6. Accountability
How accountability and assurance help to deliver a trust's strategy.
This section covers the trust quality description of accountability.
Accountability
The board holds the executive leadership team to account for the effective implementation of the trust strategy and operating plan, including in relation to the use of resources and the drivers of impact.
The board assures itself:
- of the integrity of financial information
- that there are robust risk controls and risk management systems
- that there is compliance with regulatory, contractual, and statutory requirements, including safeguarding
The board agrees:
- the annual operating plan and budget for the trust, which delivers on the trust’s strategy
- metrics and process by which progress will be assessed
The board must have robust strategic oversight of the operations and performance of the trust including:
- holding the senior executive leader to account for improving pupil and staff performance by asking the right questions, informed by data
- having a regular cycle of meetings and appropriate processes to support business and financial planning
- managing the trust within the available resources and ensuring regularity, propriety and value for money
The board has a collective responsibility and avoids getting involved in operational matters unless the trust is in breach of a statutory duty.
To ensure and embed robust accountability, that improves educational standards and financial performance, it is essential for the board, and a committee, where it has delegated powers for education or financial data, to:
- agree a range of metrics, including both quantitative and qualitative data, to measure progress and impact
- have access to objective, high quality and timely data
- scrutinise pupil progress, attainment and financial information, comparing these with local and national benchmarks over time
- monitor and oversee school improvement and financial health
- know the questions that need to be asked of the executive leadership team
- put in place an external audit of finances and strategic priorities
Accountability in a trust also involves compliance with statutory and contractual requirements, across a range of areas, through adherence with:
- the trust’s funding agreement and articles of association
- the Academy Trust Handbook
- charity and company law
- The Education (Independent School Standards) Regulations (2014) and any other applicable education, employment and health and safety legislation
- conditions and obligations imposed by funding or regulatory bodies
- keeping children safe in education, relating to safeguarding and safer recruitment
- the Equality Act 2010, including the public sector equality duty, as set out in section 149 of the Equality Act – trusts must actively promote equality and diversity as public authorities
- legal duties in religious measures and laws where applicable, for example the Church of England Diocesan Boards of Education Measure 2021 and Catholic Canon Law
The board is also accountable for:
- effective planning to ensure key duties, such as special educational needs and disabilities, and ensuring inclusion are undertaken effectively across the trust
- overseeing and monitoring the impact of pupil premium and other targeted funding stream conditions
Find out more about accountability from:
- statutory policies for schools and academy trusts
- the academies planning calendar
- the assurance framework for trust governance from Confederation of School Trusts.
6.2.1 Rigorous analysis of education data
An effective board will:
- have at least one person with the skills to interpret the full detail of educational performance data and ensure the board has a correct understanding of the trust’s educational performance
- understand the limitations of performance data, including being clear about what the data implies
- have access to objective, high quality and timely data and know the questions that need to be asked of executive leaders
- identify issues of priority that need to be addressed and discussed
- seek explanations from executive leaders where performance is below expectations
Find out more about analysing your data from:
- Understanding your data: a guide for school governors and trustees, which includes pointers to areas of questioning
- Making data work: teacher workload advisory group
- Eliminating unnecessary workload associated with data management
6.2.2 Sources of education data
The executive leadership team helps the board access:
- data published by the Department for Education (DfE) and Ofsted
- management information
- information on priorities for improvement
The executive leadership team is not the only source of information – the board can commission or request audit reviews from external partners.
The board:
- agrees with the senior executive leader how data will be provided – this will help the board stay focused on its strategic functions, while being mindful of staff workload
- identifies ways to validate and cross-reference the data provided by the executive leadership
Find out more about understanding and analysing school performance from:
- School and college performance measures – guidance and tools to help boards understand and analyse trust performance
- performance tables – check your trust and other trust’s performance data
- MAT performance measures statistical data release – performance data (key stages 2, 4 and 5) for MATs and sponsors
The trust’s DfE Sign-in approver can provide the board with a trustee account for:
- Analyse School Performance (ASP) – boards can look into their academy’s performance and identify its strengths and weaknesses, and trustees who lead on attainment data can analyse the ASP full report
- Ofsted Inspection Data Summary Report (IDSR) – also covers 16 to 18 provision and includes key stage 5 data
The board must:
- oversee financial performance
- ensure public money is well spent
- sign off the annual accounts
A trust’s significant level of autonomy makes it important for the board to consider the regularity, propriety and value for money of trust business.
Trusts must comply with the Academy Trust Handbook as a condition of their funding agreement, including the requirements on related party transactions and executive salaries.
Trustees must take ownership of the trust’s financial sustainability and ability to operate as a going concern.
The board should have at least one trustee with relevant financial skills and experience, who can fully interrogate detailed financial data and who:
- builds a relationship with the school business professional responsible for finance, such as the chief financial officer, finance director, finance manager
- acts as the link between the school business professional and the board
- ensures the board has a correct understanding of the trust’s finances and financial performance
It is important that everyone on the board has a basic understanding of the financial cycle, legal requirements on accountability and spend and an oversight of the trust’s spending.
The board must:
- use the school resource management self-assessment checklist to ensure its trust is meeting the right standards to achieve good financial health and resource management
- submit the trust’s checklist online to the Education and Skills Funding Agency (ESFA), through a link on the page
- complete the dashboard on the schools financial benchmarking website
Find out more about financial management for trusts from:
- Academy Trust Handbook
- Operating an academy trust as a going concern, from the Education and Skills Funding Agency
- School resource management: top 10 planning checks for governors
6.3.1 Sources of financial data and tools
Boards can use the following financial tools to help achieve value for money:
- School resource management – information, tools, training, guidance and a YouTube playlist to help schools and trusts save money on day-to-day costs
- Integrated curriculum and financial planning (ICFP) – tools and training to helps trusts plan the best curriculum for their pupils with the funding they have available
- Schools financial benchmarking website – includes a dashboard to compare school data to statistics thresholds that DfE has identified as indicators of good resource management and outcomes
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View my financial insights (VMFI) – a benchmarking tool which:
- trusts and local authorities access through an IDAMS account
- academies access through a DfE Sign-In account
- any users within trusts, such as school business managers, senior leaders, and governors or trustees, can access
- School resource management: top 10 planning checks for governors – checks for trusts to use early in the annual budget planning cycle and when looking ahead at the 3 to 5-year position
Guidance is available on:
Managing risk is essential to ensure the trust is meeting its key objectives and to protect its funds and assets.
The requirement for the board to appoint the audit and risk committee is set out in the Academy Trust Handbook (section 3.6).
The board must take a whole trust approach to making sure risk assessments are in place to safeguard and promote pupils’ and staff welfare.
Further information on basic control principles is outlined in the Academy Trust Handbook (sections 2.6 and 2.7).
The board must establish policies and procedures that support the independent and effective use of internal and external audit functions, including reporting arrangements.
Find out more about risk management from:
- ESFA: academy trust risk management guidance
- the sector-led academy trust governance code: principle 4: Decision-making, risk and control
Conflicts of interest must be avoided or managed.
The Academy Trust Handbook (sections 2.25, 5.36, 5.38, 5.52) has useful information on avoiding conflicts of interest.
The Charity Commission’s guidance on Conflicts of interest: a guide for charity trustees (CC29) and the academy trust governance code principle 3: Integrity are also useful sources of information.
For information on related party transactions read:
- Academy Trust Handbook (section 5) for more information
- guidance for academy trusts declaring or seeking approval for related party transactions
6.6.1 Paying for goods and services
Boards may pay for goods and services, including those provided by trustees in line with their articles of association and the Academy Trust Handbook.
Where a trustee provides goods or services, they must not put themselves in a position where personal interests conflict with their governance duty unless they are authorised to provide the goods or services and, therefore, they must declare their interest.
If a conflict exists, the board must:
- be assured that receiving the goods or services is in the best interest of the trust and will help it achieve its purposes
- manage, and be seen to manage, the conflict
- be open and accountable
- consider the advantages and disadvantages of using the goods and services
Section 6.5 covers how to manage conflicts of interest.
Use the guidance on disclosure in DfE’s Academy Trust Handbook (paragraphs 5.35-5.39).
Use the guidance on trustee expenses and payments to find out if a charity can pay trustees and what expenses they’re entitled to.
The board has legal responsibility for the trust’s actions. If trustees act reasonably in the course of their duties, they are generally protected from personal liability, with liability falling on the trust (company).
Trusts must have adequate insurance cover to comply with its legal obligations or be a member of the academies’ risk protection arrangement (RPA).
Articles of association provide a power for the trust to indemnify the trustees. Further information is available in the Academy Trust Handbook.