared common purpose and alignment to the overall council priorities. 

This new appraisal process replaces all previous appraisal systems in the legacy councils. Designed to complement regular 121 conversations, there is a key focus on health and wellbeing and the council’s values and is designed to build on supporting the strengths, interests and motivations of employees.

The appraisal process aims to:

  • Ensure all employees understand and are engaged with Cumberland Council’s values and Target Operating Model and how these underpin and link to their role.
  • Provide a regular opportunity to check in on health and wellbeing.
  • Ensure all employees feel included, valued and supported in delivering against council priorities.
  • Provide quality time to reflect on what has been achieved, is progressing well, could be even better and how.
  • Encourage ownership of work and development, seeking solutions and opportunities to further improve practice.
  • Appears easier to use which should encourage/support completion.
  • The opportunity to capture personal learning and development needs to inform the provision of learning opportunities for employees.

Data protection

Effective service delivery and compliance with legal obligations is dependent on the lawful collection, use and disposal of data that identifies people, this includes personal, sensitive personal or criminal/law enforcement data (‘person identifiable data’).   

The council is a large, complex organisation, and is required to comply with data protection legislation, including (but not limited to):

UK General Data Protection Regulation (‘UKGDPR’)

Data Protection Act 2018 (‘DPA 2018’)

Human Rights Act 1998 (‘NRA 2008’)

This extends to Elected Members, employees or contractors who are likely to have access to person identifiable data about employees, customers, clients, residents and visitors.  

Whether you work in an office, from home or deal with customers face-to-face, you have a personal responsibility to ensure that this data is always kept secure, and that the privacy of individuals is protected.

An eLearning course is mandatory for all staff as part of their induction and is designed to raise awareness of security and data protection issues, in four separate modules:

  • Data Protection
  • Records and Information Management
  • Cyber Security
  • Freedom of Information

It is the managers responsibility to ensure that this course is completed by all their staff during the first few months of their employment with the Council. 

Decision making and report writing

The Council has many functions and responsibilities which requires decisions to be taken by the right person at the right time in the right way in accordance with the Council’s Constitution. 

Fraud awareness

Cumberland Council takes its responsibility for safeguarding public monies seriously and has a zero-tolerance approach to fraud; bribery and corruption; money laundering and tax evasion. Fraud and corruption reduce the resources available to deliver Council services to those people who depend on us. Failure to put in place effective measures to counteract financial irregularities may also damage the Council's reputation.

There is a responsibility for all officers to notify and report any issues of serious concern. Failure to do so may have a negative impact on the delivery of council services, negatively impact the Council's reputation or impact the conduct of an individual.

Management has a responsibility to provide a safe and effective working environment, which enables individuals to raise genuine concerns about malpractice or unlawful conduct in the workplace. They must also ensure adequate controls are in place to help prevent and detect fraud, including ensuring robust policies are in place that define how the Council manages the prevention, detection, investigation and recovery of fraud.

Officer code of conduct

Cumberland Council’s Code of Conduct outlines existing laws, regulations and conditions of service, and provides officers with guidance to assist them in their day-to-day work including fraud or corruption, hospitality and gifts and related party transactions.

Performance management

Performance management is a crucial tool for achieving objectives, continually improving services and ensuring that the Council is providing value-for-money services to its residents. This means that performance management is integral to the role of every Council Officer rather than the sole responsibility of a particular individual or department.

Managers at all levels should:

  • Contribute to and produce relevant plans and objectives which contribute to the Council Plan
  • Inform planning, resourcing, quality management and service delivery
  • Identify, mitigate and escalate risks as appropriate.
  • Provide data in accordance with performance reporting requirements.
  • Seek support to improve performance, review systems and processes, and manage risks.
  • Manage staff performance and undertake appraisals
  • Facilitate and apply learning.
  • Encourage staff to seek support when needed to improve performance and provide support when requested.

 

Setting performance measures

The Council has a responsibility to ensure its data is a true and accurate reflection of the services it delivers, particularly as these support funding applications, key decision making and targeting of resources.  The development of performance measures is a key management process which requires input and ownership from all those with responsibility for collecting, storing and reporting performance measure data.

Links to the Council’s Performance Framework include the following

Procurement

The council is the custodian of public money and must procure its goods, works and services in accordance with the law (Public Contract Regulations 2015, and subsequently the Procurement Act which comes into force on the 28 October 2024).

Procurements must be open, transparent, and fair.

The contract procedure rules, which form part of the council’s constitution, outline the key steps that need to be followed and should be referred to prior to undertaking any procurement.

Generally, a permission to procure will need to be given, in writing, before a procurement can commence and the total contract value (which is the contract value including any potential contract extensions) helps determine the minimum route to market:  

Total Contract Value Procedure
Up to £2,000 Responsible Officer must use a process which obtains best value for money.
One oral quotation (confirmed in writing where the quotation exceeds £500).
Include Local Supplier if appropriate
£2,001 - £50,000 2 written quotations.
Invitation to submit a quotation in writing to at least 2 candidates, Include Local Suppliers if appropriate
£50,001 - £100,000 3 written quotations.
Invitation to submit a quotation in writing to at least 3 candidates,
Include at least 2 Local Suppliers if appropriate
Exceeding £100,000 but below relevant Procurement Threshold Written Tender.
The tenders must be advertised on Contracts Finder and via the councils' e-tendering system
Procurement Threshold and above Written Tender.
The tenders must be advertised on Find a Tender System (FTS), Contracts Finder and the councils' e-tendering system

Prior to any contract award, generally, a permission to award will be needed from someone with the appropriate delegation.

Advice and guidance on the contract procedure rules and/or procurement regulations should be sought from the Procurement Team (procurement.mailbox@cumberland.gov.uk) and they can also provide you template documents in relation to quotations and tenders. 

Alternatively guidance can be found on the authority’s Procurement SharePoint page for further information on topics such as:

  • The role of Procurement
  • How does Procurement work?
  • Award and evaluation criteria
  • Social Value and how to incorporate it into your procurement
  • Premier Supplier Service
  • Procurement Library where you will find templates, document and guides

RIPA

Codes of practice and guidance for making an application under the Regulation of Investigatory Powers Act (2000).  Recent changes coming in to force from December 2023.

 These help public authorities assess and understand whether, and in what circumstances, it is appropriate to use covert techniques.

The codes also provide guidance on what procedures need to be followed in each case. All RIPA codes must be approved and debated in both Houses of Parliament and published.

There is an eLearning module available on iLearn that covers The Regulation of Investigatory Powers Act 2000.