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Undertakings: Southern Water

Completion Date: 30/04/2025
Ref: SRN-2019-00008

WATER INDUSTRY ACT 1991 (AS AMENDED): SECTION 19(1)(b)

THE SECRETARY OF STATE FOR ENVIRONMENT, FOOD, AND RURAL AFFAIRS:

  1. is satisfied that Southern Water Service Ltd. “the Company” has contravened the Water Industry (Suppliers’ Information) Direction 2019 (subsequently referred to as the Direction). The information supplied has not met the requirements specified therein due to inaccurate and incomplete data submissions and is therefore in breach of section 202 of the Water Industry Act 1991 (as amended), (subsequently referred to as the Act).
  2. has notified Southern Water Services Ltd. on 03 December 2019 that the Secretary of State is considering making in relation to the Company an enforcement order under Section 18 of the Act.
  3. notes that Southern Water Services Ltd. has on 14 January 2020 given an undertaking under Section 19(1)(b)of the Act to take the following steps by the dates shown:

Steps to be taken:

(a) The company shall maintain the following measures.

Date: for the duration of the undertaking.

  1. Ensure monitoring of all critical information systems necessary to ensure compliance with the Regulations is carried out in line with the company schedules, implementing any revisions from step (b)1 as required.
  2. Ensure any new risks identified under (a)1 are dealt with in accordance with the reviewed risk methodology, developed under (b)3.
  3. Produce an accurate shortfall report of scheduled statutory water samples each month, to be reported to the drinking water quality regulator on or before the 7th day of each calendar month, in respect of samples taken during the penultimate month (for example, a report in March must be about the samples taken during the previous January).
  4. Ensure monitoring and sampling is undertaken in accordance with the Regulations and where any significant deviation occurs, the Drinking Water Inspectorate are informed.
  5. Ensure manual intervention, verification and validation of data continues in line with the company procedures, implementing any revisions, including those from step (b)2 as required.
  6. Conducting periodic audits, at a minimum frequency of quarterly, of all available data to examine accuracy of sample scheduling versus actual samples taken with regard to zonal samples and their locations (including change of locations), transcription errors, and chain of custody.

(b) The company shall review, revise and/or make operational the following measures by the dates specified.

  1. Review the schedule for monitoring of all critical information systems necessary to ensure compliance with the Regulations to ensure it is appropriate.
    Date: Complete
  2. Conduct a review of all procedures associated with manual intervention, verification and validation of data to determine whether they are fit for purpose;
    Date: Complete
    • develop an action plan to correct any that are not fit for purpose
      Date: Complete
  3. Review, define and document the risk methodology for the assessment of risks associated with data integrity or reporting.
    Date: Complete
  4. Develop a procedure to capture all changes to the operational water supply configurations that could potentially alter the annually predefined water supply zone boundaries and their asset linkages and ensure these are notified to the Water Quality and Compliance team immediately.
    Date: By 31 January 2020
  5. Conduct a review of water quality GIS data to identify and record where there are risks to the effective management of water quality and public health. An example of factors to be considered are:
    Date: By 31 October 2020
    • The accuracy of water quality data held.
    • The mechanism and timeliness of data transfer to the Labware and other water quality systems and the associated risks to the accuracy of sampling.
    • The risks of changing water supply zone boundaries during the year.
    • The accuracy of grid references used in site manuals.
    • The appropriateness of the governance and mechanisms for updating GIS data.
  6. Produce an action plan to address the risks identified in step (b)5.
    Date: By 31 January 2021
  7. Carry out reviews to identify the risks associated with the following areas;
    Date: By 31 March 2020
    • Water Supply Works online water quality monitoring instrumentation and other monitoring infrastructure
    • Water telemetry and SCADA systems
    • Network communications IT infrastructure
    • Core information management systems
    • Data and information management
  8. Using the information gathered in step (b)1, (b)5 and (b)7, produce an actionplan in the following areas requiring capability and technology improvements;
    Date: By 30 June 2020
    • End-to-end information management capabilities.
    • Enterprise Asset Management systems (EAM)
    • Data and Information management strategy
    • IT business continuity improvements
    • Integrated monitoring and control capabilities
    • Enterprise Geographical Information Systems (GIS)
  9. Implement a new Enterprise GIS solution which is fully integrated with the application estate to support Water quality processes.
    Date: By 31 March 2025
  10. Deliver the action plans developed in step (b)6, (b)8 and (b)9.
    Date: By 31 March 2025

(c) Auditing:

The company shall define a strategy for auditing the effectiveness of the measures made operational above, to include a monthly review of information management system operational performance. Any new risks identified through this auditing shall feed into a revision of the action plan defined in step (b)2, (b)8 and (b)10.
Date: By 30 April 2020 and updated as required

(d) Reporting:

At regular intervals provide the Drinking Water Inspectorate with reports on progress made with carrying out the steps set out in the Action Plans defined in (b)2, (b)6, (b)8 and (b)10. Provide details of any new findings relevant to this Undertaking, the results of subsequent actions and details of the mitigation measures implemented as well as an update on general progress.
Date: Annually, by 31 March each year for the duration of the undertaking

Additionally, reports should be submitted against the following milestones;

  1. Confirm that all operational changes to the water supply network that could potentially impact the annually predefined water supply zones boundaries are notified to the Water quality and Compliance team.
    Date: By 31 January 2020
  2. Provide a report confirming completion of the items highlighted in the FEO audit report, to include the improvement work on the GIS systems.
    Date: By 31 January 2021
  3. Provide a report detailing the audit strategy.
    Date: By 30 April 2020
  4. Provide a report detailing the review of water quality data in systems which hold GIS information.
    Date: By 31 July 2020
  5. Provide a report detailing the outcome of the end to end risk based reviews set out in 4(b)5 and 4(b)7.
    Date: By 31 July 2020
  6. Provide a report confirming completion of the measures outlined in (b).
    Date: By 30 April 2025

(e)

Provide a report confirming completion of the project and demonstrating the benefit of the actions taken in step (b).
Date: By 30 April 2026

  1. is satisfied that Southern Water Service Ltd has given and is complying with an undertaking to take all such steps as appear to the Secretary of State for the time being to be appropriate to secure or facilitate compliance with the requirements of Water Industry (Suppliers’ Information) Direction 2019.

Authorised by the Secretary of State to sign in that behalf
Milo Purcell
Deputy Chief Inspector
Drinking Water Inspectorate
DWI Ref No: SRN-2019-00008
17 January 2020