Bristol Water's Assurance Plan 2019/2020 - Information for our customers and stakeholders on our approach to assurance and on ensuring the data ...
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Bristol Water’s Assurance Plan 2019/2020 Information for our customers and stakeholders on our approach to assurance and on ensuring the data and information we report and publish on is reliable and accurate.
CONTENTS Executive Summary...........................................................................................................................................2 Introduction..........................................................................................................................................................5 1. About Bristol Water..........................................................................................................................................5 2. About this document – Our Assurance Plan........................................................................................6 3. Regulatory Requirements.............................................................................................................................9 Our approach to assurance.............................................................................................................................12 4. Taking into Account Regulatory, Stakeholder and Customer Feedback....................................12 5. Targeted Assurance Activities..................................................................................................................15 What this means for our Customers and Stakeholders........................................................................34 6. Governance, Oversight & Culture............................................................................................................34 7. Assurance in the Round.............................................................................................................................35 8. Our Promise – How we propose to move out of Prescribed Assurance......................................37 Glossary...............................................................................................................................................................38 Appendix 1 – Independent Assurance.......................................................................................................40 Appendix 2 – Data Items’ Risk Assessments..........................................................................................43 Appendix 3 – Company Monitoring Framework Assessment 2018................................................49
EXECUTIVE SUMMARY
This document is Bristol Water’s Assurance Plan, which sets out our
approach to assurance of the information that we will publish during
2019/20. The purpose of our Assurance Plan is to give customers and
others with an interest in our business (known as stakeholders) trust
and confidence in our data and in how we use this data to report on
our performance. It covers all the key information that Bristol Water
reports and publishes throughout 2019/20. This includes information
reported for regulatory purposes and that produced for the benefit
of customers.
OVERVIEW Bristol Water takes the trust and • We have updated the interactive
confidence of customers and performance graphic on our
stakeholders in our data very website, to include information
seriously. It is our intention included in the mid-year
that by publishing transparent, performance report, as well
accurate and reliable information, as adding information on our
through the processes set out in customers’ average bill.
our Assurance Plan, that we will
demonstrate compliance with • We have continued to ‘dual
our assurance requirements. Our report’ our leakage performance,
ambition is to ensure that all of and its impact on per capita
the information we communicate consumption for 2015-20 so the
externally is assured to be impact of technical improvements
accurate, timely, appropriate to the way leakage is calculated
for the intended audience and is transparent. Our mid-year
transparent. Changes that we have performance report included this
made to deliver on this ambition data for the first half of 2018/19.
within the past year include:
• Our tariff and charges
• We have again published a publications (particularly for new
mid-year performance report1. connections charges) now include
This provides an update on more customer-friendly language
performance for a number of data and user-friendly graphics, to
items, comparative information improve their readability for
on our performance and forecasts interested parties. Our Statement
of our future performance, (we will of Assurance2 on our tariffs also
also follow this approach for our now includes an engagement
annual performance reporting), as summary section, setting out the
well as: organisations we have consulted
and what changes we have made
1. A statement from our Chief to the information we present as a
Executive Officer; result.
2. A statement from the Bristol
Water Challenge Panel; • Improvements to the format
3. A statement from our and contents of our Annual
independent technical assurer, Performance Report and
Atkins, that our description Data Assurance Summary,
of performance is fair and which makes it easier for our
reasonable. customers and stakeholders
1
Bristol Water Mid-Year Performance Report 2018/19
2
Charges in Detail
2
to find information, so that This document provides the following
our performance against our
Assurance Plan is transparent.
The targeted areas of
An overview of the assurance that were
• In addition to the Risk & companies’ assurance
Compliance Statement, our identified in our Statement
methods and processes. of Risks, Strengths and
Board is also committed to
publishing our ‘Trust beyond Weaknesses exercise.
water’ statement, which goes
beyond the legal and statutory
commitments. The statement
reflects on the Board’s views An update on feedback we
Our plans for addressing
on our operational and have received from our
the risks in the targeted
financial performance, customers and stakeholders
areas of assurance.
assurance activities and long- on our assurance plans.
term strategy.
This document should be read in conjunction with the Statement of Risks, Strengths and Weaknesses of
Information 2018/193.
ASSURANCE PLAN This Assurance Plan covers backed dashboard designed to
information reported within: provide accessible comparative
information for customers and
1. 2018/19 Annual Performance stakeholders
Report (including our regulatory
accounts and our 2015-2020 We have undertaken an internal
performance commitments) and risk assessment to determine
2019/20 Mid-Year Performance which data items we report on in
Report the documents and sources in the
2. 2018/19 Annual Report list above are at risk of inaccurate
(including our statutory accounts) reporting. Since the publication
3. 2020/21 Wholesale and Retail of these risk assessments in our
Charges Schedule, Charging Statement of Risks, Strengths
Arrangements and Charges and Weaknesses of Information
Schemes consultation in November
4. 2018/19 Guaranteed Standards 2018 we have now reviewed
Scheme (GSS) payments our assessments and provided
5. Data on New Connections and updated view as part of
performance this Assurance Plan. We have
6. Complaints reporting to therefore identified fifteen (15)
CCWater data items that require targeted
7. Water quality information assurance activities throughout
provided to the Drinking Water the year ahead.
Inspectorate
8. Information provided to Our detailed risk assessment
the Environment Agency methodology can be found in our
(including our Water Resources Statement of Risks, Strengths
Management Plan and Market and Weaknesses of Information
Information) document. However, in summary,
9. Data reporting for non- to be identified as either a high
household competition, reported or critical risk and therefore to
to MOSL be included within the targeted
10. Data provided to the Discover assurance activities, a data item
Water website, an industry- must reflect one of the following:
3
Statement of Risks, Strengths and Weaknesses of Information 2018/19
3
High probability of inaccurate reporting
Complexity of data sources
Completeness of data set
Extent of manual intervention in data
Complexity and maturity of reporting rules
Weak control framework
Level of control activities
Experience of personnel reporting
Evidence of historical errors with data
High impact if risk materialises
On customers
On Company reputation
Strength of Outcome Delivery Incentive (in terms of its reputational or financial impact)
Used as industry comparator
The Company has a strong • Prioritising data items and
control framework in place for the areas of reporting that have been
majority of data items we report identified by Ofwat and other
on, which helps to mitigate the regulators as areas of assurance
probability of inaccurate reporting or transparency of reporting risk
from occurring. However, even compared to other companies.
with a strong control framework
we have a number of the items We are continually adapting our
within the high risk category. This practices to address areas of
has been caused by a range of data accuracy and transparency
factors, including: concerns and we know that to
improve our assurance status
• Recognising the ‘impact’ of we have to do more than just
the risk of inaccurate reporting meet Ofwat’s expectations,
(regardless of the probability of it but to exceed the regulator’s
taking place) and reflecting this expectations by a clear margin, in
impact in our risk assessment. particular showing how we will
boost trust and confidence in the
• Our independent technical Company and in the sector, by the
assuror, Atkins’, reports’ for 2017/18 activities that we undertake.
year-end and 2018/19 mid-year
of our performance commitment By demonstrating that we have
methodologies and data, which a thorough system of controls
has helped identify potential (both internally and externally) to
weaknesses promptly. make sure that the information
we report and publish achieves a
• The inclusion of new data items, high level of accuracy, our aim is
some of which the Company to help build trust and confidence
has little evidence of data or in Bristol Water and the wider
experience in collating data for. water sector.
4
INTRODUCTION
1. ABOUT BRISTOL WATER Bristol Water is a water supply private water company in 1846 and
company, responsible for the has continued in this role ever since.
provision of water to 1.2 million Parts of our network still date from
people in the city of Bristol and these early days. Our original aim
surrounding area. then, as it is today, was to supply good
clean drinking water with a high
Our vision is to meet our customers’ quality service and that is value for
expectations by providing an money. We provide excellent quality
outstanding water service in a of water, and some of the lowest
sustainable and affordable way. levels of leakage in the country.
We are one of 17 companies in In 2014 we published a business plan
England and Wales who distribute setting out our priorities for 2015-20.
water and Bristol Water is one of six This included a number of key aims
that focuses exclusively on water, and outcomes that we want to deliver
not waste water. In our supply area, for our customers and stakeholders.
waste water services are provided by We published a revised strategy and
Wessex Water. business plan with an updated set of
performance commitments in 2018,
Bristol Water was founded as a which will apply from 2020-25.
performance in 2017/18. Bristol Water with a certificate4, in
acknowledgement of:
Over the last couple of years • Participating in the programme
Bristol Water has participated for at least two consecutive
in the European Benchmarking benchmarking cycles.
Co-operation (EBC), a water
industry-based, not-for-profit • Providing timely and good quality
benchmarking exercise on costs, data.
performance and asset base.
In our mid-year performance Benchmarking is most effective • Participating actively in the
report, published in December if we can use the lessons learned programme, in particular by
2018, we set out our performance from the exercise to improve our attending the annual benchmarking
to date in 2015-18, and included own performance and data quality. workshop and presenting our data at
comparisons to other companies’ The EBC Foundation has awarded the workshop.
4
Further information about this certificate can be found on the website of EBC Foundation
5
2. ABOUT THIS We regularly publish information Scheme (GSS) payments
on our performance to 5. Data on performance on New
DOCUMENT – demonstrate to customers, Connections, reported via Water UK
OUR ASSURANCE PLAN stakeholders and our regulators 6. Complaints reporting to CCWater
that we are delivering the 7. Water quality information provided
services expected of us. This to the Drinking Water Inspectorate
data has been risk assessed 8. Information provided to the
to determine the likelihood of Environment Agency (including our
inaccurate reporting. If we are Water Resources Management Plan
well prepared, and have systems and Market Information)
and controls in place to prevent 9. Data reporting for non-household
inaccurate reporting of data and competition, reported to the market
information from happening, it operator MOSL
is less likely that things could 10. Data provided to the Discover
go wrong for our customers. Water website, an industry-backed
Getting this right first time will dashboard designed to provide
improve our customers’ trust and accessible comparative information
confidence in the Company and for customers and stakeholders
in the water sector. Specifically,
This document is known as this Assurance Plan covers A more detailed explanation of
Bristol Water’s Assurance Plan. It information reported on for the what these items cover can be
sets out our proposed approach to following: found in the glossary section of
assurance of the information that this document. In summary, this
we will publish during 2019/20. 1. 2018/19 Annual Performance document provides assurance that
The purpose of our Assurance Report (including our regulatory we:
Plan is to give customers and accounts and our 2015-2020
others with an interest in our performance commitments) and • Have processes and procedures
business (known as stakeholders) 2019/20 Mid-Year Performance in place to reduce the risk of
trust and confidence in how Report inaccurate or incomplete reporting.
we report on our performance. 2. 2018/19 Annual Report (including
By publishing this information our statutory accounts) • Are dealing appropriately
annually, we are also ensuring 3. 2020/21 Wholesale and Retail with any risks and weaknesses
that the economic regulator of Charges Schedule, Charging identified in our Statement of
the water sector, Ofwat, will have Arrangements and Charges Risks, Strengths and Weaknesses
confidence in our assurance Schemes of Information, by undertaking
activities (section 3). 4. 2018/19 Guaranteed Standards targeted assurance activities.
Specifically, we will do the following to inform customers of our performance in a way that increases their
trust and confidence in us and in the information that we publish:
Report accurate, reliable information and, where we identify any issues, we will:
Deal with the issue in a timely way
Involve customers, stakeholders and the Bristol Water Challenge Panel; and
Review our risks and Assurance Plans continuously and make sure they reduce the effects of any
areas of concern.
If we are at risk of failing to meet our performance commitments, we will:
Be open about the issue;
Give customers and stakeholders a clear explanation of the issue; and
Explain how we will deal with the issue.
6
This document should be read in • Independent Assurance
conjunction with our consultation Assessments and Regulatory
document on the Statement of Feedback:
Risks, Strengths and Weaknesses 1. We are required to incorporate
of Information 2018/19. independent external assurance
as part of our assurance plans. In
In common with other water addition to the requisite statutory
companies in England and audit and assurance role, we
Wales, we carry out an annual employ external auditors to audit
Risks, Strengths and Weaknesses and assure our key financial and
exercise with stakeholders, to non-financial information. We set
highlight the areas that require out in appendix 1 the role that both
‘targeted’ assurance; the areas our independent technical assurer,
that have the most significance Atkins, and our financial auditors,
to customers and stakeholders, PwC, will play in assurance of our
due to their impact on them, or key submissions
for those that have the greatest 2. We prioritise data items and data
probability of a risk of inaccurate reporting that have been queried
reporting materialising. The by Ofwat, and aim to exceed these
exercise provides details of our minimum expectations for data
methodology for identifying accuracy and transparency in
any risks that may materialise. areas that are most important to
As figure 1 demonstrates, the trust and confidence in our data
Statement takes into account and performance.
various factors when determining
the risk ratings for the data items • External Engagement:
the Company reports on, including: 1. Customer and stakeholder
feedback to the Statement of
• Company Risk Assessment: Risks, Strengths and Weaknesses
1. The Company risk assessment consultation on whether they
has been carried out by the team agree with the Company’s
in Bristol Water responsible assessments
for reporting information to 2. Feedback from the Bristol Water
customers, regulators and Challenge Panel
stakeholders. This team has 3. Feedback from other
detailed knowledge of our stakeholders to our published
reporting processes and consultations
requirements, and the control
Figure 1 – Factors to determine framework in place for assurance We also publish all of our latest
data items’ risk assessments of our information. assurance plans6 on our website
2. The team has examined the ahead of reporting to encourage
inherent probability of inaccurate input from our customers.
reporting this information, the
strength of the control framework We published a consultation on our
we have in place to mitigate this Risks, Strengths and Weaknesses
risk and the potential impacts of exercise on 29 November 2018,
any errors. and sought the views of our
3. The methodology for stakeholders and customers. This
determining the risk was initially Assurance Plan incorporates the
based on the Data Assurance results of our consultation on
Guidance for Electricity and Gas that exercise, which concluded
Network Companies5, published by on 31 December 2018 as well as
Ofgem in February 2015, which we the results of our consultation on
amended to ensure it is relevant our draft Assurance Plan, which
for the key considerations in the concluded on 28 February 2019
Assessment of risk for each water industry. (section 4). Following the close
data item
5
Data Assurance Guidance for Electricity and Gas Network Companies
6
Bristol Water Performance
7
of these consultations, we have Report (APR). The APR will be and Weaknesses of Information)
analysed and updated the results published in July 2019, alongside we will demonstrate compliance
of our risk assessment (explained a statement of board compliance with our assurance requirements.
in appendix 2) and the controls we with its statutory and regulatory Compliance with our Assurance
had put in place to provide targeted obligations (known as the Risk Plan will be reviewed by Ofwat
assurance on our information & Compliance Statement) and in its Company Monitoring
that is most at risk of being a summary of the assurance Framework assessments (its
inaccurately reported (section 5). activities and improvements latest assessment can be found
We will set out the level of internal undertaken throughout the year in appendix 3), our Board (in its
and external assurance that we (known as the Data Assurance Risk and Compliance Statement
propose to apply to each piece of Summary). 2018/19) and the Bristol Water
information within this document Challenge Panel (in its Annual
and what these assurance It is our intention that by Report 2018/19). The milestones the
activities mean for our customers publishing transparent, accurate company will meet as
(section 7). and reliable information through part of this assurance framework is
this Assurance Plan (which has below.
The feedback we have received been aided by the identification
will assist our assurance activities, of the data items most at risk
in advance of the publication of inaccurate reporting via our
of our Annual Performance Statement of Risks, Strengths
Date Published as a
Document Publisher
published by consultation
Draft Assurance Plan 31 January 2019 Bristol Water √
Assessment of Company Monitoring
Framework 2018
31 January 2019 Ofwat
X
Final Assurance Plan
(This Document)
31 March 2019 Bristol Water
X
Annual Performance Report, Data
Assurance Summary and Risk &
Compliance Statement
15 July 2019 Bristol Water
X
Statement of Risks, Strengths and
Weaknesses of Information
30 November 2019 Bristol Water
√
X
Assessment of Company Late 2019/ Early Ofwat
Monitoring Framework 2019 2020 (TBC)
If Ofwat considers that we have not met the requirements of our assurance plan it may intervene to prescribe a
greater level of assurance to be applied in future. It may also apply other regulatory remedies, including finan-
cial penalties if it deems that to be appropriate.
8
3. REGULATORY In June 2015 Ofwat published a provided for the PR14 business
Company Monitoring Framework7, plan and CMA reference.
REQUIREMENTS which set out how it intended
to oversee the information that We had remained in the
water companies in England and prescribed category in the
Wales provide to their customers assessments undertaken since
and stakeholders. Ofwat expects the first assessments made in
companies to be transparent 2015 (with the other assessments
and to provide information that being undertaken in November
enables them to understand how 2016 and November 2017). However
the Company is performing. This in January 20198, Ofwat announced
framework is intended to provide that it was moving Bristol Water to
customers and stakeholders with the targeted category of assurance.
confidence in the information that Ofwat noted:
companies produce, and allow Ofwat
to take action where it feels that its ‘The company has demonstrated
requirements are not being met. that it has acted upon feedback
that we provided, and has made
The framework sets out the significant improvements from
different levels of assurance the previous year. It has exceeded
to support the information we our expectations for the risk and
publish, depending on Ofwat’s compliance statement and met
confidence in the quality of the our expectations in all but three
information that companies of the other specific assessments
produce. Companies are areas (financial flows, financial
categorised as ‘self-assurance’ monitoring framework and
where Ofwat has given the charges engagement).
most discretion to decide what
assurance is needed above ‘The company has met the
the minimum required, and requirements for being promoted
have the most trust from the to the targeted assurance
Figure 2 – Ofwat’s Categories
regulator. Ofwat categorises category. It has not shown
of Assurance
companies as ‘targeted’ where evidence of behaviour that leads
it considers companies have to a reduction in the trust and
not consistently met the high confidence stakeholders can place
standards customers and other in it. It has had no significant
SELF-ASSURANCE
stakeholders expect. Ofwat problems with its assurance plan
categorises companies as and has been in the prescribed
‘prescribed’ where companies category for at least 12 months.
have not provided them with Companies in the prescribed
sufficient confidence in their assurance category in the
ability to deliver, monitor and previous year can only move up to
report performance. Companies the targeted category in one year”
within the prescribed category
TARGETED ASSURANCE
of assurance are therefore those Ofwat’s latest assessments of the
that Ofwat has the lowest level of Company’s performance in the
trust in to publish accurate data Company Monitoring Framework
and information. and our plans for improvements
can be found in appendix 3.
In November 2015, Ofwat As a ‘targeted’ company we
informed Bristol Water that it are required to undertake the
intended to move the company activities listed below. These
PRESCRIBED ASSURANCE
into the ‘prescribed’ category are set within the context of the
of assurance, citing concerns requirements for the other two
with the quality of our evidence categories of assessment.
All companies in the prescribed assurance band are required to undertake the requirements identified in figure
3 (next page).
7
Company monitoring framework – final position
8
Company monitoring framework: 2018 assessment – Individual company report – Bristol Water
9Assurance Category Assurance Requirements
Alongside each set of information they provide, the Boards of these
water companies must provide:
Self-Assurance • explicit sign off on the assurance that they are providing;
• full transparency on the audit procedures; and a summary of the
outcome of the assurance that their company has carried out.
In addition to meeting the requirements for the self-assurance category,
companies in the targeted category are required to:
• carry out an exercise with stakeholders to target issues to address (the
statement of risks, strengths and weaknesses exercise); and
Targeted Assurance • publish a statement on this in the autumn of each year in advance of
submitting information. For issues a company targets, they are required
to publish draft Assurance Plan and speak with and listen to stakeholders
before confirming final Assurance Plans, but only in these targeted areas.
In addition to meeting the requirements of self-assurance and
targeted categories, companies in the prescribed category are required
to publish their assurance plans for all information in advance of
reporting. This is so that stakeholders (including Ofwat) can gain
confidence and, if necessary, provide comments or guidance that
the company would need to respond to. The risks, strengths and
Prescribed Assurance
weaknesses exercise that a prescribed company carries out (this
document) must highlight the areas of reporting that have the most
significance or are of greatest risk to customers (the ‘targeted’ areas).
For these areas the company must incorporate independent external
assurance as part of its assurance plans.
Figure 3 – Targeted Assurance Requirements
Incorporate independent external assurance (provided by Atkins and PwC).
Identify the risks, strengths and weaknesses in providing the quality of information that
stakeholders want and trust and highlight the areas that have the greatest risk to customers.
Publish a Risks, Strengths and Weaknesses Statement on this as a consultation in the autumn
of each year (this was published in November 2018).
Consult on a Draft Assurance Plan to ensure that it is sufficient to address the issues identified
in the Strengths, Risks and Weaknesses statement.
Publish a final Assurance Plan, so that stakeholders can gain trust and confidence in all the
key information that Bristol Water reports and publishes throughout 2019/20.
10The table below presents an overall comparison of the previous annual assessments Ofwat has taken to date
since the Company Monitoring Framework was introduced.
2016 2017 2018
Area of Assessment
Assessment Assessment Assessment
Financial Monitoring
Meets expectations Meets expectations Minor concerns
Framework
Charges schemes assurance/
Meets expectations Meets expectations Minor concerns
Charges engagement
Financial Information Meets expectations Not Included Not Included
Final 2010-15 reconciliation Meets expectations Not Included Not Included
data submission
Outcomes Meets expectations Serious Concerns Meets expectations
Compliance with principles
of board leadership, Meets expectations Meets expectations Not Included
transparency and governance
Water resources management
Not included Not included Meets expectations
plan and market information
Long-term viability statement Not included Not included Meets expectations
Financial flows Not included Not included Minor concerns
Risk and compliance Meets expectations Meets expectations Exceeds expectations
statement
Assurance plan Minor concerns Meets expectations Meets expectations
Targeted reviews Minor concerns Not included Not included
Data assurance summary Minor concerns Minor concerns Not included
Cost assessment Not included Not included Meets expectations
Casework Minor concerns Minor concerns Meets expectations
PR19 initial assessment
of business plans – Not included Not included Meets expectations
data consistency
PR19 initial assessment of Not included Not included Meets expectations
business plans – data quality
Wider assurance and
Not included No issues No issues
information
This document is intended to meet or exceed the expectations of Ofwat’s Company Monitoring Framework,
and we have welcomed the opportunity to use this exercise as the basis for additional engagement with our
customers and other stakeholders.
11OUR APPROACH TO ASSURANCE
4. TAKING INTO We provided details of our 2017/18 We received one response to the
performance to a meeting of Statement of Risks consultation;
ACCOUNT REGULATORY, the BWCP on 9 July 2018. This from a member from the
STAKEHOLDER AND meeting was also attended by BWCP. We have reviewed and
CUSTOMER FEEDBACK our technical reporter from incorporated the suggestions
Atkins, who gave details of the provided as appropriate.
We have consulted our customers assurance assessment on each
and key stakeholders in two outcome. A further meeting of Since the publication of our
phases. The first phase was on the BWCP was convened on 12 Statement of Risks, Strengths
our Statement of Risks, Strengths December 2018 to review our and Weaknesses of Information
and Weaknesses of Information, mid-year performance, assurance 2018/19 we have taken into
which we published on 29 framework and progress against consideration all the factors
November 2018. The consultation actions raised from year end that determine our data items’
closed on 31 December 2018. reporting. risk assessments (as explained
We invited comments through in section 2). In our initial
publishing the document on our The results of our risk risk assessment, which was
website and by advertising the assessments on our reported data published in our Statement of
consultation on social media, items can be found in appendix Risks, Strengths and Weaknesses
particularly via Twitter and 2 of this document. These have 2018/19, we identified seventeen
LinkedIn. We also presented our been updated to reflect the (17) data items at either a high
risk assessment methodology feedback we have received as a or critical risk of inaccurate
and results to our Board, result of the Statement of Risk reporting and therefore had been
including to our independent consultation and based on the identified as requiring targeted
non-executive directors, and comments Ofwat made as part assurance activities. The table
to a customer sub-group of our of the 2018 assessment of the below presents the risk items that
Customer Challenge Panel, Company Monitoring Framework, have been updated in our risk
known as the BWCP, on 27 which was published at the end assessment, based on our final
November 2018. of January 2019. review of the risk assessments.
Initial Risk Factors Final Risk Factors
Assessment in considered in Assessment in considered
Data Item Risks, Strengths Initial Risk Assurance Plan in Final Risk
and Weaknesses Assessment 2019/20 Assessment
2018/19
Whilst this is a new
performance measure, this
New data item information has previously
Void included for been routinely collected and
Properties High this year’s Medium assured as part of annual
property count calculations
assessment
used to support other
performance measures.
measures.
As the Southern Resilience
To be Scheme that this
performance commitment
Population consistent with monitors has now been
at risk from High previous risk Medium completed, the assessment
asset failure assessments now reflects the lower
probability of inaccurately
reporting the remaining
population at risk.
12The second phase was on the Our posts were designed to We have reviewed and
approach undertaken in our encourage two way dialogue incorporated the suggestions
Assurance Plan, which we published with customers and to generate provided as appropriate; the
as a draft on 31 January. The exchanges on a variety of topics. feedback received related
consultation closed on 28 February We received two responses to the to technical revisions in the
2019. We again invited comments draft Assurance Plan consultation; document, particularly in regard
through publishing the document one from a member from the BWCP, to information in sections 5 and
on our website and by advertising writing in a personal capacity and 8, which the final version now
the consultation on social media, one from the Chair of the BWCP, addresses. The Chair of the BWCP
particularly via Twitter and LinkedIn. writing on behalf of all members. also noted:
‘The Bristol Water Challenge Panel is pleased to respond to the consultation by Bristol Water on its
Draft Assurance Plan. Since 31 January of this year, Bristol Water has been assessed as requiring to
provide ‘targeted assurance’ to the water regulator Ofwat. We congratulate Bristol Water on achieving
this promotion. We also welcome the level of detail in the Plan regarding how Bristol Water treats
its risks, strengths and weaknesses in the draft Plan which is in excess of that required by targeted
water companies. It is our expectation that Bristol Water, as a mark of transparency and openness,
will publish the detail contained in the Draft Assurance Plan.
‘As a Challenge Panel, we note that Bristol Water has a clear framework for assessing and categorising
information-reporting risk, that is has controls and mitigations to reduce such risk and that it has
identified the practices that must be improved in order to meet the requirements of Ofwat. We note
this level of openness and willingness to take on board queries, amendments and contributions from
customers, stakeholders and other partners creates trust and confidence in the company.
‘The bill payers of Bristol Water have expressed (through various and different customer research
projects) their wish to be educated, and to know more, about the water sector in general and Bristol
Water in particular. Bristol Water is stepping up to this challenge by improving the language its uses
to speak to customers, the production of colourful and informative graphics that interpret data as well
as by the increase in channels (such as its website and social media) by which it communicates. The
Challenge Panel has seen a step-change in such methods during this Asset Management Period and
the Draft Assurance Plan extends this practice further.’
Mrs Peaches Golding OBE
For and on behalf of the Bristol Water Challenge Panel
13We note the limited level of
customer engagement with our
Statement of Risks, Strengths and
Weaknesses and draft Assurance
Social Media Outreach
Plan consultations. Both were
published on our website and we
kept the consultations open for a
Two - the number of written responses to
number of weeks. We also actively
used social media to encourage a
the consultation
greater level of engagement with
our customers and stakeholders
(our social media outreach is
included in the graphic opposite). 2,430 - the number of impressions
Rather than a reflection on the
design of our consultations, we
feel that the low response rate is a
result of the technical content of
the exercise itself. Three - the number of likes
The low response rate also
reflects the experience of all
companies across the industry;
not surprisingly customers have 21 - the number of engagements
not shown a great deal of appetite
for engaging in the methodology
behind the risk assessments.
However, to help increase
awareness of assurance activities
identified we will continue to use
social media, including promotion
on Twitter and LinkedIn, in order
to encourage greater participation
in the process in future years.
145. TARGETED ASSURANCE Following our data items’ risks data to challenge the key data and
assessments, we set out in this assumptions made.
ACTIVITIES section the targeted assurance
activities which will be undertaken • Internal review and approval of
in the year ahead. These activities key data by Executive Management
will help to mitigate the most Team and the Board.
important risks. We have identified
fifteen (15) data items that require • External assurance of reporting
targeted assurance activities. These processes and data associated with
data items have been targeted for our Annual Performance Report, our
one of the following reasons: Regulatory Accounts, our Wholesale
and Retail Charges and Charges
• The risk of inaccurate reporting Scheme, our Guaranteed Standard
has significantly increased Scheme data and our data on
Data items that require compared to 2017/18, to the extent performance on new connections.
targeted assurance that the data item has deteriorated
activities. in its overall risk assessment i.e. it • Review and challenge of our
has moved from a ‘medium risk’ in performance (at both mid-year and
2017/18 to a ‘high risk’ in 2018/19. end-year) in 2018/19 against our
performance commitments by the
• The data item was reported as BWCP.
either ‘high’ or ‘critical risk’ in
2017/18 and has remained within • Review and challenge of our
either of these categories for performance by the CEO.
2018/19.
• Our internal audit programme
• The data item is a new reporting includes periodic reviews of the
requirement for 2018/19 and has governance process, including sign
been identified as either a ‘high’ or a off of data quality assurance forms
High impact if
risk materialises ‘critical’ risk. and compliance with governance
and approval methodologies.
Section 7 illustrates the
assurance activities we propose Our detailed risk assessment
to undertake for the data items methodology can be found in our
used in our published reports or Statement of Risks, Strengths
for our regulatory submissions. and Weaknesses of Information
High probability
of inaccurate
Weak control
framework
In summary the assurance will document. However, in summary,
reporting
comprise: to be identified as either a high
or critical risk and therefore to
• Internal governance and control be included within the targeted
of all information listed in this assurance activities, a data item
section, including peer review of must reflect one of the following:
High probability of inaccurate reporting
Complexity of data sources | Completeness of data set | Extent of manual intervention in data |
Complexity and maturity of reporting rules
Weak control framework
Level of control activities | Experience of personnel reporting |
Evidence of historical errors with data
High impact if risk materialises
On customers | On Company reputation | Strength of Outcome Delivery Incentive (in terms of its reputational
or financial impact) | Used as industry comparator
15The final risk assessment for all risk the transparency of our data and for some of our reported data.
items (found in appendix 2) reflects information, which are intended to However, we are seeking to continue
our ability to identify the potential increase the trust and confidence in to improve the assurance and
for errors and, if necessary, act which customers and stakeholders transparency of our reporting and
accordingly to address them. can place in our reports. see external assurance for our
targeted data items as an important
The additional targeted activities we Having been promoted from a part of this process, and as such
intend to undertake in response to prescribed to targeted assurance do not propose any changes to our
our risk assessment for specific data status in the 2018 CMF, we are approach to assurance of our data in
items are set out in the table below. no longer required to undertake 2019/20 in response to our change in
This includes steps taken to improve independent external assurance classification.
162017/18 Risk 2018/19 Risk Reason for 2018/19 Targeted Assurance Activity Identified for 2019/20
Data Item
Assessment Assessment Risk Assessment
This measure will replace the current measure, SIM, from 2020/21. Shadow
reporting will commence in 2019/20.
Internal Assurance
This data item will follow the same internal reporting requirements that
our other performance commitments follow, as outlined in our Statement
of Risks, Strengths and Weaknesses of Information. The data item will have
a specific owner and reviewer, responsible for production and updating
the reporting methodology statement. Data owners and reviewers are
required to provide signed confirmation that the data has been compiled
Customer measure in accordance with the relevant methodology, and that the data is a true
of experience N/A High New data item – affects representation of the facts. This form provides the opportunity for the data
(new data item) control framework owner and reviewer to identify any concerns with the quality of the data,
(C-MeX)
for investigation by senior managers and Directors. A data approver (the
Executive Director responsible for the area the data item relates to) then
approves the quality of the data, in consultation with Economic Regulation
team.
External Assurance
Our shadow data is to be externally audited in 2019/20 by our technical
assurer, Atkins. Their assurance approach is outlined in appendix 1.
Expected Outcome of Assurance Activities on 2019/20 Risk Assessment
As a result of our assurance activities, we anticipate that this will reduce to a
medium risk.
This measure comes into effect from 2020/21 with shadow reporting in
2019/20.
Internal Assurance
This data item will follow the same internal reporting requirements that our
Developer other performance commitments follow, as outlined in our Statement of
services measure N/A Risks, Strengths and Weaknesses of Information.
High New data item – affects
of experience (new data item) control framework External Assurance
(D-MeX) Our shadow data is to be externally audited in 2019/20 by our technical
assurer, Atkins. Their assurance approach is outlined in appendix 1.
Expected Outcome of Assurance Activities on 2019/20 Risk Assessment
Due to the complexities in data reporting, we do not anticipate that the risk
will reduce below a high risk.
172017/18 Risk 2018/19 Risk Reason for 2018/19 Targeted Assurance Activity Identified for 2019/20
Data Item
Assessment Assessment Risk Assessment
The risk of inaccurate reporting has increased for this data item, compared to last
year’s assessment.
Internal Assurance
An internal ‘action plan’ has been implemented to improve the logging of
unwanted calls. The plan was produced following the 2017/18 year-end audit and
updated following the 2018/19 mid-year audit by Atkins. In summary, Atkins has
identified two areas for improvement:
1. Data collation for risks and controls - relating to the collation of monthly data in
a central spreadsheet.
2. The accuracy of reporting of unwanted calls (which contributes to the
quantitative component of the SIM calculation, which is 25% of the overall score).
Data collation risks and controls
Steps have been implemented to reduce manual data entry by linking the
central spreadsheet used to the numerous contributory reports. Further work is
being undertaken now to simplify the spreadsheet, provide further tools for data
analysis and to automate data checks and data forecasting.
The accuracy of reporting of unwanted calls
In response to the initial findings from Atkins’ 2018/19 mid-year audit, a report has
been developed to split the call data logged by individual teams at Bristol Water.
Service Incentive Identified weaknesses in This allows control processes to be compared to the volume of calls logged on
Medium High
Mechanism (SIM) control framework our main database, to ensure that they are proportionate and accurate. Having
implemented this reporting procedure, our analysis shows that the vast majority
of logged unwanted calls (95%) are received via our operational customer support
team and are therefore subject to existing monthly controls activities, which
include call listening of a sample of calls by managers responsible for reviewing
the accuracy of the data logged.
We recognise that despite the relatively low call volumes received by the teams
outside of our operational customer support team (the remaining 5% of unwanted
calls), stronger control activities are required to ensure that these calls continue to
be logged accurately. As a result, call recording has now been introduced for our
metering, new supply and water regulation teams (which combined are c.4% of
logged unwanted calls). A weekly manager review of 10% of the calls is now being
undertaken for each team. There has also been an increased focus on training
since the 2017/18 audit to ensure that documented processes are being followed.
We have also allocated a member of staff to support the roll-out of assurance
across the other teams.
Our analysis suggests that the SIM score calculation is relatively insensitive to the
number of unwanted calls. Given the small proportion of calls received outside of
the operational customer support team, it is unlikely that under-reporting in these
other teams will have a material impact on the SIM score.
(continued on next page...)
182017/18 Risk 2018/19 Risk Reason for 2018/19 Targeted Assurance Activity Identified for 2019/20
Data Item
Assessment Assessment Risk Assessment
(continued from previous page...)
However, in recognition of the potential customer service impacts of unlogged
calls, we will continue to undertake the above processes to ensure that accurate
logging is being adhered to, without exception, by every team.
Service Incentive Performance information is also included in our interactive performance
High Identified weaknesses in
Medium graphic on our website.
Mechanism (SIM) control framework
External Assurance
The data item will continue to be audited by our technical assurer, Atkins. Their
assurance approach is outlined in appendix 1. The progress made as part of the
action plan outlined above will be included within the scope of the audit.
Expected Outcome of Assurance Activities on 2019/20 Risk Assessment
As a result of our assurance activities, we anticipate that this will reduce to a
medium risk.
Our reporting approach for our 2016/17 leakage data was highlighted in
Ofwat’s 2017 Company Monitoring Framework assessment (this contributed
to the regulator having ‘serious concerns’ about our outcome reporting).
Internal Assurance
Since that assessment we have agreed with the regulator to dual-report on
this performance commitment and provide thorough explanations behind
the methodologies undertaken within our in published reports (which we
have done as recently as the 2018/19 Mid-Year Performance Report). We will
High impact on continue to dual-report on this performance commitment until the end of
2019/20.
Leakage High High customers, stakeholders
or company reputation, if Performance information is also included in our interactive performance
risk materialises graphic on our website to aid transparency to customers.
External Assurance
The data item will continue to be audited by our technical assurer, Atkins.
Their assurance approach is outlined in appendix 1. Both sets of data
included in the dual-reporting are included within the scope of the audit.
Expected Outcome of Assurance Activities on 2019/20 Risk Assessment
Due to the complexity of leakage reporting, we do not anticipate that the risk
will reduce below a high risk.
192017/18 Risk 2018/19 Risk Reason for 2018/19 Targeted Assurance Activity Identified for 2019/20
Data Item
Assessment Assessment Risk Assessment
Internal Assurance
This data item will follow the same internal reporting requirements that our other
performance commitments follow, as outlined in our Statement of Risks, Strengths
and Weaknesses of Information.
Performance information is included in our interactive performance graphic on our
website to aid transparency to customers.
High impact on
High customers, stakeholders External Assurance
Low Pressure High
or company reputation, if The data item will continue to be audited by our technical assurer, Atkins. Their
risk materialises assurance approach is outlined in appendix 1.
Expected Outcome of Assurance Activities on 2019/20 Risk Assessment
The high risk rating for this measure reflects our recognition of the impact on
inaccurate reporting, rather than a high probability of inaccurate reporting or
specific weaknesses in the control framework. We therefore do not anticipate that
the risk will reduce below a high risk.
Internal Assurance
This data item will follow the same internal reporting requirements that our other
performance commitments follow, as outlined in our Statement of Risks, Strengths
and Weaknesses of Information.
Performance information is included in our interactive performance graphic on our
High impact on website to aid transparency to customers.
customers, stakeholders
Bursts High High External Assurance
or company reputation, if
risk materialises The data item will continue to be audited by our technical assurer, Atkins. Their
assurance approach is outlined in appendix 1.
Expected Outcome of Assurance Activities on 2019/20 Risk Assessment
The high risk rating for this measure reflects our recognition of the impact on
inaccurate reporting, rather than a high probability of inaccurate reporting or
specific weaknesses in the control framework. We therefore do not anticipate that
the risk will reduce below a high risk.
Internal Assurance
High impact on
Unplanned This data item will follow the same internal reporting requirements that our other
customers, stakeholders performance commitments follow, as outlined in our Statement of Risks, Strengths
Customer Minutes High High
or company reputation, if and Weaknesses of Information.
Lost (UCML) risk materialises
(continued on next page...)
202017/18 Risk 2018/19 Risk Reason for 2018/19 Targeted Assurance Activity Identified for 2019/20
Data Item
Assessment Assessment Risk Assessment
(continued from previous page...)
Performance information is included in our interactive performance graphic on our
website to aid transparency to customers.
High impact on External Assurance
Unplanned customers, stakeholders
High High The data item will continue to be audited by our technical assurer, Atkins. Their
Customer Minutes or company reputation, if assurance approach is outlined in appendix 1.
Lost (UCML) risk materialises
Expected Outcome of Assurance Activities on 2019/20 Risk Assessment
The high risk rating for this measure reflects our recognition of the impact on
inaccurate reporting, rather than a high probability of inaccurate reporting or
specific weaknesses in the control framework. We therefore do not anticipate that
the risk will reduce below a high risk.
The risk of inaccurately reporting PCC has deteriorated over the years (it was
assessed as a low risk in 2016/17). Our approach to reporting our 2016/17 PCC data
was highlighted in Ofwat’s 2017 Company Monitoring Framework assessment (this
contributed to the regulator having ‘serious concerns’ about our outcome reporting).
Internal Assurance
Since that assessment we have agreed with the regulator to dual-report on
this performance commitment and provide thorough explanations behind the
methodologies undertaken within our in published reports (which we have done as
High impact on recently as the 2018/19 Mid-Year Performance Report). We will continue to dual-
Per Capita customers, stakeholders report on this performance commitment until the end of 2019/20.
Consumption High High
or company reputation, if
(PCC) risk materialises Performance information is included in our interactive performance graphic on our
website to aid transparency to customers.
External Assurance
The data item will continue to be audited by our technical assurer, Atkins. Their
assurance approach is outlined in appendix 1. Both sets of data included in the dual-
reporting are included within the scope of the audit.
Expected Outcome of Assurance Activities on 2019/20 Risk Assessment
Due to the complexity of measuring PCC, we do not anticipate that the risk will
reduce below a high risk.
212017/18 Risk 2018/19 Risk Reason for 2018/19 Targeted Assurance Activity Identified for 2019/20
Data Item
Assessment Assessment Risk Assessment
The risk of inaccurate reporting has increased for this data item, compared to
last year’s assessment. The high risk rating is primarily in recognition of omitted
specific disclosure information that we should have included in our regulatory
accounts notes, which was not included in our Annual Performance Report and,
consequently, led to a number of queries being raised by Ofwat.
Internal Assurance
Regulatory A review of all required disclosures will now be included in our approval process for
Medium High Identified errors last year the 2018/19 APR.
Accounts
External Assurance
The data item will continue to be audited by our financial auditor, PwC. Their
assurance approach is outlined in appendix 1.
Expected Outcome of Assurance Activities on 2019/20 Risk Assessment
As a result of our assurance activities, we anticipate that this will reduce to a
medium risk.
Internal Assurance
This data item is reviewed by two teams at the company – Economic Regulation
and Finance.
Our tariff and charges publications (particularly for new connections charges) now
include more customer-friendly language and user-friendly graphics, to improve
their readability for interested parties.
Our Statement of Assurance on our tariffs also now includes an engagement
High impact on summary section on who we have spoken to and what changes we have made
customers, stakeholders to the information we present in our tariffs and charges publications as a result,
Tariffs & Charges High High
or company reputation, if which brings it in line with industry best practise.
risk materialises External Assurance We will continue to assure the information via external
financial auditors, to ensure accuracy and reliability. The data item is audited by
our financial auditor, PwC. Their assurance approach is outlined in appendix 1.
Expected Outcome of Assurance Activities on 2019/20 Risk Assessment
The high risk rating for this measure reflects our recognition of the impact on
inaccurate reporting, rather than a high probability of inaccurate reporting or
specific weaknesses in the control framework. We therefore do not anticipate that
the risk will reduce below a high risk.
222017/18 Risk 2018/19 Risk Reason for 2018/19 Targeted Assurance Activity Identified for 2019/20
Data Item
Assessment Assessment Risk Assessment
Internal Assurance
A process map will be introduced as part of the reporting methodology, in order
to reduce the probability of inaccurate reporting from materialising for this data
item. This approach is already included in the methodologies for our performance
commitments.
High impact on External Assurance
Guaranteed The data item will continue to be audited by our technical assurer, Atkins. Their
High High customers, stakeholders
Standards Scheme assurance approach is outlined in appendix 1. The scope of the audit will include
or company reputation, if
(GSS) Payments a review of the process map and its effectiveness in identifying any risks in our
risk materialises
reporting processes.
Expected Outcome of Assurance Activities on 2019/20 Risk Assessment
The high risk rating for this measure reflects our recognition of the impact on
inaccurate reporting, rather than a high probability of inaccurate reporting or
specific weaknesses in the control framework. We therefore do not anticipate that
the risk will reduce below a high risk.
Internal Assurance
Our new connections charges now include more customer-friendly language and
Service Incentive Identified weaknesses in
Medium High user-friendly graphics to improve transparency.
Mechanism (SIM) control framework
We have continued to expand upon our tailored engagement activities with our
developers to ensure that their voices are heard alongside our stakeholders in
the wider Bristol area. We established our Market Engagement Days in 2017 as an
on-going engagement activity to bring together developers and self-lay providers
(SLPs) to build relationships, communicate information, and receive feedback. We
High impact on have used our Market Engagement Days as part of our consultation on the new
Developer Services customers, stakeholders charging approach for developer services, which we successfully introduced in
Data High High April 2018. We will continue to undertake similar engagement activities.
or company reputation, if
risk materialises
We also continue to undertake quarterly reporting on our developer services
performance to Water UK and the SIM action plan includes the processes our new
supplies team and Kier will undertake to ensure accurate complaints reporting is
addressed.
External Assurance
Atkins’ audit scope of the SIM data item is linked to the information for this data
item.
Expected Outcome of Assurance Activities on 2019/20 Risk Assessment
Due to the complexities in data reporting, we do not anticipate that the risk will
reduce below a high risk.
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