Southern Water Services Limited – Regulatory Compliance

Water Industry Act 1991 (as amended) (“the Act”): Section 19(1)(b)

Reference: SRN-2019-00008

Acceptance Notice:

The Drinking Water Inspectorate, on behalf of the Secretary of State for Environment, Food, and Rural Affairs:

1. Is satisfied that Southern Water Services 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 the company on 3 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 the company has on 15 August 2025 given a new undertaking under Section 19 (1) (b) of the Act, to take the following steps by the dates shown.

Steps to be taken:

1. The company shall maintain the following measures for the duration of the undertaking.
2. Ensure monitoring of all critical information systems necessary to ensure compliance with the Regulations are carried out in line with the company schedules, implementing any revisions from step 4(b)i as required.
   Date: For the duration of the Undertaking.
3. Ensure any new risks identified under 4(a)(i) are dealt with in accordance to the reviewed risk methodology, developed under 4(b)iii.
   Date: For the duration of the Undertaking.
4. Produce an accurate shortfall 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 regarding samples taken during the penultimate month (for example, a report in March must be about the samples taken during the previous January).
   Date: For the duration of the Undertaking.
5. Ensure monitoring and sampling is undertaken in accordance with the Regulations and where any significant deviation occurs the Drinking Water Inspectorate are informed.
   Date: For the duration of the Undertaking.
6. Ensure manual intervention, verification and validation of data continues in line with the company procedures, implementing any revisions, including those from step 4(b)ii as required.
   Date: For the duration of the Undertaking.
7. 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.
   Date: For the duration of the Undertaking.
8. The company shall review, revise and/or make operational the following measures by the dates specified.
9. Review the schedule for monitoring of all critical information systems necessary to ensure compliance with the Regulations to ensure it is appropriate.
   Date: Complete.
10. a) Conduct a review of all procedures associated with manual intervention, verification and validation of data to determine whether they are fit for purpose;
    b) develop an action plan to correct any that are not fit for purpose.
    Date: Complete.
11. Review, define and document the risk methodology for the assessment of risks associated with data integrity or reporting.
    Date: Complete.
12. 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: Complete.
13. 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:
    1. The accuracy of water quality data held.
    2. The mechanism and timeliness of data transfer to the Labware and other water quality systems and the associated risks to the accuracy of sampling.
    3. The risk of changing water supply zone boundaries during the year.
    4. The accuracy of grid references used in site manuals.
    5. The appropriateness of the governance and mechanisms for updating GIS data.
       Date: Complete.
14. Produce an action plan to address the risks identified in step (b)v.
    Date: Complete.
15. Carry out reviews to identify the risks associated with the following areas:
    1. Water Supply Works online water quality monitoring instrumentation and other monitoring infrastructure.
    2. Water telemetry and SCADA systems.
    3. Network communications IT infrastructure.
    4. Core information management systems.
    5. Data and information management.
       Date: Complete.
16. Using the information gathered in step (b)i, (b)v and (b)vii, produce an action plan in the following areas requiring capability and technology improvements:
    1. End-to-end information management capabilities.
    2. Enterprise Asset Management systems (EAM)
    3. Data and Information management strategy.
    4. IT business continuity improvements.
    5. Integrated monitoring and control capabilities.
    6. Enterprise Geographical Information Systems (GIS).
       Date: Complete.
17. Implement a new Enterprise GIS solution which is fully integrated with the application estate to support Water Quality processes.
    Date: 30 July 2025.
18. Deliver the action plans developed in step (b)vi, (b)viii and (b)ix incrementally.
    Date: 31 December 2025.
19. 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)ii.
    Date: by 30 April 2020 and updated as required.
20. Reporting:

Annually provide DWI with a report on progress made with carrying out the steps set out in the Action Plans defined in (b)ii, (b)vi, (b)viii and (b)x. 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.
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: Complete.
2. Provide a report confirming the completion of the items highlighted in the FEO audit report to include the improvement work on the GIS systems.
   Date: Complete.
3. Provide a report detailing the audit strategy.
   Date: Complete.
4. Provide a report detailing the review of water quality data in systems which hold GIS information.
   Date: Complete.
5. Provide a report detailing the outcome of the end-to-end risk-based reviews set out in 4(b)v and 4(b)vii.
   Date: Complete.
6. Provide a report confirming completion of the measures outlined in (b).
   Date: 31 January 2026.
7. Provide a report confirming completion of the project and demonstrating the benefit of the actions taken in step (b).
   Date: 31 December 2026.

5. Further Details of this Acceptance Notice:

The Secretary of State is satisfied that Southern Water Services 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 requirement of regulation 4(2)(c) of the Water Supply (Water Quality) Regulations 2016 (as amended).

Authorised by the Secretary of State to sign in that behalf

 

Nicholas Adjei
Deputy Chief Inspector, Drinking Water Inspectorate
19 August 2025.
Reference: SRN-2019-00008