ISSUE 1.0 Page 1 of 7 Regulatory Information and Data Quality Assurance Policy Contents Policy Scope Responsibility for Data Quality and Assurance Reference Documents The Data Quality Assurance Process Risk Strengths and Weaknesses Data Quality Objectives Reporting and Representation of Data Assurance of data quality Reviewing this Policy Policy The purpose of this policy is to ensure Bournemouth Water provides accurate and reliable information in order to manage our activities, inform stakeholders and meet our ongoing regulatory requirements. Specifically we will to ensure data quality so that it can: Provide effective and efficient services to our customers and other stakeholders. Produce accurate and comprehensive data and information on which timely, informed decisions can be made to inform the future of the company. Monitor and review activities and operations. Produce accurate regulatory returns to ensure compliance with our legislative and regulatory requirements. Enable the production of transparent and meaningful information to stakeholders. This policy will be communicated to all those involved in the data collection and reporting process. It will be prominently displayed on the company s intranet.
ISSUE 1.0 Page 2 of 7 It is the responsibility of senior managers to ensure that staff who are working with data are aware of the policy and understand how it relates to their work. The policy will be the overarching policy for the data assurance and will fit within a framework of documentation produced by different areas of responsibility for data. It is an integral part of the role of all members of staff to ensure that they follow the principles of this policy in order to maximise the accuracy, timeliness and quality of data collected and recorded, analysed and reported. This policy is endorsed by the BW board and will be reviewed at the annual Management Review to ensure its validity and robustness. Scope The scope of this framework covers data held in the company-wide systems, and any data collected from these systems that are used for analysis, regulatory reporting and stakeholder communications. This policy will inform an annual process of assuring data quality overseen by the Regulation Department, and reported to the Board, and will fit within a framework of information to support the aims and objectives of data assurance, and related policies for Bournemouth Water. Responsibility for Data Quality and Data Quality Assurance Board of Directors The Board has the overall responsibility to ensure the accuracy and validity of all information and data produced by the company. It is responsible for ensuring that information or data is appropriately reported to the Regulator and other stakeholders in order to demonstrate the ongoing achievement of the objectives laid out in our business plan. These duties are discharged to the Bournemouth Water Executive Team to implement Management Team The Management Team are responsible for the collection and preparation of data used for regulatory information the ongoing improvement of data preparation and collation methodology.
ISSUE 1.0 Page 3 of 7 Compliance Department Responsibility for oversight of the processes, systems and review that ensure accurate and valid data rests with Compliance Department, which reports performance to the Executive Directors and has a dotted line to the Board of Directors. Regulation Department The Regulation Department is responsible interpreting and communicating the requirements for provision of economic regulatory information and data, the collation and submission of this information and the co-ordination of the assurance programme. Operations Group Management Team The Operations Group Management Team is responsible for overseeing the production of and the assurance programme for water quality, water supply and asset management information and regulatory data. Individual responsibility It is an integral part of the role of all members of staff to ensure that they follow the principles of this policy in order to maximise the accuracy, timeliness and quality of data collected and recorded, analysed and reported. BOB TAYLOR MANAGING DIRECTOR CHAIR OF AUDIT COMMITTEE DAVID LOVETT FINANCIAL CONTROLLER PHILIPPA GOODWIN FINANCE DIRECTOR TRACEY LEGG REGULATION MANAGER RICHARD STANBROOK DIRECTOR OF RETAIL AND CORPORATE SERVICES TONY SPINKS COMPLIANCE MANAGER ANDREW ROANTREE DIRECTOR OF OPERATIONS OPERATIONS GROUP MANAGEMENT TEAM
ISSUE 1.0 Page 4 of 7 Reference Documents Quality Manual Quality Procedure 01 - Management Review Quality Procedure 02 - Internal Audit Quality Procedure 03 - Quality Records Quality Procedure 04 - Preventative Action Quality Procedure 20 - Job Descriptions Quality Procedure 23 - Documentation Quality Procedure 27 - Computer Controls Quality Procedure 37 - Risk Management BWQAM BWQP01 BWQP02 BWQP03 BWQP03 BWQP20 BWQP23 BWQP27 BWQP37
ISSUE 1.0 Page 5 of 7 The Data Quality Assurance Process
ISSUE 1.0 Page 6 of 7 Risk Bournemouth Water s Risk Management System which is administered by the Compliance Department was developed around the principles of ISO 31000:2008 and utilises a full top down, bottom up approach to risk. All risks are reviewed by their owners every six months with the Compliance Department. All risks are reported to the Risk Management Committee and the principal and emerging risks are discussed by the committee. The key risks relating to data are included in appendix 1. All risks associated with data quality are recorded on the risk register. Strengths and Weaknesses We have identified our risks, strengths and weaknesses in relation to data and information quality these are detailed in Appendix 2. We have engaged in a programme of communication and consultation with our stakeholders to communicate our risks and our key controls in order to identify where they feel our strengths and weaknesses lie in relation to data and information quality. We will engage with: Customer View (which includes CCWater, the Environment Agency and Natural England) Customers Ofwat Drinking Water Inspectorate Through this process of engagement we aim to identify and understand: our stakeholders current concerns about how data is collected and how information is reported, the importance various stakeholders place on information, how each stakeholder uses information and their requirements for its precision, and, whether stakeholders require different information or would prefer presented in a different way.
ISSUE 1.0 Page 7 of 7 Data Quality Objectives Our data quality objectives are set out below and indicate our approach to achieving them. Appropriate Responsibility, Accountability and Awareness Managers will ensure every member of staff is made aware during their induction of the need for good quality data and how they can contribute to it. Every member of staff should be aware of their individual responsibilities with regard to data collection, storage, analysis and reporting and this should be recorded in their job description. Managers will ensure every member of staff should be aware of the implications of poor data quality in their area in terms of internal and external accountability including those affecting other departments and the company as a whole. All staff should report any data quality issues immediately to their manager who should ensure remedial action is taken promptly All staff should be made aware of the policies related to data quality during training and induction and the need for ongoing data quality will be regularly communicated to staff through briefings and departmental reviews. Appropriate Policies and Procedures The company has defined its key data requirements and assurance arrangements within the quality manual. Local procedures exist for key activities such as data collection exercises and external reporting All policies and procedures are reviewed regularly to consider their impact on data quality and to ensure they reflect any change needs Departmental managers ensure policies and procedures are adopted and embedded within working processes and that compliance is achieved
ISSUE 1.0 Page 8 of 7 Appropriate Systems and Processes Guidelines for all processes supporting key data requirements as defined by the company exist and are followed consistently across the company Reasonable efforts are made to ensure that data is collected and recorded once only, wherever possible, without the need for multiple systems Data collection systems contain internal validation to ensure accurate and complete data where possible Companywide systems have, where possible, internal validation checking facilities to ensure data is complete, consistent and internally validated All systems should be electronic wherever possible to reduce the risk of manual error, except where there is a need to collect, process and store original documents There should be clear strategies for data storage and archiving from systems, with retrieval and security appropriate to its present value and future use A documented Version Control Procedure is detailed in the Quality Manual and is strictly adhered to Reporting and Presentation of Data Internal management information and reports should be clear in what they are reporting, reflect the audience for which they are intended, and should be reviewed regularly to ensure that they reflect any changes in requirements. These reviews should be balanced with the need for consistency over time so that trends can be easily recognised and reported. External reporting should be subject to validation and verification, submitted on a timely basis and should evidence a full audit trail. This will include the appropriate approval and sign-off as specified by the body to whom the information is being submitted, or agreed by the Regulation Department in the absence of such a recommendation. The person producing the data should not be the same person responsible for the final sign-off, this should be completed by a senior manager. Assurance of Data Quality Bournemouth Water has been certified to the ISO 9001 and 14001 standards for Quality and Environmental Management since 1996. As part of these management systems, Corporate, Management and Individual responsibilities have been allocated to give ownership, accountability and
ISSUE 1.0 Page 9 of 7 a means of communication for all business functions; this applies equally to data and information quality. Management Review The departmental manager will ensure that the information and data gathering methodology is current, relevant and will review all regulatory data prior to submission to the regulation department. This will ensure that the ownership and accountability at this stage resides with the department producing the information or collating the data. Internal Audit The Compliance department will by independent audit, review data and information collation methodology and validate by sample, the data collected for internal and external reporting which have been identified through the Risk Assessment or Stakeholder engagement process. This will be coordinated through the Compliance Programme and will include mid-year and year-end audits. External Audit Bournemouth Water utilises independent external auditors to review and provide assurance on regulatory and financial reporting and information. We have appointed Ernst & Young as our financial auditors and Halcrow Management Sciences to independently assure other regulatory information and data. External assurance audits will be conducted annually and will provide further assurance on the work conducted by Internal Audit. External assurance on interim or Ad-hoc requests will be dealt with on a case by case basis where assurance over and above that provided by internal audit is required. The Compliance Department will be responsible for the implementation of this policy and oversight of the companywide framework for the assurance of regulatory data quality. This policy will be reviewed at regular intervals following feedback, renewed stakeholder consultation or the identification of new risks. This will ensure that the policy remains relevant and will aid improvement.
ISSUE 1.0 Page 10 of 7 Reviewing this Policy This policy will be reviewed annually as part of Bournemouth Water s Management review. This is achieved through a review of the key policies and processes, to assess their continuing suitability, adequacy and effectiveness in satisfying the needs of its customers and shareholders. The objective of this process is to find out how we are doing and to ensure continual improvement. The management review will address the need for changes to policy influenced by both internal and external factors such as changes in the organizational structure, registration pending and the introduction of new technology. The review should result in the continuous improvement of the system. Any actions identified as a result of the reviews will be minuted and responsibilities and timescales for completion will be identified by management. The Compliance Manager will follow up completion and effectiveness of actions and record the results