Official hearing page

13 January 2023 – Christopher Gilding and Kathryn Parker

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(10.05 am)

Mr Beer: Good morning, sir, can you see and hear me?

Sir Wyn Williams: Yes, I can.

Mr Beer: Thank you very much. Can I call Mr Gilding, please.

Christopher Gilding

CHRISTOPHER GILDING (affirmed).

Questioned by Mr Beer

Mr Beer: Thank you, Mr Gilding. As you know my name is Jason Beer and I ask questions on behalf of the Inquiry. Can you give us your full name, please?

Christopher Gilding: Christopher James Gilding.

Mr Beer: Thank you very much for coming to give evidence to the Inquiry today and for the witness statement that you have previously provided we’re very grateful. Can you look at the witness statement, please.

Christopher Gilding: Yes.

Mr Beer: It should be in the hard copy bundle in front of you?

Christopher Gilding: Mm-hm.

Mr Beer: It should be 19 pages in length, excluding the exhibits page and exhibits, and dated 7 September – sorry, 7 December and on the last page there should be your signature. Is that your signature?

Christopher Gilding: It is, yes.

Mr Beer: Are the contents of that statement true to the best of your knowledge and belief?

Christopher Gilding: They are, yes.

Mr Beer: Thank you very much. A copy of that witness statement will be uploaded to the Inquiry’s website and therefore I’m not going to ask you questions about every part of it. Do you understand?

Christopher Gilding: Okay. Thank you.

Mr Beer: Can we start, please, with your background and experience. I think you joined the Post Office in 1977; is that right?

Christopher Gilding: Indeed, yes.

Mr Beer: And you left in 2016?

Christopher Gilding: Yes, that’s correct.

Mr Beer: Therefore, you were employed by the Post Office for, by my calculation, 39 years; is that right?

Christopher Gilding: 39, yes.

Mr Beer: Would you consider yourself to be a loyal company employee in that time?

Christopher Gilding: I was indeed, yes. I felt so.

Mr Beer: Between 1977 and the late 1980s, I think you describe it as in your statement, you worked in Crown branches; is that right?

Christopher Gilding: That’s correct, yes.

Mr Beer: First as a counter clerk and then as an assistant branch manager?

Christopher Gilding: That’s right.

Mr Beer: So that’s your first job, as it were?

Christopher Gilding: Well, yes, yes, and progressed through the branch management, so from assistant branch manager I became a branch manager and I managed at pretty much every branch office in Hampshire over the years.

Mr Beer: Then between the late 1980s and 1992 you were a regional reserve trainer, it’s described as.

Christopher Gilding: Yes. So that was a role that was sort of an add-on to myself being an assistant branch manager at the time. So as a reserve instructor, if there were any courses due to take place that they didn’t have staff available for, then I was asked to go and run those courses.

Mr Beer: Then I think in 1992 you became a Crown branch manager –

Christopher Gilding: That’s right, yes.

Mr Beer: – and you stayed a Crown branch manager until 2009; is that right?

Christopher Gilding: That’s right, yes.

Mr Beer: If you just look at paragraph 3 of your witness statement, please, where you say that, 1992 to 2009, and it says 27 years as a Crown branch manager. I think that must mean 17 years?

Christopher Gilding: 17 years, yes.

Mr Beer: In that time as a Crown branch manager, did you use Horizon after it was introduced in about 2000?

Christopher Gilding: Indeed, yes.

Mr Beer: Would you have used it on a daily basis?

Christopher Gilding: Absolutely, yes, yes.

Mr Beer: So that’s your sort of third role, if you like, after being the regional reserve trainer. Then between 2009 and 2013 you were what’s described as a field team leader in network support and, is this right, that meant that you managed a team of trainers and auditors?

Christopher Gilding: That’s correct, yes.

Mr Beer: Did you hold the title training and audit manager?

Christopher Gilding: No. I was a field team leader.

Mr Beer: Just look at paragraph 9 of your witness statement on the second page where it says under the heading “My roles in relation to the Horizon IT System”,”Branch manager”, which we’ve dealt with and then “Training and Audit Manager”.

Christopher Gilding: So the field team leader was the job title. Training and audit manager was what the purpose of the role was.

Mr Beer: Understand. During that time, you would have used Horizon in training events presumably –

Christopher Gilding: Yes, indeed.

Mr Beer: During branch audits?

Christopher Gilding: Absolutely.

Mr Beer: And in visits to offices assisting postmasters to investigate balance enquiries?

Christopher Gilding: That’s very true, yes.

Mr Beer: Then your next role between 2013 to 2015 you were seconded for, I think, a two-year period within those three years to the Horizon mediation investigation team.

Christopher Gilding: That’s correct, yes.

Mr Beer: I think also looking at paragraph 9 there you were a team leader?

Christopher Gilding: That’s right, yes. So within that mediation team I was line managing a team of – I believe it was six people.

Mr Beer: Thank you. Then in 2015 you returned to the field team leader role where you stayed for about a year or, and so in 2016 you took voluntary redundancy?

Christopher Gilding: That’s correct, yes.

Mr Beer: I’m going to come back to some of those roles in a moment but I just want to focus on something now that we haven’t heard much about so far.

Christopher Gilding: Okay.

Mr Beer: It’s your role in the Horizon mediation investigation team?

Christopher Gilding: Mm-hm.

Mr Beer: As we’ve said, that was for two years in 2013 to 2015. By way of background, would this be right, that the Post Office had established an investigation into some issues about the operation of the Horizon scheme following a campaign for the Justice for Subpostmasters Alliance, the JFSA; do you remember that?

Christopher Gilding: Yes, I do remember that and the mediation team that I was asked to join was to look at the data for some of the offices that were involved in the scheme.

Mr Beer: So do you remember, to put this in context, the setting up of the scheme following some work done by, amongst others, an MP called James Arbuthnot?

Christopher Gilding: I remember the scheme being set up but I was not involved in any part of that.

Mr Beer: Do you remember the involvement of Second Sight?

Christopher Gilding: They were – I’m trying to think what the title was – but yes, they were involved with the mediation programme, yes.

Mr Beer: Can you remember what their – we know an awful lot. I want to ask you what you can remember from seven or eight years ago.

Christopher Gilding: Their role was to – my understanding was their role was to look at if there was any discrepancies within the Horizon System from a software point of view and then to make recommendations based on what they found.

Mr Beer: Looking at it generally, was this the position: the Post Office had offered a scheme to subpostmasters so that individual subpostmasters could have an opportunity to raise their concerns about discrepancies or issues with the Horizon scheme that Second Sight could investigate. You were not seconded to Second Sight at all. You were still working for the Post Office?

Christopher Gilding: No, very much working for the Post Office.

Mr Beer: What did your work consist of when you were a team leader on the mediation investigation team?

Christopher Gilding: So we were allocated – my team were allocated certain cases, so – I say cases/branches that had become part of the mediation scheme. So they entered the mediation scheme and then we were allocated individual cases and we would work primarily as a pair and investigate the Horizon data to try and ascertain how the losses had occurred according to the data that was provided from the Horizon System.

Mr Beer: I think you told me earlier how many people were in your team.

Christopher Gilding: I believe it was six. I’m trying to recall but I’m not sure. But it was around six in my team.

Mr Beer: Was there more than one team?

Christopher Gilding: Yes, there were two teams within – from the line manager that I worked for, there were two teams, yes.

Mr Beer: Who was the line manager that you worked for?

Christopher Gilding: Kathryn Alexander.

Mr Beer: Were there any other teams other than those two investigating Horizon Issues?

Christopher Gilding: Yes, you are quite right. So we were the south team. There was a north team as well, based in Scotland, and I’m trying to – I think it was Wendy Mahoney was the team leader for the north.

Mr Beer: Thank you. I just want to look at the approach that you took in the course of that two-year period investigating discrepancies raised by subpostmasters and others.

Christopher Gilding: Mm-hm.

Mr Beer: Can we look, please, at paragraph 106 and 107 of your witness statement, please, which is on page 18.

Christopher Gilding: Yes.

Mr Beer: In that paragraph, under the heading “Bugs, errors and defects”, you say:

“I always operated on the statement received from Fujitsu that Horizon was ‘the 2nd most secure system in Europe’. I personally was never aware of any issue or problems with Horizon.

“All of my dealings with Subpostmasters and staff were based on Horizon being a robust accounting system.”

When did you receive that statement from Fujitsu that it was the second most secure system in Europe?

Christopher Gilding: So that was a statement that was used when we had – when I was in the Crown network and we had our very initial training into the introduction of Horizon. I attended a two-day course that all branch managers would have attended and that was a statement that was used as part of the introduction to that program, that the Horizon System was robust and – yes, as I said, they were very confident that this was a very secure system.

Mr Beer: You used language there that you received the statement from Fujitsu.

Christopher Gilding: Sorry, the statement was as part of the training given by whoever the trainers were at that time. So it would have been a Post Office trainer not Fujitsu, but it was a statement that they were obviously given to pass on as part of the training to show how strong the system was.

Mr Beer: So the people that were training you said, “We have been told by Fujitsu that the system is the second most secure in Europe”?

Christopher Gilding: Yes, yes.

Mr Beer: You have added that you were personally never aware of any issue or problems with Horizon and it was, to your knowledge, a robust accounting system.

Christopher Gilding: Absolutely, yes.

Mr Beer: When you say that you operated on the basis of that statement, do you mean that you believed what Fujitsu said in that statement without investigating the merits of it?

Christopher Gilding: Yes, that’s true, yes.

Mr Beer: So you mean by that statement you operated on the basis that the statement must be true?

Christopher Gilding: Yes.

Mr Beer: Does that mean that, because you operated on the basis that the statement must be true, you were therefore sceptical or disbelieving of any suggestion that there may be errors, bugs or defects in Horizon?

Christopher Gilding: I’m not sure “sceptical” is the right word but I never – I didn’t see any evidence to say that there had been any problems.

Mr Beer: If you were operating on the basis that the statement must be true, why would look for any evidence that there might be errors, bugs or defects?

Christopher Gilding: Because that was the role I was asked to do and I was looking at the data that was provided to try and identify how the losses had occurred in the branch. But all of that was under the assumption that the Horizon data was solid and true.

Mr Beer: And that assumption was based on something that you had been told in a training exercise, what, a decade earlier?

Christopher Gilding: Yes, yes. And also when we were part of the mediation team, I personally, and other members of the team, did enquire with our team leader as to whether we were 100 per cent confident with the data that we were working on because there would have been no point in interrogating the data if it was known to be false and we were assured that the data was solid.

Mr Beer: Who gave you that assurance?

Christopher Gilding: That was my team leader who was Kathryn Alexander.

Mr Beer: When you say we asked, do you mean –

Christopher Gilding: Myself and my team, when we were seconded onto the mediation team. Obviously, we wanted to make sure that we were working with good evidence and not information that was going to be corrupted in any way because there was no point in investigating data if it wasn’t true –

Mr Beer: Obviously not.

Christopher Gilding: – to the best of our knowledge.

Mr Beer: And you got, what, a verbal assurance, “No this data is solid, robust and reliable”?

Christopher Gilding: Yes, nothing written, just verbal.

Mr Beer: And, “There are no problems, no errors, bugs or defects in Horizon that could be causing these discrepancies”?

Christopher Gilding: That’s correct, yes.

Mr Beer: Can we look, please, at POL00006581.

Christopher Gilding: Sorry, which page are we on?

Mr Beer: It’s going to come up on the screen for you.

Christopher Gilding: All right, thank you.

Mr Beer: This is a document that you wouldn’t, I think, have seen at the time but it’s been shown to you in preparation for these hearings.

Christopher Gilding: Yes.

Mr Beer: It’s an advice of Brian Altman, King’s Counsel. It’s dated 15 October 2013. I’m not going to go to the back end of the document to establish it’s date. Just take that from me.

The document concerns a review by him of past prosecutions undertaken by a firm of solicitors called Cartwright King on behalf of the Post Office.

Christopher Gilding: Mm-hm.

Mr Beer: Do you remember Mr Altman?

Christopher Gilding: I met him briefly once.

Mr Beer: Can we look, please, at the third page of the advice. Then at paragraph 4, Mr Altman says:

“Regarding the process by which I have been asked to conduct my review and by reference to each in the above process list in chronological order …”

He sets out how he went about the process of fulfilling his instructions.

Then if we go over the page, please, and look at the top of the page, point 3 of his instructions, he says:

“… on 19 September 2013, I attended Guildford Classroom Training Office … where I received a day’s training on the Horizon system. Chris Gilding (Network Support Team Leader) trained me. Andy Holt (Business Relationship Manager) was on hand to assist and answer questions.”

Is that the occasion that you’re referring to when you said you briefly met him?

Christopher Gilding: Yes.

Mr Beer: Did you give him a day’s training?

Christopher Gilding: I did, yes.

Mr Beer: Do you remember that in the Guildford classroom training office?

Christopher Gilding: Yes, I remember being in the Guildford training office and over – with training for legal teams, over a period of a few months, I was asked to do three different training sessions. This was one of the ones that I undertook and there were other sessions where I had six representatives from the legal team. The point of the one-day training was just to give them an oversight of what the equipment looked like and how it was used from a user interface point of view.

We also looked at the reports that could be drawn from the system and how they were interpreted.

Mr Beer: Did you undertake balancing training?

Christopher Gilding: We did a balancing exercise. So they were given a handout with some transactions to put through, as you would do in a live situation, and then they were shown the balance procedure and talked through the balance procedure and, at the end of the balance procedure, we looked at how many discrepancies or any discrepancies that they managed to identify as part of the exercise that we’d done.

Mr Beer: Ie the person you were training, their own user error?

Christopher Gilding: Yes.

Mr Beer: In the course of this training, you were presumably still working on the basis that the statement you’d received indirectly from Fujitsu, namely that there were no problems whatsoever with Horizon, that it was reliable and robust?

Christopher Gilding: Indeed, yes.

Mr Beer: Do you remember was there any conversation about that in the course of this training?

Christopher Gilding: No, I don’t remember any conversation on that subject.

Mr Beer: What did you understand the purpose of the training to be?

Christopher Gilding: The purpose of the training was, as I mentioned, was just to give the legal team an oversight of –

Mr Beer: Do you mean an overview?

Christopher Gilding: Overview, sorry – an overview of the equipment and how it was used and how the staff using the equipment would interact with the user interface.

Mr Beer: There was no discussion about bugs, errors and defects?

Christopher Gilding: No.

Mr Beer: Thank you. That can come down.

Can we look back at your witness statement, please, at paragraph 25, which is WITN05380100 at page 4. Just wait for it to come up on the screen.

Can we see at paragraph 25, you say:

“I was never made aware of any bugs or defects with Horizon and my view was that it was a robust system as all of the accounting errors I came across as a Crown manager were due to inputting errors by staff members.”

Presumably now, in the light of what you know, you accept that, with the benefit of hindsight, you were proceeding on an erroneous assumption?

Christopher Gilding: Yes, from what I now know but that was not my belief at the time.

Mr Beer: You now know – is this right – that because of litigation and the findings in the civil courts and in the criminal courts, and indeed from some of the evidence that the Inquiry has heard, that there were a series of bugs, errors and defects within the Horizon System from when it was rolled out until perhaps 2016?

Christopher Gilding: I personally have not seen anything about what those defects were. So, to this day, I’m still unaware of what the bugs or defects were.

Mr Beer: You say in this paragraph that every error you came across was down to the member of staff; it was always their fault, never the system?

Christopher Gilding: Yes. Any errors that I identified were to – either from staff inputting incorrectly onto the Horizon System or, more often, it would be not actually the inputting into the Horizon that was the issue, it was what they physically did with the cash and stock. But obviously what they recorded on Horizon was not necessarily the same as what they were doing with the cash and stock, so hence a discrepancy would appear.

Mr Beer: Did no-one in the 16 years or so that you were a Post Office employee whilst Horizon was in operation ever say to you “I think the computer’s the problem, not me”?

Christopher Gilding: Yes, I would have heard that statement.

Mr Beer: But it was always untrue?

Christopher Gilding: I had no evidence to suggest otherwise.

Mr Beer: What enquiries did you make as to the reliability of the data that the system was producing?

Christopher Gilding: None, really. No, I was just –

Mr Beer: So how can you say that, “I had no evidence that it wasn’t the computer, it was always the member of staff”, if you never made any enquiry?

Christopher Gilding: I suppose what I’m saying is that data I would look at from the Horizon System always seemed to be robust.

Mr Beer: How could you tell?

Christopher Gilding: Just from experience of looking at that information.

Mr Beer: Experience at looking at a screen?

Christopher Gilding: No, at reading the transaction and event logs that the system produced.

Mr Beer: Now, you performed a variety of roles as we’ve seen, training people, being a supervisor for training people –

Christopher Gilding: Mm-hm.

Mr Beer: – auditing branches, being a supervisor for those auditing branches and then investigating alleged discrepancies in the course of the mediation scheme, and the only thing in all of that time you ever found was that it was always the subpostmaster’s fault or the counter staff’s fault; is that right?

Christopher Gilding: I had – didn’t come across evidence to suggest anything else other than that.

Mr Beer: You say in paragraph 26 of your witness statement:

“My view of the robustness of the system didn’t change over time as the losses attributed to Horizon only appeared to occur in sub post offices, I am not aware of any major losses in Crown offices, the Horizon [system] installed in all branch types across the network was identical.”

What are you trying to say by that paragraph, please?

Christopher Gilding: I’m just saying that any losses that I was asked to look at regarding Horizon errors, Horizon data, was always with sub offices. I was never asked to investigate any losses within Crown branches.

Mr Beer: I see. This attitude of mind that you had, that the system was the second most secure in Europe, that it was robust, that there were never any errors, bugs or defects in it and that all and any issues were the fault of subpostmasters or counter staff, did that remain for the entirety of the 16 years that you worked whilst Horizon was in operation?

Christopher Gilding: Yes, it was, yes.

Mr Beer: So you carried that attitude of mind into your work as a trainer and as a manager of trainers, as an auditor –

Christopher Gilding: Yes.

Mr Beer: – and a manager of auditors and when investigating allegations of Horizon-caused shortfalls?

Christopher Gilding: Yes, indeed.

Mr Beer: I’m just going to address very briefly your work as an auditor and a team leader of auditors. That statement can come down now, thank you.

I’m going to address this briefly, as it may be that you will be returning to the Inquiry in one of its later phases when we look at individual cases.

Christopher Gilding: Okay.

Mr Beer: As an auditor, I think it’s essentially for four years – is that right – between 2009, when you stopped being a Crown branch manager, and 2013, when you took up the role of team leader in the mediation investigation team that –

Christopher Gilding: It may have been a shorter period than that. When I joined the training team in 2009, we were just a training team and I believe it was about 2011, but I’m not sure of the exact date, there was a restructuring of the field support team and the training and audit teams were amalgamated into a field support team –

Mr Beer: Thank you –

Christopher Gilding: – so before then they were two separate …

Mr Beer: Okay, so it might be for the first two of the four years you were just training –

Christopher Gilding: That’s correct.

Mr Beer: – and it was only for the second half that you were training and auditing?

Christopher Gilding: Yes.

Mr Beer: I understand. I was going to ask you about that later. The merger of the audit and training functions, why was that undertaken? On the face of it, they are not natural bed fellows.

Christopher Gilding: My understanding, it was to try and make a better use of the resource as in people that we had available within the field support team, so that because it was a national team, by having multiskilled trainers and auditors, it would reduce the amount of travel that the audit team were having to make because we would have more people across a wider geographical spread.

Mr Beer: I see. So your understanding was that it was for sort of business pragmatic reasons, rather than because of a natural affinity or similarity between the skillset needed for both?

Christopher Gilding: No, it was a restructure of the field support function and it was, as I say, to improve the coverage over geographical spread. But –

Mr Beer: So – sorry.

Christopher Gilding: But what I will say is that, coming from the training background, going into audits, we were very much treating the audits as a support function rather than a punitive visit. It was always there to support the subpostmasters with any issues or questions that they may have had.

Mr Beer: Okay. So “audit” is the wrong word to describe you there?

Christopher Gilding: So an audit –

Mr Beer: You are supporters and helpers?

Christopher Gilding: Yes. So, basically, we were asked – we would be asked to attend an office and –

Mr Beer: Who would be asked by?

Christopher Gilding: So there was a scheduling team based in Salford who would allocate. The selection criteria for which offices to visit, there was a team in our financial department in Chesterfield who would identify from the data that they were looking at from the offices if there was an office where they thought maybe there would be a reason for a visit to take place.

Mr Beer: What would be a reason for a visit to take place?

Christopher Gilding: It might well be that there was a high volume of cash declared as being in the office but when that office was asked to return some of the cash to the cash centre that they were not returning it.

Mr Beer: So something suspicious?

Christopher Gilding: Yes, yes. But there was also a programme of random audits that would just be – so every office was due to have a visit once every five years on a random basis.

Mr Beer: So the request didn’t come from the subpostmaster?

Christopher Gilding: No.

Mr Beer: So it wasn’t “I need some help and assistance”?

Christopher Gilding: Not from that audit point of view, no.

Mr Beer: So you were a team leader of the auditors?

Christopher Gilding: Yes.

Mr Beer: How many people in the team did you lead?

Christopher Gilding: It varied. At one stage, I believe I had 15 and then it varied between nine and 15, depending on which area I had responsibility for.

Mr Beer: Where were you based?

Christopher Gilding: I was based in Southampton and –

Mr Beer: What was your geographical area?

Christopher Gilding: So my first geographical – are we talking just the audit function or the training function?

Mr Beer: Just the audit, please.

Christopher Gilding: So just the audit function would have been Hampshire, Berkshire, Dorset, Devon and Cornwall.

Mr Beer: Where were the staff that you led based?

Christopher Gilding: Geographically spread over that area.

Mr Beer: Was there a central office to which they would come?

Christopher Gilding: No. No, they were all field based.

Mr Beer: Who was your line manager?

Christopher Gilding: At that time, I can’t remember.

Mr Beer: Were they based in the Southampton office?

Christopher Gilding: No.

Mr Beer: Did you –

Christopher Gilding: Again, it wasn’t the Southampton office. It was my home address. I was based at home, sorry, yes.

Mr Beer: The others out in the field, they were based at their homes rather than Post Office offices?

Christopher Gilding: Yes, that’s correct.

Mr Beer: Did you carry out audits yourself?

Christopher Gilding: I was part of the audit team, yes, and so I attended some audits and, if it was an audit of a Crown Office I would lead the audit and that was felt necessary because you were dealing with managers of a certain Post Office grade and so the Crown Offices audits were always led by a field team leader, to make sure that there was somebody of the same grade, because that had caused issues in the past where a field adviser had led a Crown audit, challenged a Crown manager about something and because there was some –

Mr Beer: They tried to pull rank?

Christopher Gilding: Yes.

Mr Beer: So when you were carrying out these audits, you were investigating discrepancies, shortfalls, imbalances and sometimes suspending subpostmasters?

Christopher Gilding: No, I never suspended a subpostmaster. That was not my remit. Our job as auditors were to attend the office to look at – to get a report from the Horizon System of the cash and stock that should have been on hand, to do a physical check of the cash and stock that was there, make a comparison of the two and, if there was any discrepancies, we would then report that to a contracts adviser.

So each of the sub post offices had a contracts adviser. So our role was purely to identify what was there in the branch and report to the contracts adviser and they would then make a decision on how to proceed. That could be either that the office was reopened and the contracts adviser would speak direct to the subpostmaster about how any shortfalls would be repaid or it might be that they advised us to close the branch whilst investigations were undertaken by the contracts adviser.

Mr Beer: Would that happen on the occasion of your first attendance?

Christopher Gilding: Yes.

Mr Beer: So this would be done on the phone, would it?

Christopher Gilding: Yes, absolutely, yes.

Mr Beer: Sometimes you would close the branch there and then?

Christopher Gilding: We would – yes. If the contracts adviser wanted the branch closed, and it was always their decision, then we would advise the postmaster what the decision was and we would close the branch, secure the stock and cash, take those keys away from the branch and make sure that they were passed to the contracts adviser.

Mr Beer: So you wouldn’t decide whether to suspend somebody?

Christopher Gilding: No, that was not my role.

Mr Beer: Did you carry out the suspension, ie tell somebody whose branch was closed and their keys taken away from them that they were suspended or was that done by somebody else?

Christopher Gilding: No, that was done over the phone by the contracts adviser.

Mr Beer: So you would hand a mobile to the subpostmaster and somebody at the other end of the phone would say “You’re suspended”?

Christopher Gilding: Would talk them through what their decision was and what the process was, yes.

Mr Beer: And then you’d take the keys away and lock up?

Christopher Gilding: That’s correct.

Mr Beer: I just want to look, please, at a document just to work out whether this is you or not –

Christopher Gilding: Okay.

Mr Beer: – that’s referred to. It’s POL00029492. We should have here a briefing pack prepared by the Post Office for the Post Office for a meeting with James Arbuthnot MP and Oliver Letwin on 17 May 2010. Can you see that at the top?

Christopher Gilding: Yes.

Mr Beer: Now, this is a document that I think you wouldn’t have seen at the time but, again, you have seen more recently because we’ve shown it to you?

Christopher Gilding: Indeed, yes.

Mr Beer: The index to the contents notes what the pack contains and, at the bottom, there’s a reference at point 8 to the Yetminster case?

Christopher Gilding: Mm-hm.

Mr Beer: Can you see that? Yetminster, I think, being a village in Dorset.

Christopher Gilding: That’s correct.

Mr Beer: You told us already that your reach extended to Dorset; is that right?

Christopher Gilding: That’s right. Is it Dorset or Somerset, I’m not quite sure?

Mr Beer: The internet suggests Yetminster is in Dorset.

Christopher Gilding: Okay.

Mr Beer: If we go over the page, please, and look at the agenda for this meeting with the two MPs, we can see who was going to be present: Messrs Arbuthnot and Letwin, and then Alice Perkins, the then Chairman of the Post Office; Paula Vennells, the then chief executive of the Post Office; Susan Crichton, the legal and compliance director of Post Office; and Lesley Sewell, chief information officer of the Post Office; and then Mr Ismay and Ms van den Bogerd, and you will see their job titles there.

If we just expand out a little bit, please, thank you, we will see the agenda and, again, under item 6b we’ll see the review of what’s described as the “Tracey Merrick Case”. We’ll see in due course that that’s a reference to Tracey Ann Merritt and that Susan was going to lead on that; that’s Susan Crichton the legal, and compliance director at the Post Office.

So if you just – to give you some context for this document, if we go over the next page, please, you can see that this is a list of key messages for the people that are going to lead Alice, to start with, and then Paula Vennells next. If you just scan.

Christopher Gilding: Can I just say, Jason, at this stage, I was aware that – although I’m not listed on the attendees because I didn’t attend the actual meeting, I was aware that this meeting took place because, as we discussed earlier, where I was asked to show the workings of Horizon System to the legal team, when this meeting was called, I was asked to attend the Post Office headquarters. They had what they called a model office which was a dummy office set up there and I was asked to be there and available in case the Members of Parliament wanted to have a hands-on demonstration.

As it was, when the meeting was finished I wasn’t called, so I didn’t participate in any way but I was aware this meeting was taking place because I was there on stand-by in case.

Mr Beer: Thank you. You weren’t in the room?

Christopher Gilding: Not at all, no.

Mr Beer: Then if we go over the page again, please, to page 4 on the briefing note of what was going to be said, if you just scan that. If you look that second bullet point in the first box:

“Although we recognise that Horizon is not perfect, no computer system is, it has been audited by internal and external teams, it has also been tested in the courts and no evidence of problems found …”

Would that accord with your view at this time?

Christopher Gilding: Indeed it would, yes.

Mr Beer: Did you contribute to this?

Christopher Gilding: No.

Mr Beer: Did you brief up the people that wrote this document?

Christopher Gilding: No.

Mr Beer: Then the next bullet point:

“An upgraded version of Horizon was deployed 2 years ago. Both versions of Horizon were built on the same principles of reliability and integrity.”

Would that match your own view?

Christopher Gilding: Yes, it would, yes.

Mr Beer: “Although we recognise that Horizon is not perfect, no computer system is, it has been audited by internal and external teams, it has also been tested in the courts …”

That seems to be a repetition of the earlier – maybe it’s to emphasise the point.

Then training is dealt with in the next paragraph or the next bullet point. If you just scan that as to what it is said that Ms Vennells, I think, was going to lead on. Then if we go over the page, please. Under topic 5 “Introduction to case review”, the messages were going to be:

“Occasionally we do get incidents of fraud.

“Process … audit, internal review, interview, if can’t be resolved then dismissal for Crown staff, court for subpostmasters (need to explain why).”

There seems to be a record there of a distinction between treatment of Crown staff and subpostmasters. Was that something that you had experience of?

Christopher Gilding: Yes. Only in the fact that the Crown staff were employed by Post Office Limited and –

Mr Beer: SPMs were not?

Christopher Gilding: No, indeed.

Mr Beer: But the difference in treatment. If the incident could not be resolved then “dismissal for Crown staff, court for subpostmasters”; do you know what that’s a reference to?

Christopher Gilding: No, I don’t, no.

Mr Beer: Then there was going to be a review of the Jo Hamilton case. The Inquiry is very familiar with Josephine Hamilton’s case and it seems like the key facts or the pitch was going to be that there were cash holdings; the training was received; there was some audit findings; Ms Hamilton was in personal financial difficulties; she’s provided an opportunity for an explanation; and she did plead guilty to fraud.

Then the again misdescribed as Tracey Merrick case at 6b. There’s an outline of the timeline of events.

Then if we go forwards, please, to page 19 of this document, there is on this and over the following pages a detailed explanation of the Yetminster case, correctly describing the person involved as Tracey Ann Merritt and, again, the Inquiry is very familiar with Tracey Ann Merritt. She was a witness in Phase 1 of our Inquiry and gave evidence to us about what happened to her, including how the prosecution of her left her suicidal.

Can we move through this, please. It says that:

“The defendant [as she’s described] had been employed as a postmistress for over four years. Ms Merritt worked the Yetminster Post Office, but also operated an outreach Post Office at Chetnole.

“An audit was conducted that Yetminster Post Office on 29 September 2011 following concerns raised by a former holiday relief worker at the Yetminster branch in August 2011 over alleged cash shortages.”

Then:

“Mr Constant and Mr Gilding arrived at the Yetminster Post Office at 8.30 am …”

That is, am I right, a reference to you?

Christopher Gilding: It is, yes.

Mr Beer: You remember auditing the branch?

Christopher Gilding: I do, yes.

Mr Beer: In this two-year period, I think it would be, as you now described it, how many audits did you conduct?

Christopher Gilding: I honestly can’t remember. It would have been in the high – I would say around about 100 but it may have been less, it may have been more.

Mr Beer: So one a week then?

Christopher Gilding: Yes, sometimes there could be two or three in a week but, yes, I would say 50 to 100, but I don’t know the exact number.

Mr Beer: Can you recall anything of the detail of this? As I say, we may be coming back to you later but for now –

Christopher Gilding: Yes. I’ve read this document and, yes, I recollect what was stated here was what happened on the day.

Mr Beer: If we go forwards to page 22 of the document, please, under interview the caution was explained to Ms Merritt. She was interviewed, it’s said, in accordance with PACE and she said the following:

“She denied having taken the money the night before the audit as she had previously advised auditors, and now produced a large document regarding ongoing litigation by Shoosmiths Solicitors over the reliability of the Horizon System.”

Did you conduct the interview?

Christopher Gilding: No.

Mr Beer: Until you read this document, did you know that, in her interview under caution, Ms Merritt said that what she had told you and your colleague was incorrect and was, in fact, blaming the Horizon System?

Christopher Gilding: No, I didn’t know that.

Mr Beer: What involvement did the auditors have in the subsequent investigation of a subpostmaster for the purposes of prosecution?

Christopher Gilding: After we’d attended and produced the audit report, we had no further involvement. That was handled by the contracts adviser and the security team.

Mr Beer: In the course of this audit, you would have been applying the attitude of mind that you described earlier; namely, the system’s robust, nothing’s wrong with the data, it’s down to the subpostmaster?

Christopher Gilding: Yes, and as this audit report states, there was a shortfall in the cash and there was a personal cheque from the postmaster that was in the till and when questioned as to why there was a personal cheque in, as it says there, she gave us a statement that she’d taken the cash for personal reasons.

Mr Beer: You now know that she says that’s incorrect and that it was the Horizon System and, in fact, I think you now know that the prosecution against her was discontinued, don’t you?

Christopher Gilding: I have heard that since but that was not what we were told at the time.

Mr Beer: No. Did you ever think when conducting audits that “What we might be” – “What might be being said to us was inaccurate and caused by upset and panic”?

Christopher Gilding: So part of our remit was, once we conducted an audit, if we were to find a discrepancy, like in this case, we were to ask the postmaster for an explanation and that would just be noted and a signature gained from the postmaster to confirm that that was what was discussed. We would not engage in any kind of investigation or questioning because that would – could possibly have endangered any future questioning carried out by the security team. So our role was purely to record what was said at the time and record that and pass that on.

Mr Beer: Thank you. That document can come down now.

Can we go back to your witness statement, please, and paragraph 25 which is on page 4 of the witness statement. WITN05380100 at page 4, please.

You tell us in the witness statement at paragraph 25 that you were never made aware of any bugs or defects with Horizon, correct?

Christopher Gilding: Correct, yes.

Mr Beer: Can we therefore look at a small number of documents, please. Firstly, FUJ00052407. This is a PinICL 54313. You’re aware of what PinICLs are, aren’t you?

Christopher Gilding: Can you remind me?

Mr Beer: Well, I’m not going to give evidence but can you recall what a PinICL was?

Christopher Gilding: No.

Mr Beer: Do you remember a system where you could call in to a centralised facility issues or problems with the operation of the Horizon System?

Christopher Gilding: Yes. So there was – we had a Network Business Support Centre which was a telephone helpline and one of the options was if you had issues with Horizon you could call them.

Mr Beer: This is a record at their end –

Christopher Gilding: Right, okay, thank you.

Mr Beer: – of such a call. Can you see that in the top line, underneath the title, it says “Opened” 19 September 2000, and the customer is recorded to be you?

Christopher Gilding: I can see that, yes.

Mr Beer: If we go two boxes to the right, we can see it’s recorded to be you.

If we go down to the big box, the activities box, we can see that it deals with a call opened, as we saw, on 19 September 2000 where the caller is having problems balancing. Can you see that?

Christopher Gilding: Yes, I can see that.

Mr Beer: That the postmaster is trying to balance and it is saying “cannot balance while transfers are in progression”. Then if we go down to over the page, to the entry at 7.52, there are lots of entries for 7.52 but the first one – thank you – Rakesh Patel says:

“I applied the outstanding transfers workaround and have confirmation from the PM that this was successful.

“The PM has agreed closure of this call.”

Do you remember this problem, calling in that a postmaster was trying to balance and couldn’t balance whilst transfers were in progression and a workaround was applied?

Christopher Gilding: No, I don’t remember. I’m not sure why my name is on there because the office code is that of a Crown Office and I was a Crown manager at the time and the person named as the caller on the third line was my assistant manager at the time. So I’m – from what I’ve read there, it would appear that he was dealing with this and I don’t have any recollection of it at all.

Mr Beer: You say in your statement – we needn’t turn it up – in paragraph 108, when you were shown this document by the Inquiry many months ago, that you recalled that the sum wouldn’t roll over if there were outstanding transfers.

Christopher Gilding: Yes, that was part of the Horizon balance process. If you were in an office like a Crown Office where there were multiple stock units, if there were outstanding transfers from one stock unit to another, ie stock A had transferred an amount out but stock B had not accepted it, then the office accounts rollover procedure would not be able to take place because there was an outstanding figure.

Mr Beer: Did you know that you would have to ring technical support for them to apply a fix, a workaround, to allow that to happen?

Christopher Gilding: No, I didn’t because, personally, I didn’t come across that situation.

Mr Beer: What did you know about that problem then? In what context did you know about it because this appears to be a record of a system error with Horizon that has a fix applied to it, a workaround applied to it?

Christopher Gilding: I’ve no recollection of ever being involved in this and, until I saw this document, that’s the first that I’d seen of a workaround.

Mr Beer: So your name is being used in vain in this document?

Christopher Gilding: I wouldn’t say “in vain”. It may have been put on there because I was the manager of that particular branch –

Mr Beer: Would that have been right – sorry, to speak over you – at that time, at September 2000?

Christopher Gilding: I believe so. I believe so. I’m not sure which office I was at at the time but, looking at the office code and the name of the other person who was my assistant manager at the Southampton branch, so round about 2000 I would have been in Southampton branch.

Mr Beer: Can we look at a different PinICL, please. Again, I think you’ll be familiar with this because we’ve given them to you in advance and it’s clear from what you just said that you have pored over them very carefully. FUJ00076367.

Can you see that this is 25 October 2000?

Christopher Gilding: Yes.

Mr Beer: The PinICL is opened and the customer is recorded as you again, yes?

Christopher Gilding: Yes.

Mr Beer: Are you going to give the same answer as before: this is nothing to do with you?

Christopher Gilding: No, I’m not going to give that answer. However, looking at this, it’s a report – what – the enquiry made is to do with a supplementary report that was produced as part of the accounting process and what was being queried on this occasion is why a supplementary report had additional figures on that were different to what was being reported in the account itself and what was eventually brought to our attention, so myself and – well, particularly me, was the fact that I was incorrectly reading the report that was being produced.

Mr Beer: So shall we go through the PinICL, please.

Christopher Gilding: Sure.

Mr Beer: Looking at the big box at activities, third line:

“… has reprinted a [customer’s] revenue for week 29” –

Christopher Gilding: “Counters revenue”.

Mr Beer: Sorry, I’m so sorry:

“… counters revenue for week 29 and it is showing the week numbers for 29 and 28 mixed as the grand total.”

Can you decode what that’s saying, please, if this was your message to support?

Christopher Gilding: The counters revenue was a supplementary report that was printed as part of the balance procedure for the office and the counters revenue was where items were recorded. So, for instance, the Post Office at the time was selling different forms of stationery and because there wasn’t a product code attached on Horizon to the stationery, that’s where the sales would appear as part of the counters’ revenue. So the counters’ revenue would be a breakdown of those sorts of things.

So the figure that would appear at the bottom of that report would agree with the corresponding line on the account and, on this occasion, the two were – on the report had been amalgamated or appeared to have been amalgamated.

Mr Beer: Now, there is lots of – this is a long PinICL, this one, and if we just look at some entries, please, look at the third page, please, after it’s been allocated by a John Simpkins to a Steve Squires on 26 October it – if you look on the 25th – sorry, before the allocation, about ten lines in:

“Will pass to SSC …”

Can you recall what the SSC was?

Christopher Gilding: No.

Mr Beer: “Could this be a new CI4 Bug?”

Were you aware of that bug?

Christopher Gilding: No.

Mr Beer: Was these ever discussed with you on the telephone?

Christopher Gilding: No.

Mr Beer: Then the allocation that I mentioned at the foot of the page, please, allocated, two lines from the bottom, to Steve Squires to investigate. Then over the page, please, to page 4 three lines from the bottom the call record has been transferred to the EPOSS development team. Did you know what EPOSS was?

Christopher Gilding: EPOSS is Electronic Point of Sale, as far as I’m aware.

Mr Beer: Were you ever told of any difficulties or problems with the EPOSS part of Horizon?

Christopher Gilding: No.

Mr Beer: So that would fall within that attitude of mind that you had –

Christopher Gilding: Yes.

Mr Beer: – that everything was tickety-boo?

Christopher Gilding: Yes.

Mr Beer: Can we move on, please, to page 5. When the issue’s investigated, it seems that a Mr Kay had problems tracking the issue, because of missing messages in the message store. Did you know what the message store was?

Christopher Gilding: No.

Mr Beer: He records:

“I have traced through this problem and by looking at the message store I find that all the stock unit markers are correct, the office reprint markers are correct and the WP level seems to be sufficiently high to include the fixes for some known problems in this area.”

Was any of this ever fed back to you –

Christopher Gilding: Absolutely not.

Mr Beer: – that there were known problems?

Christopher Gilding: No, until I was shown this document as part of the bundle, I’d not seen any of this information before.

Mr Beer: What did you think when you saw it?

Christopher Gilding: I didn’t understand it, to be honest.

Mr Beer: “However, looking that audit logs I cannot find any evidence of the Counters Revenue reprint being printed. I tried to build the message store from the attached file and failed due to missing correspondence server messages.”

Do you know what any of that means?

Christopher Gilding: No.

Mr Beer: If you had been told at the time, it would have been gobbledygook to you then?

Christopher Gilding: It would have been, yes.

Mr Beer: Can we go to page 6, please, four lines in it seems that Mr Squires called your branch. You weren’t available. Mr Kemp, your assistant, said he would do a reprint to see if the problem still occurs, “However, as the office is very busy this is unlikely to be before 14.00”.

Christopher Gilding: Right.

Mr Beer: Then over to page 7 – I’m not going through every line here, you will appreciate, it’s just looking at the sort of key points as the issue developed. On page 7, there are a number of entries about evidence deletion. Can you see that?

Christopher Gilding: I can see that, yes.

Mr Beer: Now, in due course, we may have to enquire of Mr Squires about who it was who made those entries and what they mean, why evidence was being deleted from the message store or whether any other evidence was deleted.

But if we look forwards, please, to 8 December at the foot of the page, I don’t know at the moment exactly what this means where a deleted – sorry, a previous user appears to have been deleted but there’s a record that, I think, Mr Kaiser is making these entries, albeit in February 2002 or 2 February.

In any event, the text is:

“I have looked at the new attachments, and they are not what Steve Kay asked …”

If we go over the page, please:

“… for on [20 November]. In order to recreate the problems we need …”

Then there’s a list of things that are needed:

“a FULL message store (ie every single record from every counter and correspondence server)

“the audit logs from the counters on which the reports were produced AND the date on which they were printed.”

Then he records or someone records:

“From what I could see within the message store that was supplied, the problem with Redeemed Stamps report could just be a case of user misunderstanding. This report (& Counters Revenue) are Office Weekly reports that are not cut-off. So if the user prints them, then carries out further transactions between that time and the point of office rollover, any reprint produced in future [Cash Accounting Periods] will be different from the originals.”

Then if we go forwards to 11 December, which is on page 9, we can see at the foot of the page that the full logs are added and on 15 December, which is on page 10, it’s recorded at 17.07.21:

“Problem diagnosed and a code/data fix has been applied …”

Were you informed of that?

Christopher Gilding: No.

Mr Beer: That they had applied a data fix –

Christopher Gilding: No.

Mr Beer: – at the other end?

Christopher Gilding: No, and I have no idea what that is.

Mr Beer: Were you told anything to the effect that, “Look, there’s a problem with the Horizon System. We’ve changed some code” or “We’ve applied a data fix in order to mend it”?

Christopher Gilding: No.

Mr Beer: So what were you told?

Christopher Gilding: I honestly can’t remember. I’m not aware of – we looked at a statement just now that said that the report, if not cut off from the previous cash account, could duplicate the figures and I believe that’s what we were told but I can’t say for definite that’s what we were told, that this was the early days of Horizon System and we had not followed the right process and that we hadn’t cut off this particular report at the end of the cash account period, hence why the duplication of the following months and the previous months on this one report.

Mr Beer: So in your mind this was another case of Horizon being robust, reliable and perfect but, in fact, the user error, ie you in your office, getting it wrong?

Christopher Gilding: Yes, but I was never made aware of anything else that’s on this.

Mr Beer: Thank you.

Mr Beer: Sir, we’re at 11.15. Might that be an appropriate moment to take the morning break?

Sir Wyn Williams: I was just unmuting myself. Yes, by all means, Mr Beer. What time shall we start again?

Mr Beer: Let’s say half past please, sir.

Sir Wyn Williams: Fine. Thank you.

(11.15 am)

(A short break)

(11.31 am)

Mr Beer: Sir, good morning. Can you see and hear me?

Sir Wyn Williams: Yes. Yes, I can.

Mr Beer: Mr Gilding, can we look at a third PinICL, please FUJ00077691. Can you see that this one is dated 3 October 2000 as having been opened –

Christopher Gilding: Mm-hm.

Mr Beer: – and the customer is recorded as being you again?

Christopher Gilding: Mm-hm.

Mr Beer: I think you have had the opportunity to look over this PinICL as well.

Christopher Gilding: Yes.

Mr Beer: You will see the entry under “Activities”, third line in:

“Critical event … Error in Riposte API call Access is denied … No KEL for this particular NT error.”

Can you recall calling a helpline or similar in relation to this?

Christopher Gilding: No.

Mr Beer: Have you had the opportunity to read the PinICL?

Christopher Gilding: I have, yes.

Mr Beer: Can you recall what was reported back to you?

Christopher Gilding: I have no recollection of this at all.

Mr Beer: I’m not going to go through it all, not least in the interests of time and it’s quite a long record, but the long and the short of it was a decision was taken in the course of the investigation of the bug that not – that the root cause of the bug needn’t be investigated and that the bug needn’t be fixed. But you can’t remember what was reported back to you?

Christopher Gilding: I have no recollection of this event at all. The fact that the case is opened at 3.43 in the morning, I certainly wouldn’t have been in the office at that time.

Mr Beer: No.

Christopher Gilding: So why my name is attached to that I have no idea.

Mr Beer: Can you recall any communication over this issue?

Christopher Gilding: No, nothing at all.

Mr Beer: You’ve informed us – that can be taken down, thank you – that you had what I described as an attitude of mind, a state of belief, on the basis of what another POL employee said to you in the course of your training on Horizon, that they said Fujitsu had said.

Christopher Gilding: Mm-hm.

Mr Beer: When you were carrying out training, did you pass that on?

Christopher Gilding: No.

Mr Beer: Why not?

Christopher Gilding: Because it was something that had been said as part of the training and the reason that I – the reason it was explained in the initial training to us that it was the second best –

Mr Beer: “Second most secure”, I think was the phrase you used in your witness statement.

Christopher Gilding: – was because as employees of Post Office we were sceptical because it was new technology. Everything had always been paper-based so we had a lot of people (a) who were having to deal with technology for the first time and there were concerns about, obviously, using a computer system that a lot of people hadn’t used and so this statement, I believe, was made to reassure people. Because the payment of pensions and allowances were taking place at post offices at the time, I believe that the statement was made to reassure us that the system was secure as regards people’s information for pensions.

But when I did any additional training, I would not have used that statement.

Mr Beer: Just help us: you said that you think it was given as reassurance to you. Why didn’t you pass on the reassurance when you were training?

Christopher Gilding: I may have done. I can’t honestly say I didn’t. I may have done but it was not something that was part of any script or training plan that was given.

Mr Beer: But what you didn’t do in the course of training, was to say that “In the nine years [by then] that I’ve been using Horizon, I have been informed of a series of errors, bugs and defects in it”, because you hadn’t?

Christopher Gilding: No. Because I hadn’t.

Mr Beer: Nobody was telling you about things that were known by the Post Office and Fujitsu about problems in the system?

Christopher Gilding: Absolutely.

Mr Beer: Therefore, you weren’t training people that there were such bugs?

Christopher Gilding: I was training people on the knowledge that I was given and that was that it was a secure system. There was no indication of any bugs or defects at any stage whilst I worked for the Post Office.

Mr Beer: You have explained to us the basis on which you came to that conclusion earlier as, in part, on what you were told and, in part, because you never had cause to investigate the data that the system itself was producing?

Christopher Gilding: Yes.

Mr Beer: You assumed it was accurate?

Christopher Gilding: Yes.

Mr Beer: In terms, speaking generally to start with, turning to training, would it be right to say that there were two types of training that were given: one was training to new employees, entrants to the Post Office estate for the first time, so new joiners?

Christopher Gilding: Yes.

Mr Beer: And then, secondly, training about Horizon to existing employees?

Christopher Gilding: So what sort of timescale are you thinking about?

Mr Beer: Right from the beginning. So when Horizon was being rolled out, they were the two types of training that were going on.

Christopher Gilding: So when Horizon was rolled out I was part of the Crown Office network. I was not in the training team. So from my personal introduction to Horizon, I, as a Crown manager, attended a two-day course but what training took place for Horizon at sub office network, I don’t know, because I wasn’t part of the team then.

Mr Beer: You weren’t part it. So when it came to 2009 and you started to deliver training, were you trained as a trainer. I think your witness statement says no.

Christopher Gilding: No, I wasn’t. I was – because I had previously been a trainer when I was on the reserve instructor trainings, so I had experience of delivering classroom training, and because of my years of experience as a branch manager and using the Horizon System there, it was decided that that was a fit for the role, so no additional training was required.

Mr Beer: Were you training new recruits?

Christopher Gilding: Not directly. You mean new joiners to the Post Office?

Mr Beer: Yes.

Christopher Gilding: Not on a regular basis. That was the role of my team. I was –

Mr Beer: You were supervising –

Christopher Gilding: I was supervising the team, basically. There were odd days where I would stand in if one of my team was unwell and we just couldn’t arrange cover. So I might step in to deliver that day or morning’s training until a relief could be arranged. But that would be the only times I did any classroom training.

Mr Beer: But the function of the team that you managed was to train new joiners?

Christopher Gilding: Primarily new joiners, yes.

Mr Beer: Primarily –

Christopher Gilding: Yes, it was new joiners, yes.

Mr Beer: I think you tell us in your witness statement – it’s paragraph 10 – maybe if we just turn that up, please, WITN05380100, at page 2, paragraph 10. You tell us in that paragraph that when you were training back in the mid-’80s, when you were delivering the induction course – that’s for new joiners –

Christopher Gilding: Yes.

Mr Beer: – this was pre-IT and it was six-week classroom course.

Christopher Gilding: Indeed, yes.

Mr Beer: Then I think if we go to paragraph 58, please, which is on page 9, it says:

“Following the introduction of Horizon and the reduction of emphasis on numeracy skills required to balance the branch, the training was reduced to 4 weeks.”

Yes?

Christopher Gilding: Yes.

Mr Beer: Then in paragraph 59, you tell us that:

“This was reduced further to 2 weeks as the product range changed drastically …”

Yes?

Christopher Gilding: Yes.

Mr Beer: So the scheme was six weeks training before Horizon, then four weeks, then two weeks?

Christopher Gilding: Yes.

Mr Beer: Just going back to paragraph 58 there, you say that:

“Following the introduction of Horizon and the reduction on emphasis of numeracy skills …”

What do you mean by that “the reduction on emphasis of numeracy skills”?

Christopher Gilding: Because pre-Horizon, the staff who were working for the Post Office had to have a high level of numeracy because everything was done with pencil and rubber, basically, and you had –

Mr Beer: Ledgers?

Christopher Gilding: Ledgers, yes, basically. However, when Horizon came in, the reports were automatically generated, based on the inputs to the system, so a lot of the calculations were done by the system, rather than the person having to be able to have mental arithmetic and add up columns.

Mr Beer: So did that account from the drop from six weeks to four weeks?

Christopher Gilding: The drop from six to four was primarily around the change – and the same with when we went from four to two, it was all to do with the change of the product range that was being trained. So as the number of products being trained was reduced, so the amount of time required in the classroom was reduced. The training in the classroom was very much based around the products and introducing new entrants to the products and their understanding and then the actual use of Horizon in the classroom would be through practice sessions of how to sell those products and then how it was for – accounted for.

Mr Beer: Were there Horizon terminals in the classroom?

Christopher Gilding: Yes, there were.

Mr Beer: Could you facilitate or demonstrate rolling over the accounts in the classroom?

Christopher Gilding: No.

Mr Beer: Why couldn’t you roll over in the classroom?

Christopher Gilding: Because the information from the software allocated to the classroom, they were given a branch code which identified them as we a training unit, so that was to ensure that any transactions put through a classroom terminal did not go into the live server.

Now, because it was a training unit, it wouldn’t – the system wouldn’t allow the branch to be rolled over. So, at the start of each training course, the trainer would go in before the course started and reset all the terminals to a certain starting position with amounts of cash and stock and then, when the balance procedure was shown, we could go as far as producing the reports and checking the stock against the printouts but we couldn’t then progress to roll over to the next accounting or trading period.

Mr Beer: So the people being trained were being trained on equipment that didn’t enable them to be trained about progressing from one accounting period to the next?

Christopher Gilding: That’s correct.

Mr Beer: Wasn’t that –

Christopher Gilding: So that training – sorry, that would have been covered with the on-site training. So after attending the classroom, the subpostmasters had a trainer with them for the first two weeks of Go Live. So that was part of the online, to show how that that finalised.

Mr Beer: Wasn’t that a flaw in the training being offered?

Christopher Gilding: It was but there was – because of the restrictions on the terminals, there was nothing that we could do to actually demonstrate that. We had handouts that explained how the process worked but we couldn’t physically walk them through it.

Mr Beer: Did anyone ever raise this, “Can’t we create a training environment which doesn’t connect to the live estate and we can roll over from one week to the next”, because it’s something that the subpostmasters are going to be doing every week, on a weekly basis, for the rest of their working lives?

Christopher Gilding: Yes, and the question was asked and I don’t know who by but, generally, by our team and us as team leaders, and we were just told, no, the technology wasn’t available.

Mr Beer: So a “computer says no” answer?

Christopher Gilding: Basically, yes, sort of thing, yes.

Mr Beer: Did you view that at the time as a significant flaw, that there was a disconnect between how people were being trained in the classroom, as opposed to the situation that they would experience live time in their offices?

Christopher Gilding: Not as a direct flaw because the – what we would show them in the classroom would take them right up until the closing of that account. The only thing they wouldn’t see was how those figures were taken forward so the final figures on that account would appear as the starting figures on the next account. That’s the only thing they wouldn’t see.

Mr Beer: If we just go back to paragraphs 18 and 19 of your witness statement, please, which is on page 3. We’re dealing with a different type of training here, which was when Horizon was first introduced into the Crown network. You say:

“… all staff attended a one-day face-to-face training event, which had a very hands-on syllabus. All staff were trained on how to access the Horizon System, how to enter transactions via the customer facing screens and how to balance an individual stock unit at the end of the balance period. This included ‘rolling’ the [stock unit] into the next [balance period].”

How was it that that was able to be trained ten years earlier and ten years later it wasn’t?

Christopher Gilding: So what I’m saying there is we were shown how to use the equipment. The rolling over to the next bit was not done on the terminals. Again, that was done via a handout explanation.

Mr Beer: So the similar limitation –

Christopher Gilding: Absolutely.

Mr Beer: – applied?

Christopher Gilding: Yes.

Mr Beer: When you were managing the team, was feedback ever given by your team members as a result of the training that they delivered, that tutees were finding difficulty with balancing?

Christopher Gilding: So each training event there was feedback collated. However, that was sent to – that was collated and sent to an external company who would provide the summary of that feedback to the senior managers.

Mr Beer: Who was the external company?

Christopher Gilding: I can’t remember. I can’t remember.

Mr Beer: Okay.

Christopher Gilding: For some reason, I have a thing that they were based in Totton in Southampton but I couldn’t tell you their name.

Mr Beer: So they were responsible for receiving feedback –

Christopher Gilding: We had feedback forms that we would give to the delegates. They would be placed in a prepaid envelope, sent to this company. They would then create the data from the feedback and send that to our network business – to the national training team up in Salford.

Mr Beer: Did you ever get to see that?

Christopher Gilding: The only part of that I ever got to see was if there were specific comments made about individual members of my team.

Mr Beer: What, and they were extracted?

Christopher Gilding: Yes.

Mr Beer: What was that?

Christopher Gilding: That was felt to be part of a training tool for the individuals, any learning points that came out from feedback from delegates about the individuals.

Mr Beer: What about the substance of what they were saying rather than the identity of the trainers?

Christopher Gilding: So that was being fed into the national training managers who were making decisions about how the training was run and what training would be delivered and how it would be developed. So as – in my role, as managing the team, for the majority of the time I had no involvement in that side of things.

There was after a later – another reorganisation, where part of that responsibility came down to us as field team leaders, where we were asked to input into different training reviews but, again, we were only asked for our comments. We didn’t actually action those reviews.

Mr Beer: Can we look at that, please.

Christopher Gilding: Yes, indeed.

Mr Beer: I think you are referring to POL00005850. We can see at the bottom left training for quarter 3 review of December 2011. Is this a record of the exercise that you had just mentioned?

Christopher Gilding: Yes, it is, yes.

Mr Beer: You’ll see the way that the document works. The individual who is providing the feedback referred to as a stakeholder.

Christopher Gilding: So these individuals, are they field team leaders across the country?

Mr Beer: Yes, and they presumably have pulled this from –

Christopher Gilding: From their teams.

Mr Beer: – from their teams.

Christopher Gilding: Yes.

Mr Beer: So the individual who is providing the feedback who is described as the stakeholder sets out a requested change and then the response to that is given in the far right-hand column.

Christopher Gilding: Yes.

Mr Beer: If we go forward to page 5, please, I think we can see yours.

Christopher Gilding: Mm-hm.

Mr Beer: Just to understand what you’re saying in this document, a number of the columns say “lose” and some say “change”. When you say “lose” and then there’s a number, what’s the number referring to?

Christopher Gilding: So, for instance, “Lose 46 Cash Management”, is that what you’re saying me, what 46 …

Mr Beer: Yes.

Christopher Gilding: 46 was the session number within the training event. So each of the different –

Mr Beer: Modules?

Christopher Gilding: – yes – were all given session numbers.

Mr Beer: And you’re suggesting nationally that module 46 should be removed because, and then you give the reason?

Christopher Gilding: Yes.

Mr Beer: I just want to ask you about an entry halfway down the page, starting stock balancing. It reads:

“Stock balancing is only 2 slides and that is talking about cash management, which has already been covered in an hour’s session. It needs to have more reference to all aspects of balancing – for example, TP and …”

By that you mean “transaction processing”?

Christopher Gilding: Trading periods.

Mr Beer: And balancing periods?

Christopher Gilding: Yes.

Mr Beer: “… net discrepancies’ settling centrally, transaction corrections and rems.”

Christopher Gilding: Remittances.

Mr Beer: We know what remming in and out is, it’s all right.

Can you tell us on what basis were you making that suggestion?

Christopher Gilding: So that was – so the actual stock balancing session was very much a practical session and these two slides were – at the start of the session were an introduction to what the delegates were about to do and how they should complete the balance in the training environment.

But, as I’ve said with the outcome, there was very little explanation around terminology and the accounting procedures for losses and gains and it was important that once they left the classroom that the delegates were aware of how they correctly accounted for losses and gains and what the correct procedures were.

Mr Beer: Why is it important to be able to account for a gain or a loss?

Christopher Gilding: Because if you don’t account for it correctly, it would impact on your accounts for the following – so you would have false starting figures for your next accounting period.

Mr Beer: What might happen to you?

Christopher Gilding: You might get an audit.

Mr Beer: You might get?

Christopher Gilding: You might get an audit.

Mr Beer: Annoyed?

Christopher Gilding: An audit.

Mr Beer: An audit?

Christopher Gilding: You might get a visit from the audit team.

Mr Beer: What might happen then?

Christopher Gilding: That would depend on the outcome of that particular audit.

Mr Beer: You might get sacked?

Christopher Gilding: Not necessarily.

Mr Beer: You might get prosecuted?

Christopher Gilding: Not necessarily.

Mr Beer: It’s been known to happen, hasn’t it?

Christopher Gilding: It has been known to happen but that’s not the primary role of the audit.

Mr Beer: You said that the primary role of the audit was actually to help people.

Christopher Gilding: Yes, to identify discrepancies and how they may have occurred.

Mr Beer: Is that how your team saw it, the auditors that went in, that “We’re there to help people, not to act as investigators, to pass on information to investigations division” –

Christopher Gilding: No, our role was purely to go in and identify the situation in the branch, to assist in any way we could and then pass that relevant information on to the contracts advisers and the security team.

Mr Beer: You are recording this in December 2011; so 10 or 11 years after the introduction of Horizon, you’re making the point that the training on balancing is inadequate or needs to be changed?

Christopher Gilding: Yes, needs to be – but there were training reviews on a regular basis, as far as I’m aware.

Mr Beer: We’ve heard some evidence that feedback that was provided before rollout suggested that training on balancing was inadequate?

Christopher Gilding: Mm-hm.

Mr Beer: We’ve heard evidence that the feedback provided during rollout, a decade earlier, was that the training on balancing was inadequate, and here you are 11 years later saying there are problems with the training on balancing, aren’t you?

Christopher Gilding: Yes, with the – yes, with the training in the classroom.

Mr Beer: The entry in the row below:

“Add more information regarding how a branch works [‘differently’, I think that must mean] between office & stock unit, TPs and BPs, how Horizon accounts for transactions.”

Do you know how it was that – which is essentially the same point as above, isn’t it?

Christopher Gilding: Yes, this is more around explaining what all the different terminologies are. There wasn’t, in my view, enough emphasis on what the different terminology was used, so people could get – yes, they might get confused as to the difference between a trading period and a balance period. So it was to make a lot clearer what the differences were.

Mr Beer: These problems with the training on balancing, were they raised – were you raising this on the basis of what had been said directly to you by recruits or by what your team members had fed back to you?

Christopher Gilding: So this was feedback from the team members.

Mr Beer: Was it fairly consistent across the board?

Christopher Gilding: Yes.

Mr Beer: So not an isolated issue?

Christopher Gilding: No, no. Isolated issues wouldn’t have – would have been dealt with on an individual basis. Items that were put forward as part of the training review were a wider view.

Mr Beer: Can we look, please, at POL00005869, please. This seems to be part of the same process. You’ll see the date in the bottom left.

Christopher Gilding: Right.

Mr Beer: If we turn to page 17 of the document, please, we can see a record of feedback from your team. Can you see that?

Christopher Gilding: Yes.

Mr Beer: Are the entries in the right-hand column from tutees, from recruits?

Christopher Gilding: No, these are from trainers who are running the courses.

Mr Beer: So this is pooling the actual words of trainers in a document, so rather than you speaking for them they are speaking to head office?

Christopher Gilding: Yes, so they are giving me their feedback or thoughts on these sessions and I’m collating that and passing that to the review.

Mr Beer: Somebody says in the second entry for your team, in the second paragraph:

“My initial thought is what has changed. I have already expressed the opinion that we might have missed the boat as far as making changes to the course and still hope this isn’t seen as being negative and unconstructive. It seems to me all we have done is to take the old sessions, update them a little but no longer call them module 1, 2 or 3. I was very aware that this course is still a one size fits all type of course which is aimed more towards which the Crown offices branches. All of this might of course be changed with the network changes, even so, SPMR or Main [Post Office] Branches are not the same as counter assistants in a Crown Office, my feeling is there should be a course written completely from scratch that is aimed specifically at someone who will have to run a branch by themselves after a couple of weeks or so. As a for instance, we could cover rems more fully.”

What’s the essence of the complaint there?

Christopher Gilding: The essence of the complaint is that it is – the training package was a one size fits all, that the style of training was aimed primarily around the products and that – yes, the one size fits all didn’t necessarily fit.

Mr Beer: You said in the course of that answer, the course had been aimed too much at the products or focused too much on the products. Can we just look at what you say in your witness statement, please?

Christopher Gilding: Right.

Mr Beer: WITN05380100, at page 17, in paragraph 102, at the top of the page. Is this what you were just referring to there:

“… I felt the emphasis of the course, and the business as a whole had become too sales orientated and not enough focus was on cash discrepancies within branches.”

Christopher Gilding: Right, so what I’m referring to there as, stated in previous paragraph 101, this is around 2012 when Post Office as a business changed the way that they were operating and that they were going very much for a sales-driven culture, rather – so the changes to the training then were very much around “Here’s the product, here’s how we sell it” and then “How do you now add on additional sales to that product?”

It wasn’t something that sat comfortably with me. That’s not what I do. I’m not a salesman and, whilst that was the direction the business was going, personally it is just my view – it’s not the business’ view – but my view was that there was too much time spent on trying to increase sales rather than paying attention to the accounting and accuracy within the branch.

Mr Beer: You say in this paragraph that there was not enough focus on cash discrepancies within branch. Why did there need to be focus or more focus on cash discrepancies?

Christopher Gilding: So that when discrepancies occurred in the branch, the subpostmaster would have a greater knowledge of how to investigate and also have a full understanding of what support options were available for them as well.

Mr Beer: You say at the end of that paragraph:

“I stress this [is] my view and not that of senior management team who were striving to keep branches afloat by generating new income streams.”

Christopher Gilding: Yes.

Mr Beer: Does that reflect what you were told back at the time?

Christopher Gilding: Yes, yes.

Mr Beer: Is it right that on the course that your colleague referred to in the document that we just looked at, balancing and cash account issues were handled on day 2 of the course?

Christopher Gilding: I can’t remember the agenda of the course but if that’s what they say, then …

Mr Beer: If you can’t remember –

Christopher Gilding: No, I can’t remember the exact agenda of the course.

Mr Beer: Can you recall at any time, until you went over to the Horizon mediation investigation team, that anyone within Post Office suggested to you that any of the problems that subpostmasters and other branch staff might face were due to any issue with Horizon at all?

Christopher Gilding: No.

Mr Beer: Thank you very much. They are the only questions I ask at the moment. I think there are some other questions.

Yes, Mr Jacobs.

Questioned by Mr Jacobs

Mr Jacobs: Mr Gilding, good afternoon. I ask questions on behalf of 156 subpostmasters, assistants and managers who are represented in this Inquiry by Howe+Co. I want to ask you about some points in your statement that you make about Horizon training and subpostmaster user errors. I am going to take you to three paragraphs in your statement. The first paragraph is paragraph 43 and the reference for that, I see is already on the screen, is at page 7 of 19.

Sir, can you hear me a bit better now?

Sir Wyn Williams: I can hear you clearly or more clearly than that last.

Mr Jacobs: Thank you, sir, I think the microphone was too far away. At paragraph 43, you say:

“Informal and formal feedback was given at each event to the trainer.”

Are you able to say whether you received any feedback or whether feedback was given after the event, after training had completed, or concluded?

Christopher Gilding: So the feedback I’m referring to there is from the paragraph above, which states that part of my role was to attend training events whether that be classroom or on-site and, as a result of what I observed and as part of a training and development for the individuals, I would give informal and formal feedback to that trainer based on my observations.

Mr Jacobs: You would give feedback, right.

Christopher Gilding: But that was purely on observations conducted.

Mr Jacobs: What about feedback given by the subpostmaster to the trainer or the training team?

Christopher Gilding: As part of the on-site visits that I would conduct with the trainers, I would have a discussion with the subpostmaster and ask them for feedback about their training and about the trainer – more – I was more focused on the actual trainer themselves but, obviously, if they gave me information about the training as well, then that was recorded as well.

Mr Jacobs: So, essentially, you were training the trainer?

Christopher Gilding: Yes.

Mr Jacobs: Were you aware of any feedback or complaints about the training that came from subpostmasters after the training had taken place?

Christopher Gilding: No.

Mr Jacobs: Why wasn’t that fed back to you? Are you able to say?

Christopher Gilding: No, I’m not able to say.

Mr Jacobs: Did you listen to the evidence of the subpostmasters who gave evidence in Phase 2 of this the Inquiry – Phase 1, I ought to say – from February to May 2022?

Christopher Gilding: No, I’ve not seen any of that.

Mr Jacobs: Many – then you won’t have seen, and I have to put this to you, many of our clients – and 50 of them gave evidence and the rest were read into the record, and their statements have been exhibited – many of our clients say they received no training whatsoever in balancing in relation to discrepancies, many others requested further training but those requests were refused.

Were you aware of those issues at the time when you were involved?

Christopher Gilding: No.

Mr Jacobs: We’ve looked at 102 of our clients’ witness statements and 95 of these – that’s 93 per cent of our clients – all say that the training they received was inadequate. Why weren’t you aware that there were these very serious issues coming from subpostmasters in respect of Horizon training?

Christopher Gilding: Because it was not part of my role. My role was to train the trainers, not to develop the training course itself. That was down to the senior managers to develop the training courses based on the feedback from postmasters.

Mr Jacobs: What about feedback from those trainers who you trained? 19 of our clients have said in their evidence that shortfalls occurred actually during the training process itself, for which those who were conducting the training were unable to provide explanations. Did you ever hear from those who you trained about those issues arising?

Christopher Gilding: No, and that’s the first time I have heard that statement.

Mr Jacobs: Right. It’s one example, perhaps I ought to put to you Heather Earley, who was a subpostmistress from 2011 to 2017, said that she never completed a balance during training, she wasn’t trained in respect of how to deal with shortfalls and the Post Office trainer who trained her could not make the Horizon System balance. That’s one example of the 19.

Are you not aware of this?

Christopher Gilding: I’m not aware of that and I don’t know who that is or – and may well have been in a different part of the country that didn’t come under my team’s remit.

Mr Jacobs: It was in Antrim, I’m sure she wasn’t trained by you but it’s an example of someone who was being trained at the time when you were involved in training the trainers.

Christopher Gilding: Okay.

Mr Jacobs: You say in your statement then, going back to paragraph 43, that you cannot recall any trainer failing in the delivery of the training, they were dedicated, hard working, regularly went over and above their remit, made themselves available for phone calls after training had concluded and forged strong commitments with subpostmasters.

In light of the evidence, that hasn’t been contested, that our clients and other subpostmasters gave in the first phase of this Inquiry, in relation to the inadequacy of training, do you accept, with hindsight, that trainers must have failed in the delivery of training in respect of the Horizon System?

Christopher Gilding: I can only answer, as it says in my statement there, from the team that I was leading and I was satisfied that the training they were given – that they were delivering was to the standard that was required and I can only answer for my own team. I don’t know the rest of the country.

Mr Jacobs: Well, that was your experience, as you say.

Christopher Gilding: That was my experience, yes.

Mr Jacobs: But this morning in answering questions from Mr Beer, King’s Counsel, in relation to robustness and bugs and defects, you made a concession. You said at the time I thought it was robust but that’s not what I know now. Are you able to say that in relation to training, to make the same concession?

Christopher Gilding: Yes, I could make that same concession but the comment I made about being aware now, that awareness has only come after I’ve left the business back in 2016.

Mr Jacobs: Thank you. If we could then turn to the next paragraph I wanted to refer you to which is paragraph 79 of your statement which is on page 12 of 19, and you say here:

“I believe [in the present tense] the training programme was adequate, the vast majority of trainees were competent in the use of Horizon, able to complete all tasks required for their respective role within the branch.”

In light of what you’ve just said, that you can make that concession, should “I believe” now read “I believed”, in the past tense?

Christopher Gilding: Yes, yes.

Mr Jacobs: In relation to your evidence this morning a follow-on question. You said that you were told by a Post Office trainer that Horizon was the second most secure system in Europe. Do you recall the name of the person who told you this?

Christopher Gilding: No.

Mr Jacobs: The problems that I have referred to, which the Inquiry has heard about in Phase 1 of the evidence and the hearings from February to May, they were problems that you said you weren’t aware of. Do you think there is a reason why you didn’t know about these?

Christopher Gilding: Sorry, I’m not sure what –

Mr Jacobs: These issues with training that had been arising from the Horizon rollout?

Christopher Gilding: Is the reason why I was not aware of them?

Mr Jacobs: Were there meetings of other trainers, issues that were discussed in relation to “Have we heard any complaints, what’s the situation on the ground with these subpostmasters”?

Christopher Gilding: No.

Mr Jacobs: Were there discussions?

Christopher Gilding: No.

Mr Jacobs: Do you think it would have been helpful to you if someone within the Post Office had communicated these issues to you?

Christopher Gilding: Oh, absolutely, yes.

Mr Jacobs: Finally, if we can go to paragraph 91 of your statement and that’s at paragraph 14 of 19, for the benefit of the screen, you say here:

“The only difficulties I encountered with Horizon, were primarily due to user errors, ie incorrect accounting processes followed and, quite often, a reluctance from subpostmasters to seek assistance. Unfortunately there were too many occasions whereby the subpostmaster tried to ‘fix’ discrepancies but actually by incorrect accounting made the situation worse. However I am unable to offer any specific examples at this time.”

Now, we know, and you’ve acknowledged to Mr Beer this morning, that your understanding of the robustness of the system then is not what your understanding is now because of what happened in the Group Litigation because of the reasons that we’re here for in this Inquiry.

Christopher Gilding: Mm-hm.

Mr Jacobs: Are you able then to make the same concession in relation to the errors in the Horizon System being down to user error when, in fact, our clients say that that’s what the Post Office said but it was actually bugs, errors and defects in the system?

Christopher Gilding: Yes. So my statement there is based on my knowledge as somebody who worked for the Post Office and obviously, since I left the Post Office, other things have come to light that I was not aware of at the time. So my statement is based on my knowledge and experience from working for the Post Office.

Mr Jacobs: But what you know now is different?

Christopher Gilding: It’s different, yes, indeed.

Mr Jacobs: Now, you also confirmed with Mr Beer that you had what Mr Beer has described as an attitude of mind or a state of believe in relation to that the system was robust and errors were down to user error by subpostmasters.

Now, the High Court found that this was the prevalent attitude in the Post Office, the system was robust, it was the postmasters’ errors that were causing these problems. From what you can remember and recollect at the time when you were with the Post Office, when these issues with Horizon were arising, did your colleagues share these views, this attitude of mind, about the robustness of the system and the culpability of subpostmasters? Was this widespread, this view?

Christopher Gilding: Yes, it was and when I worked for the mediation team, it was – we were looking at the data from the Horizon equipment. That would have been a pointless exercise if we’d have known that information was corrupt.

Mr Jacobs: I don’t have any further questions but I expect I might have some questions I’m going to be asked to ask you. (Pause)

Sir Wyn Williams: Anyone else?

Mr Jacobs: I apologise, I do have one further question that arises on instructions, sir.

Sir Wyn Williams: All right. Carry on, Mr Jacobs.

Mr Jacobs: Paragraph 91. You say that you are unable to offer any specific examples of incidences when subpostmasters tried to fix discrepancies. Are there any cases or examples that you can remember that are relevant to your evidence of problems that subpostmasters had or experienced that you were aware of?

Christopher Gilding: No, what I’m trying to explain there is there were situations where subpostmasters had identified a shortfall and, rather than seeking assistance from the Network Business Support Centre or requesting a field team adviser to go out and assist them, they were trying to correct things on Horizon and, on several occasions, I witnessed they got themselves totally confused as to which way the accounts were, what was negatives, what was positives and actually, rather than correcting the discrepancy, they were adding to it. So that’s what I’m trying to explain now.

Mr Jacobs: Just one final point. This state of confusion that people were in, might that have been as a result of the training?

Christopher Gilding: It might be a lack of knowledge, yes.

Mr Jacobs: Thank you. I don’t have any further questions.

Questioned by Ms Page

Ms Page: Just one question, please, from me or rather one area of questioning. It’s Flora Page on behalf of a number of the subpostmasters.

What I want to ask you about is how you came to give evidence before the Inquiry. Who approached you, in the first instance, or did you volunteer yourself?

Christopher Gilding: No. I was approached by the Inquiry, via email to provide a witness statement.

Ms Page: In your personal email?

Christopher Gilding: In my personal email, yes.

Ms Page: Do you know how that email was provided to the Inquiry?

Christopher Gilding: No.

Ms Page: Would it have been left with the Post Office when you finished your period of term with them?

Christopher Gilding: I don’t know. I don’t know.

Ms Page: When you left in 2016, it was on terms which were agreed, was it? It wasn’t a dispute between you and the Post Office?

Christopher Gilding: No, it was a voluntary redundancy agreement.

Ms Page: Thank you.

Sir Wyn Williams: Anyone else?

Questioned by Ms Patrick

Ms Patrick: Yes, sir, we have one question on behalf of the Hudgells CPs, thank you.

Mr Gilding, my name is Angela Patrick and together with Tim Moloney KC we represent a number of subpostmasters who were wrongly convicted and who are now represented by Hudgell Solicitors. I have a number of questions about two documents.

Christopher Gilding: Right.

Ms Patrick: It shouldn’t take very long. So we’re going to start with a document which it goes by the reference POL00033486, if that could be brought up I would be grateful. I think you can see there it’s a typed up document and on the left-hand side it says “Do I need a cash remittance?” Beyond that title, I’m just going to ask you to look at the very bottom left-hand corner there. Can, you see that version 4.3, August 2011, Chris Gilding?

Christopher Gilding: Mm-hm.

Ms Patrick: Would this be a document that would have been drafted by you?

Christopher Gilding: So this document was not written by me but within the field team I was – it was one of the documents that I was responsible for making any updates. So the reason it’s 4.3 is, in August 2011 I must have made some sort of update but what that was I can’t recall.

Ms Patrick: You can’t recall. Right. We don’t need to go through it but I’m sure you will take it as read, you can see what’s on the page in front of you.

Christopher Gilding: Yes.

Ms Patrick: It’s a step-by-step guide on how to – Mr Beer has already said we’re already familiar with the terms – how to rem in and rem out; is that fair?

Christopher Gilding: Yes.

Ms Patrick: Now, I want to look at another document, to look at information that was available to Fujitsu at this time when this document was being overseen/approved by you?

Christopher Gilding: Mm-hm.

Ms Patrick: Can we look at what is the technical appendix to one of the Horizon judgments. I don’t expect you to have seen this before, I’m using it for shorthand. The reference is RLIT0000006.

Is that in front of you now?

Christopher Gilding: It is, yes.

Ms Patrick: The front page – I’m only bringing it up so everybody can see – the front page shows that the judgment was in 2019. So this is after your document was produced but we’re, as I say, only using it for reference to the documents that are in the judgment, no reason you would have necessarily seen this.

But I think you have said you are aware the judgments themselves had identified a number of bugs, errors and defects in Horizon. You’re nodding Mr Gilding, you have to say yes or no –

Christopher Gilding: Yes.

Ms Patrick: – for the transcribers, thank you. Yes.

Did you know that a number of those were related to remming in and remming out?

Christopher Gilding: No, I don’t know any of the details of the judgments.

Ms Patrick: If we –

Christopher Gilding: Can I just add that that document that you previously showed me, the remming in and remming out, was a document that was used for new entrant training so only would have been used with people coming into the Post Office from 2011.

Ms Patrick: So who were new?

Christopher Gilding: Yes.

Ms Patrick: It wouldn’t have been circulated to anybody else?

Christopher Gilding: No, it was purely for the training team.

Ms Patrick: So anybody else would have to refer back to their earlier training if they had a problem?

Christopher Gilding: And they would have operations manuals in the branches that explained how the processes worked.

Ms Patrick: We’ll come back to the document itself. But if we can look at a part of the judgment, and everybody will be assured I’m not going to look at every bug, I’m just going to look at one example – if we can look at page 46, please, and go to the bottom of the page and I only really want to look that title here. You can see there at 5 the judge is referring to a “Remming In bug”. Can you see that, Mr Gilding?

Christopher Gilding: Yes.

Ms Patrick: Just above paragraph 181. I don’t need to go any further than to read the start which says:

“This is a Horizon Online bug.”

Then the judge starts to look at the evidence. I want to look at a particular example – a particular paragraph, for some of the detail. So if we could go to page – I’m going to 187, which I think is on page 49 – I apologise to those dealing with the documents, page 48, and it’s at the bottom. You can see some Q&As, the judge is considering some of the live evidence that was given, and at paragraph 187, he goes on to say:

“This evidence does not support the submission that remming errors are picked up by Horizon. It is necessary, therefore, to look at the actual PEAKs …”

Now, you have looked at a PinICL and you couldn’t remember it. A PEAK is like a PinICL. It’s an internal document.

Christopher Gilding: Okay.

Ms Patrick: “… to see what they show. The one associated with what the Post Office called Issue 1, PC0203085, is dated 22 August 2010 and is headed ‘pouch remmed in on two counters at same time’. The first entry under impact statement is …”

It explains here:

“The same pouch can be remmed in to the system more than once, resulting in a shortage at the branch which POL have to rectify by issuing a Transaction Correction.”

If we can scroll down to the next page, please, the judge has looked at other evidence, and he says:

“In my judgment [in the next paragraph] that entry alone is evidence of a bug. It shows a pouch can be remmed in more than once – admittedly rarely – and that a TC [I think we can agree it’s ‘transaction correction’] is necessary to correct this.”

We don’t need to go through all the detail but, if we can scroll down a little more, but while we’re at that paragraph and that judge’s conclusion, had you ever been told that Fujitsu were aware that a bug error or defect existed –

Christopher Gilding: No.

Ms Patrick: – which could show a pouch remmed in more than once?

Christopher Gilding: No, never been told that.

Ms Patrick: Thank you.

Actually, if we can stay at paragraph 188, you can see that in front of you, there’s an entry there from a PEAK from Anne Chambers, which is recorded on 17 August, and she has some details about a pouch and below the numbers it says:

“The [postmaster] cannot reverse the transaction since rem reversal isn’t allowed.”

Can you see that, Mr Gilding?

Christopher Gilding: Yes.

Ms Patrick: Below:

“This is NOT another example of the duplicate rem problem that we have seen in the past, where use of the Prev key accepted the same pouch twice. In this case the pouch was processed on both counters …”

That seems to suggest that there were at least two problems that Fujitsu were aware of, doesn’t it?

Christopher Gilding: It does, yes.

Ms Patrick: That appeared similar. Can you help us first, what’s a “Prev key”?

Christopher Gilding: That’s the previous key. So it would take you back to the previous screen.

Ms Patrick: Thank you. So it’s not that problem that relates to the Prev key that the country problem relates to. But were you told about any bugs, errors or defects which could impact on remittances –

Christopher Gilding: No.

Ms Patrick: – or on any kind of remming in or remming out?

Christopher Gilding: No.

Ms Patrick: Can we scroll down to 192, which I think is on the following page, page 50. I’m skimming over the evidence. But in that paragraph, which I hope you can see now:

“In my judgment, this PEAK is evidence of a bug and a fix is required to remedy it. It also shows that remming in errors are not always picked up by Horizon.”

You said you weren’t told about any bugs or errors.

Christopher Gilding: That’s correct.

Ms Patrick: I assume in that sense you weren’t told that sometimes there were remming errors that weren’t picked up by Horizon?

Christopher Gilding: No, never heard that.

Ms Patrick: As somebody who was involved in training and auditing, would that have been useful information for you to have had?

Christopher Gilding: Of course. It would have been extremely useful.

Ms Patrick: Can we turn back to the first document we looked at, POL00033486, please. I know you’ve said this was only new entrants but let’s see what new entrants were being told. If we can go to page 2 of this document, please, and you can see on that page some bold text. Can you see that, Mr Gilding?

Christopher Gilding: Yes.

Ms Patrick: I will read it for the transcript:

“If you have a discrepancy with any of your remittances, please refer to Horizon Online help facility or contact the NBSC.”

That’s highlighted in bold, isn’t it?

Christopher Gilding: Yes.

Ms Patrick: Can you recall why?

Christopher Gilding: That is – that’s there so that if somebody does have an issue with their remittances and they don’t know how to correct it, then that was to emphasise that the support that was there was either through the Horizon Online help facility or that they should contact by telephone the Network Business Support Centre which was their first point of contact for any support.

Ms Patrick: I mean, at that point when you’re looking at this document, by 2011 were you aware that anybody was raising particular problems with remittances, were you hard anything from the Post Office, from your line management, from your trainers, or from subpostmasters?

Christopher Gilding: No.

Ms Patrick: Nothing?

Christopher Gilding: No, nothing I can recall.

Ms Patrick: But here it’s in bold.

Christopher Gilding: Yes.

Ms Patrick: And it’s relying on essentially the operator to identify that a discrepancy they have is related to a remittance and you’re telling them to contact, in that case, the Helpdesk?

Christopher Gilding: Yes.

Ms Patrick: So if they spot that there is a problem and it’s related to a remittance, contact either the Horizon Helpdesk – and I think we’ve heard that’s HSH but you might not – is that an acronym –

Christopher Gilding: Yes.

Ms Patrick: – or the NBSC?

Christopher Gilding: NBSC, yes.

Ms Patrick: And would it then be up to the Helpdesk, whichever one, to determine what the problem was and whether it might be user error or a bug?

Christopher Gilding: My understanding, although I was obviously not involved in that, is that the information recorded by the NBSC would then be passed on to the accounts department within Chesterfield to look at that individual branch, but that’s not an area I was involved in. That’s just my thoughts.

Ms Patrick: So just to be absolutely clear, before you looked at this document – you didn’t draft it but you were responsible for oversight of it –

Christopher Gilding: Yes.

Ms Patrick: – did anybody discuss with you that there might be bugs in Horizon related to remming?

Christopher Gilding: No.

Ms Patrick: Did anybody discuss with you that there might be errors in remming which were not spotted by Horizon?

Christopher Gilding: No.

Ms Patrick: As someone who has done remittances and who has used Horizon yourself in a post office, would that have been useful information for you to have had?

Christopher Gilding: Yes.

Ms Patrick: Thank you. I don’t have any more questions for you, Mr Gilding.

Mr Beer: Sir, there are no more questions but, just before we end Mr Gilding’s evidence session, can I just ask for one document to be brought up on the screen. It’s POL00029492. It’s the document prepared for the high level meeting with Messrs Arbuthnot and Letwin that I took Mr Gilding to earlier. You will see it says that the meeting is scheduled for 17 May 2010. That is as the document appears.

It’s been helpfully drawn to our attention that there are the other versions of this document which suggest that the meeting was, in fact, on 17 May 2012.

The Witness: I honestly don’t know which this correct date.

Mr Beer: I wasn’t –

The Witness: Sorry.

Mr Beer: I wasn’t inviting an answer. I was more addressing this to the Chair.

The Witness: Okay, sorry.

Mr Beer: No, that’s all right. No need to apologise. I just make that clear. We’ve got in the Inquiry literally dozens of versions of this document from various sources. We’ll investigate that error on the face of the document provided by, in this case, the Post Office but –

Sir Wyn Williams: All right, Mr Beer. That’s fine. I’m sure we can satisfy ourselves what the correct date is with appropriate investigations.

Mr Beer: Yes, thank you very much, sir. Subject to that, that’s the end of Mr Gilding’s evidence.

Questioned by Sir Wyn Williams

Sir Wyn Williams: Thank you, Mr Gilding. I’d just like to get one thing straight in my mind, if I may.

Christopher Gilding: Indeed.

Sir Wyn Williams: I want you to think about the time period 2009, when you first began to become involved in a formal sense with managing teams of trainers and auditors –

Christopher Gilding: Mm-hm.

Sir Wyn Williams: – and the 2015 when your secondment to the mediation investigation came to an end. So I’m focusing on that approximately six-year period. You’ve been asked a number of questions about your own mindset and I take it that the mindset – your own mindset in relation to the robustness and reliability of Horizon, and I take it from what you said that each of the teams you managed, in whatever capacity, in that same period shared your mindset.

Christopher Gilding: Yes, that’s correct.

Sir Wyn Williams: To what extent, if at all, was there discussions as between different teams? In other words, were these teams kind of self-contained and just went about their business in a vacuum or, from time to time, would there be cross-fertilisation, if I can put it in that way, between other teams doing the same job?

Christopher Gilding: There was occasions where we would cross over with other teams. So my team in the south would sometimes cross over with the London team. So, yes, there was a crossing-over between the teams on occasion.

Sir Wyn Williams: Right. And in those sessions, were there ever any occasions when the reliability or robustness of Horizon came under discussion?

Christopher Gilding: Not that I can recall.

Sir Wyn Williams: So that I don’t get a false impression about this, was that because it simply didn’t arise or was it because, so far as you can judge, every other team shared the same view of Horizon as did you and your team?

Christopher Gilding: I would say the latter, that everybody shared the same view about the Horizon System.

Sir Wyn Williams: So is this a fair point for me to take from your evidence, that in this period when you were dealing with teams who were looking into either audit or training or the like, is it true that everyone you came across who was engaged in this all had the same view of Horizon?

Christopher Gilding: As far as I’m aware, yes.

Sir Wyn Williams: All right, thank you. Thanks very much, Mr Gilding, for your willingness to answer a great many questions this morning and for providing a witness statement as well. I’m grateful to you.

Christopher Gilding: Thank you.

Mr Beer: Sir, can we say 1.40 to start the next witness, please?

Sir Wyn Williams: Yes, certainly. Fine.

Mr Beer: Thank you very much.

(12.43 pm)

(Luncheon Adjournment)

(1.40 pm)

Mr Stevens: Good afternoon, sir, can you see and hear me?

Sir Wyn Williams: Yes, I can. Thank you.

Mr Stevens: If I may call Kathryn Parker.

Kathryn Parker

KATHRYN PARKER (sworn).

Questioned by Mr Stevens

Mr Stevens: Thank you. As you know, my name is Sam Stevens and I ask questions on behalf of the Inquiry. Please could I ask you to state your full name?

Kathryn Parker: Kathryn Frances Parker.

Mr Stevens: Thank you for giving evidence to the Inquiry today and providing the written statement, which I would like to turn to now, which should be in the bundle in front of you.

Kathryn Parker: Yes.

Mr Stevens: Is that dated 10 December 2022 running to 11 pages?

Kathryn Parker: It is, yes.

Mr Stevens: Could I ask you to turn to page 9 of the statement. Is that your signature?

Kathryn Parker: It is, yes.

Mr Stevens: Are the contents of that statement true to the best of your knowledge and belief?

Kathryn Parker: They are.

Mr Stevens: That now stands as evidence in the Inquiry but I will be asking you some further questions. I’d like to start with your background. You say that you joined the Post Office in 1984.

Kathryn Parker: Yes.

Mr Stevens: That was in its graduate training programme?

Kathryn Parker: That’s right, yes.

Mr Stevens: What was your first substantive role with the Post Office?

Kathryn Parker: I was – as a graduate, I was attached to Counter Services 1.1, which was a team that was looking at the Post Office network in terms of coverage, as far as I remember, and then I had a variety of other roles.

Mr Stevens: Could you just give a summary of roles you had up until 1998.

Kathryn Parker: Up to 1998. Okay, apologies, I didn’t bring my CV with me, so I’m going to struggle a little as to the order in which they came. I stayed in Counter Services for a number of years after I finished the graduate programme. I then went over to the – I transferred over to the Post Office to work for the company secretary where I headed up a services group for the company secretary. I then came back to Post Office Limited in 1995.

Mr Stevens: Would that be Post Office Counters Limited?

Kathryn Parker: Post Office Counters Limited. Yes, it changed its name several times during that period. So it started off as the Post Office, then it was Counter Services, then it was Post Office Counters Limited.

Mr Stevens: So back to Post Office Counters Limited in ‘94, was that?

Kathryn Parker: ‘95.

Mr Stevens: ‘95, my apologies. What was your role at that stage?

Kathryn Parker: So I was head of resourcing for Post Office Limited. So that was everything to do with recruitment of staff workforce.

Mr Stevens: Getting to 1998, were you in the same role then?

Kathryn Parker: I was in the same role in 1998, yes. In 1999, I became head of personnel policy development, which was leading on all of the HR policies that applied to workforce but also leading on the policies that related to training.

Mr Stevens: As we’ll come to and you’ve referred to in your – or you’ve been taken to in your witness statement, some documents from January and April 1999 –

Kathryn Parker: Yes.

Mr Stevens: – were you in that training role in early 1999?

Kathryn Parker: I believe so. What’s important to say, though, is I was in that training role so my day job was head of personnel policy. The work to do with Horizon was not part of the core job, it was something in addition to that. So I wasn’t part of the Horizon team per se, I was doing my business-as-usual day job which was as head of personnel policy development.

Mr Stevens: In respect of training, what were your day-to-day responsibilities?

Kathryn Parker: It was around the policy, the policy for training provision. So Post Office Counters Limited at the time had a network of its own trainers and then, as Horizon came along, there was a need to work with the Horizon programme in terms of what did that mean for the way in which we were training people and how did we encompass Horizon training into what had been the previous approach to training branch office and subpostmasters.

Mr Stevens: We’re referring there to Post Office Counters Limited and focused – when we talk about Horizon, focused on what work goes on in the branches. Are you aware what part of the group was responsible for the prosecutorial function of the Post Office?

Kathryn Parker: No.

Mr Stevens: Were you – as part of your remit, did you have any involvement in training either investigators or prosecutors?

Kathryn Parker: No.

Mr Stevens: I should add to that or auditors as well?

Kathryn Parker: I don’t recall any of those. I think somewhere in the pack that you sent me there was a reference to auditors receiving training in Horizon – live training, you know, during those training events. Other than that, I don’t recall, I’m afraid.

Mr Stevens: I’d just like to bring up a document on screen. The reference is NFSP00000550. This is a meeting of the NFSP National Executive Council held between 19 and 21 October 1998. You didn’t attend that but I’d like to turn to page 18 and focus on the bottom. It should come up on screen in front of you. It may be easier then referring to the bundle.

Kathryn Parker: Thank you.

Mr Stevens: Thank you very much. So this is a minute, 6(a), concerning human resources training for subpostmasters. It says:

“Under this heading there were 2 specific subjects related to subpostmasters’ training: the Transactional Knowledge Review trial which was currently underway in the Midland Region, and the trial in the South East of classroom style training.”

We can skip the remainder of the paragraph, had next paragraph says:

“Correspondence of the 3 September from Kathryn Cook …”

Now, I will pause there: that was your previous name?

Kathryn Parker: Yes.

Mr Stevens: “Correspondence of the 3 September from Kathryn Cook gave details of the current status of the trial within the South East Region. She had indicated that a full range of data on which the analysis of the trial would be made available to the Federation.”

Can you recall, this being October ‘98, what this trial is referring to?

Kathryn Parker: No. I can’t recall it. I can try and give you a sense of what I think it might have been referring to but I don’t know for sure.

Mr Stevens: What do you think it was?

Kathryn Parker: Well, there were a number of trials going on as the work to develop the Horizon System was underway to sort of, you know, try it out on live people, just so that you can judge whether or not some of the assumptions made by, you know, techy IT people actually were working in the real world.

So I would surmise from that that we were sharing with the NFSP some of the insights that we were getting from those trials.

Mr Stevens: If we could go to the next page please. Take down the highlighted text and, on the next page, if you can focus in on the first paragraph – thank you. It went on to say:

“Mr Burrows advised the Executive Council that a quite separate form training was being introduced in the North Thames & East Anglia Region which involved classroom-style training but for a 4-week period.”

Now, pausing there, the none of the – it was never – a four-week period of training for Horizon was never trialled; is that right?

Kathryn Parker: I don’t ever remember us trialling something for four weeks. That would have been an incredible provision even to consider, let alone to think about the logistics of deploying that.

Mr Stevens: So we – knowing this four-week period scheme was being trialled, does that assist you in remembering what this trial may have been?

Kathryn Parker: No, it doesn’t. I have no recollection of us trying a four-week trial. As I say, the logistical implications of having a four-week trial for delivery of Horizon training would seem quite a commitment.

Mr Stevens: It goes on to say:

“The NC was concerned that training seemed to be becoming fragmented and variations introduced on a Regional basis. It was the intention to seek to clarify the current situation and policy of Post Office Counters towards training of subpostmasters in order that the Federation could ensure that subpostmasters received the proper training they required to meet their responsibilities.”

How was training organised prior to Horizon? Was it on a national level or by regions?

Kathryn Parker: I believe it was by regions but my memory of that is not good. From recollection, I think there were training teams regionally dispersed who were local to the area, who would be providing training. Beyond that, I’m sorry, I can’t remember.

Mr Stevens: We’ll leave that there. If we can move to another document it’s POL00039737. I want to start talking about what’s been referred to as a Horizon training competency and conformance group. Just wait for the document to be loaded thank you.

This is a letter that appears to be in draft form. It’s addressed from you to Bruce McNiven dated 8 January 1999. There are changes in the – handwritten changes to the letter. Is that your writing?

Kathryn Parker: I assume it’s my writing, yes.

Mr Stevens: It says that you had spoken to Bruce McNiven about this competency.

Kathryn Parker: Yes.

Mr Stevens: How did Bruce McNiven sit in the sort of hierarchical structure in comparison to you at this time?

Kathryn Parker: Oh, very much senior to me.

Mr Stevens: Did you work – in what regard were you working with him on this?

Kathryn Parker: The way it worked in practice was that those who were working full time on the Horizon programme would sometimes come to people like me on specific items, specific issues. They would ask for some input, they would take it, and then do with what they felt they needed to do with it. So it was more like being commissioned, I suppose.

Mr Stevens: If we could go down on the document, please, to the bullet points – thank you. In the bullet points, you set out three things that you thought needed immediate work.

Kathryn Parker: Yes.

Mr Stevens: The first one was:

“is the gap between the current performance and the necessary levels of performance consistent (ie are gaps in knowledge/performance/understanding etc, common across the population – or at least capable of being clustered – if they are then we stand a chance of filling them, if not then without having individually designed training interventions it’s difficult to see how we can do some nationally) …”

So here are you looking at the gap between the competence of subpostmasters pre-Horizon and the competence required to operate Horizon?

Kathryn Parker: I assume that’s what I was talking about. It wasn’t just for subpostmasters, though, it was for anybody working in a post office.

Mr Stevens: Any end user?

Kathryn Parker: Yes, I assume that’s what I meant, yes.

Mr Stevens: The second bullet point says:

“are these gaps ‘trainable’ (in any sense of the word).”

Kathryn Parker: Yes.

Mr Stevens: What did you mean by that?

Kathryn Parker: In – how to put this. Some people who were required to use the new system weren’t happy about having to change their working arrangements, so there is a sort of a mindset, a sort of, you know, a personal reaction to “What am I being asked to do”. So what that was referring to was, if somebody’s reluctant to take on the new knowledge, accept the new system, for example, then you can’t just sort of train that in to them. That’s a much more focused piece of change management work rather than training.

So you know we can’t win over hearts and minds through training, although you know you can do a bit of it, but actually the change management piece more broadly is about doing that kind of thing.

Mr Stevens: Then the third point is:

“what would meet this training need.”

Kathryn Parker: Yes.

Mr Stevens: That’s what I want to turn to now. You go on to say basically that if the answer to the first two questions is no, then the third bullet point doesn’t apply.

You go on to say that:

“If the answer to the first two is ‘yes’ then we can go on to specify the business impacts of trying to fill these gaps (I suspect it won’t cheap!) and, of course of not filling them.”

Kathryn Parker: Yes.

Mr Stevens: So at this stage, could you foresee that there was a sort of training gap that the Post Office may not be able to bridge or may not try to bridge?

Kathryn Parker: I suppose my starting point with this particular one was that – and if I get the numbers wrong, forgive me, it’s a long time. I think there were over 200 transactions that were being done across the counter network at this point. If you were going for a training provision that covered every single one of those transactions in detail then, absolutely, you could come up with a gold-standard training solution that would take everyone through that for every single transaction.

The approach, though, was to say that, actually, some of those transactions are done really rarely. You know, people wouldn’t come across them and therefore the focus of the training was on the most frequently required things for people to do because once you get competent in doing the most frequent transactions and you get confidence in using a system, that then means that you have the confidence to move on to some of those rarer, less frequent transactions.

So that was point I was making there, that, you know, if the model had been “We are going to train everyone on every transaction prior to going live with Horizon”, then the training solution would have to look completely different.

Mr Stevens: Did you anticipate at that stage that there may be subpostmasters or end users who wouldn’t be capable of using Horizon, even after the training programme?

Kathryn Parker: That was a concern and one of the reasons why the training support was in different buckets, for want of a better term. You know, so a standard training provision for everyone that should get people to a level of competency, plus access to post training support where people were clearly struggling on particular aspects, and the helpline. So the intention was by mixing and matching the support for developing competency you could pick up the majority of people.

But, yes, I remember conversations where we were saying we are really concerned about particularly subpostmasters or part-time counter assistants who might only do limited shifts on counters picking up a very different way of transacting business.

Mr Stevens: When you say you had conversations around this, who were those conversations with?

Kathryn Parker: Oh, I would find it very difficult to list them but it was definitely a concern in Post Office Counters at the time. I would be very surprised if the people who were copied into these documents weren’t aware of that concern.

Mr Stevens: If that was a concern, what was the Post Office’s plan for those who weren’t able to meet the competence levels to operate Horizon?

Kathryn Parker: During the period when I was working on this, the issue – we couldn’t quantify that issue, so there was a concern that was there but we didn’t know and I think I put this in my witness statement somewhere. Some of the concerns that we identified we couldn’t quantify. They might not have been, in reality, things that we should have been concerned about.

The issue is, as the data started to come through, and much of that data came through after I’d moved on sadly, you know that’s where you start to see whether there’s evidence that people are struggling to use the system appropriately.

Mr Stevens: We’ll come to that later on. We’ll move on slightly in the timeline. Please can I bring up POL00039748. This is a memo that you wrote, January 1999, pulling people together to work on the task that Bruce McNiven – or you discussed Bruce McNiven in the last document?

Kathryn Parker: Mm-hm.

Mr Stevens: Looking at the list of people who you have invited, could you help with what areas of the business these people came from?

Kathryn Parker: As far as I can remember, absolutely. Sue Smith was one of the trainers. So she was the person who provided the expertise in terms of how do you do a transaction now. So she was the subject matter expert in terms of this is how Post Office Counters Limited does this transaction and she was there because the knowledge of how things were done previously obviously informs how you are going to train to do them later. So she was the subject matter expert.

I believe some of the other people in the list were working for the Horizon project on a dedicated basis. So I think Trevor and Clare possibly and maybe Douglas. The other names, regrettably, I don’t remember.

Mr Stevens: Thank you. That document can be taken down now and could we please go to POL00039781. This is a letter dated 19 February 1999 which you drafted following an initial meeting of the group and it lists various annexes, some of which we’ll turn to in a moment. Right at the bottom, the letter goes on to say:

“We agreed that we needed to get together again around the middle of March to do the following”, essentially setting out the work the group needed to do.

Do you know why this work was only being carried out at this stage and why it hadn’t been done earlier?

Kathryn Parker: No.

Mr Stevens: I want to turn to annex D, which is described as “a copy of our ‘gap’/’vent your frustration’ list”. That’s POL00039785, here referred to as “Brainstorm of Gaps”. The second and the third entry on this list states:

“Horizon isn’t delivering what they said we would.

“We don’t have a cash account that balances.”

Could you tell me what you are understanding of those two things were at the time?

Kathryn Parker: At the time this was a brainstorm of anything that could go wrong, not necessarily things that had gone wrong. So when I referred earlier to us not having the data to know whether or not some of the issues that we feared were going to happen had happened, this is why this was a brainstorm of gaps. So “The Horizon isn’t delivering what we said we would”, quite apart from being horribly, grammatically incorrect, my sense of that is, you know, at the time was it delivering all of the transactions we were looking at? Was it covering everything that was done?

I said in my witness statement, and I’ll repeat it again at this point, at no point in my involvement in this did we think that the system wouldn’t be working correctly. That was an assumption that we made, that it was going to be working perfectly. The issue for us is that, you know, some of the clients, some of the stakeholders might say, “We don’t want our transactions on there”, for example. I think that’s what that means.

Mr Stevens: The Inquiry’s heard evidence of various problems in the system in ‘98 and ‘99. Is your evidence – and just to confirm that this document here, the group you were in were not aware at this time of problems in balancing arising from the EPOSS application?

Kathryn Parker: Absolutely, we weren’t aware. We took it as a matter of faith that it was working because, otherwise, you can’t – you can’t support people with a training product if, actually, you know the system isn’t doing what it’s meant to be doing. So no.

Mr Stevens: At the bottom, it says “Issues not resolved”, and the first bullet point under that is:

“Final C/A NR21.”

Do you recall what that means?

Kathryn Parker: I have no idea at all what that means, sorry.

Mr Stevens: If I said could it mean “final cash account New Release 2”, would that ring a bell?

Kathryn Parker: No.

Mr Stevens: Please could we bring that down and turn to annex B of the same letter. It’s POL00039783. This lists information to be shared around the group. The second square bullet point says:

“Horizon database key information (from John Meagher).”

Do you recall who John Meagher was?

Kathryn Parker: I don’t recall what his job was. I know he was quite senior.

Mr Stevens: He gave evidence earlier, being he served as Horizon product assurance manager and then Post Office acceptance manager working on the Horizon project. Would you accept that?

Kathryn Parker: That’s right entirely possible, yes.

Mr Stevens: It goes on to say:

“Regular reports on the potential risks which a training solution could avert, from: Horizon service reports, BA/Pathway/POCL joint meetings, Before and After procedures group …”

Can you recall the type of information that the group was seeking from John Meagher?

Kathryn Parker: Beyond what’s listed there, no, I can’t. I’m sorry.

Mr Stevens: Would it be fair to say that the group was seeking information on the Horizon product itself or the system itself and how it was performing?

Kathryn Parker: Let me read it again. I’ll answer that. I don’t know, is the honest answer after this length of time. I’m not sure.

Mr Stevens: We’ll move on to another document now. POL00039724, please. It’s an email of 23 February 1999 from Clare Dryhurst to you. I think you said earlier you thought – did you say you recalled Clare – working with Clare Dryhurst?

Kathryn Parker: Yes, I do, yes.

Mr Stevens: What was your working relationship with her?

Kathryn Parker: I think she must have been working on the Horizon project full time but I could be wrong. I don’t remember well enough, I do remember her name, though.

Mr Stevens: This email states that she was sending some documents. The second paragraph refers to a report of:

“… I’m sending the report Glenys Davies of PA and I knocked together on costs, benefits and actions for non conformance.”

The third paragraph says:

“I’ll send you the HEB report in paper form…”

I want to turn to those documents now in reverse order. POL00039730, please. This is a memo from Andy Radka in business service management, 7 January 1999, to Clare Dryhurst. It says:

“Find attached a copy of the HEB Consultants Summary findings from the ‘Right First Time’ initiative.”

Do you recall receiving this report?

Kathryn Parker: No, I don’t. I’m sorry.

Mr Stevens: The report looked at two sub post offices and four Crown Office branches focusing on back office activity, such as the cash account. Could I ask that we turn to page 5, please, and down to “Recommendations”. It says:

“Over the course of the two studies it has become clear that although many of the risk factors leading to human error have been tackled successfully somewhere within the Post Office network, the organisation as a whole has not been benefited as fully as it might. The considerable effort expended on improving counter service needs to be matched in the ‘back office’ by standardisation of the process and minimisation of associated risk factors, all taking full account of ‘good practice’. Competence of those performing each aspect of ‘back office’ work must be assured.”

It then gives some specific recommendations.

The last paragraph says:

“Different versions of the ‘back office process’ will need to be developed to accommodate differing circumstances (ECCO/non-ECCO, large/small, together with various mixes of business) however, the core structure could be common.”

So is it fair to say this was not looking at back office processes from a Horizon perspective?

Kathryn Parker: No. My reading of this document, which I only saw an hour or so ago, was that this was talking more generally, about standardising ways of working which were not standard across the network previously.

Mr Stevens: Could we turn the page, please, to the implementation heading. It says:

“Although any of the ‘good practices’ could be implemented in isolation and locally with some benefit, that would not address cultural shift needed within POCL if significant impact is to be made on the major cost burden of processing errors from over 19,000 post offices at Chesterfield.”

Pausing there, at the time within Post Office, was there a perceived problem with the level of cost in processing errors generated from manual cash accounts?

Kathryn Parker: I can’t comment on that specifically because I don’t know how much error rectification cost at Chesterfield, but I do know that there were different ways of working which people had developed over time and the responsibility for subpostmasters to train their counter assistants meant, again, that custom and practice developed both amongst the branch offices but also primarily amongst sub offices, as people found ways that worked for them.

Mr Stevens: Please could we – let’s stay on that page for the moment:

“In the terms of reference described above, the challenge was characterised as ‘making the best like the rest’ and the study has made it clear that there are define differences between those who make errors and those who do not. More work needs to be done to define those differences comprehensively and precisely and then build them into a process but it plainly can be done.”

Turn the page then, please:

“In an increasingly volatile business environment POCL will need to disseminate many changes in working practices to its huge network in the years to come and now is as good a time as any to review the most cost-effective means by which this might be achieved. To ignore recent and rapid advances in information technology and distanced learning techniques would be to miss an opportunity.”

At this point, did senior management see Horizon as a tool to be able to standardise back office processes?

Kathryn Parker: I don’t know for sure but I would have thought so.

Mr Stevens: When you say you would have thought so, why would you think that?

Kathryn Parker: Well, if you’ve got a circumstance where you are spending a lot of money rectifying errors at Chesterfield, as the previous document was showing, the opportunity to have technology that eliminated some of those errors would, of course, deliver you a cost saving. So that would make you may think the whole operation more efficient. So I could see why.

The other benefit that I imagine was weighing heavily on people’s mind was the ability to extract data from the system, to be able to get reports and understand without manual processes how the organisation was doing. So I don’t know for sure. I’d never had a conversation with a senior manager about whether or not that was in their mind but those are the two obvious things I would think, had it been me, that they would be looking for are.

Mr Stevens: Both of those things depend on Horizon providing accurate data?

Kathryn Parker: Absolutely, yes.

Mr Stevens: Can we turn to the other attachment, which was POL00089738. This is the “Conformance Strand 3 Business Case”, dated 11 December 1998 by Clare Dryhurst and Glenys Davies, a document we referred to earlier in the email of 23 February, and it looks at the cost of conformance and non-conformance when Horizon was introduced.

Could we turn to page 17, please. Under the heading “Impact on Transaction Processing Business Unit”, it says:

“Once the cash account has become automated, the potential for problems will expand exponentially as 300 new offices are automated weekly. In brief, there is a possible of many mistakes in each cash account, which will result in …”

We don’t need to go through the whole list but it includes:

“error rates increasing significantly …

“difficulty/impossibility of reconciling accounts …

“unable to explain discrepancies …”

It goes on to say:

“If the approach for the Horizon National Rollout does not incorporate conformance, and we use the Lottery implementation as an example, we could expect a level of 60% of outlets’ automated cash account to be incorrect with the initial month after implementation. An assumption has been made that 40% of this number will become proficient the following month. However, there is a potential that the number of outlets becoming proficient will decline due to the speed of the rollout and strain on support resources.”

It then goes on to map out a trend in the chart below:

“Using the above trend for additional staff required to support the … National Rollout, the potential staff costs incurred”, and then that’s been left blank.

Was this common knowledge within the business at the time of the potential for discrepancies and potential errors in the cash account, if training wasn’t properly implemented?

Kathryn Parker: I don’t recall it but I find it inconceivable that people wouldn’t be concerned about it.

Mr Stevens: Can you recall what was done to address those concerns?

Kathryn Parker: I think if you – some of the design of the training did include – the face-to-face training did include some of those back office processes, some of those balancing processes and then the access to the helpline and the additional one-to-one support required, I think, can all be targeted at that.

Now, the timing of the introduction of those additional aspects of support, I’m afraid, is lost to me after this length of time but, taken together, I would have expected that would pick up quite a bit of the competency gap.

Mr Stevens: Thank you. That can be taken down. I want to now look at some of the collection of feedback on the training programme. Could we turn to POL00039648, please.

It’s a training evaluation paper dated 8 July 1999. You’re not in the distribution list. Had you seen this document or do you recall seeing it at the time?

Kathryn Parker: No, I don’t.

Mr Stevens: If we could go up slightly the abstract says:

“This document defines the processes applicable to the Peritas activities undertaken to discharge the contractual responsibilities for the measurement of the effectiveness of the user training programme in a manner consistent with the Kirkpatrick model.”

Do you know what the Kirkpatrick model is?

Kathryn Parker: I do.

Mr Stevens: What is it?

Kathryn Parker: It’s the original and still the core methodology for evaluating the effectiveness of learning interventions. There are many different versions out there but, if you are slightly cynical, they are all Kirkpatrick in a different form or another. It’s the gold-standard one.

Mr Stevens: Can we turn to page 10, please, of the document and under section 5.4. It says:

“On completion of each training event each delegate is required to provide an assessment of the event in a manner consistent with level 1 of the Kirkpatrick model. Such a process is consistent with which the traditional end of course appraisal process used in most commercial training events.”

If we can go over the page, please, we see there these five areas that are to be tested:

“Achievement of course objectives.

“Quality of course presentation”, et cetera.

Then below that, there are four attributes with four possible ratings: excellent, good, satisfactory unsatisfactory. Below that it says:

“The rationale which results in the additional positive rating in this case ‘Excellent’ arises from the findings of the majority research studies in that delegates have a basic aversion to marking the highest positive category and therefore the need for balance is achieved by inclusion of the extra category.”

In your experience, is that standard practice?

Kathryn Parker: It’s not unusual. I mean, can I just give you a personal view about level 1 Kirkpatrick? They are referred to in the learning industry as “happy sheets”, you know, was the delegate happy with what was provided to them? The reason – you know, it’s very easy to collect the data but reason why you should always treat happy sheets with caution is that, generally, at the end of a training event when delegates have had the opportunity to get to know the trainer and feel comfortable, you may think that they tend to mark relatively well.

The value of the Kirkpatrick model comes from looking at evaluation at all levels, not just the easy happy sheet piece, because that is data that you can – you can get a snapshot but it doesn’t tell you anything about the willingness, ability and capability of someone to do it when they return to their office, which is why there are up the levels of evaluation which are – shall we say, probably have equal, if not more, importance than the level 1 evaluation that we’re talking here.

Mr Stevens: So is level 2 competency test immediately after at the training site?

Kathryn Parker: Level 2 is the competency test immediately afterwards and the level 3 is the ability to do it once you are in the real world. Level 4 would then look at whether or not all of the aims and intentions of whatever change programme you’re talking have been delivered.

Level 4 is relatively rarely used but, actually, is really important because that gives you the feel over time whether or not actually whatever it is you’re training for has had the impact that you were looking for. So with a big programme like this, although I know this document does suggest that level 4 is very complex, it surprised me when I read it just now that there wasn’t a level 4 of any description involved with this piece of investment.

Mr Stevens: Let’s get a look at some of the feedback which we can do before the break? Can I bring up POL00039733. This is a fax from Alan Bourne to you dated 30 March 1999. On page 3 we can see that it is a report from Kevin Fletcher on New Release 2 training practice events. If you could turn to page 5, it says:

“ICL Training Services were requested by Pathway/POCL to provide trainers for a series of courses for Counter Assistants and Counter Managers on the Horizon System. The delegates on the courses were volunteers from POCL.”

Do you remember who commissioned this research?

Kathryn Parker: I’m sorry, I don’t.

Mr Stevens: Kevin Fletcher gave evidence to the Inquiry on Tuesday and he suggested that the volunteers would have been selected by the Post Office. Would you agree with that?

Kathryn Parker: I don’t know. I don’t know how they went about finding volunteers, so I can’t comment.

Mr Stevens: I’m not going to go through all of the form but if we could just turn to page 7, please, we see that this is for the Bristol counter managers, two unsatisfactory scores. In the comments below there’s:

“More time required (several comments) …

“Too much information compressed into course.”

I’m not going through all of them, just selecting some:

“Good trainer not enough time allowed.”

Over the page, with the Bristol counter manager’s course one unsatisfactory. Selecting some of the remarks:

“I will need extra training.

“More time on balancing – error notices …

“Second day should be expanded to full day – especially for delegates who have no experience of automated systems …

“More time needed, setting up users – allocating users.

“Course definitely requires two full days second day is six hours with no lunch break. I feel the course is unsatisfactory because it is very intensive and coverage of important tasks ie balancing is rushed as a result. Bearing in mind a subpostmaster could be asked to do their first balance unsupervised.”

If we could skip, please, to 17, at the bottom the Tunbridge Wells Counter Assistants, no unsatisfactory scores, and then over the page we have:

“Balancing (two [persons]) (like to add) …

“Could always have more time …

“Error adjustments …

“Only satisfactory – because for my role as an auditor I need to cover the balancing aspect of the system.

“Stock and office balancing (like to add) …”

It’s fair to say from those the theme that came across was that people wanted from this more time on balancing and more time generally; is that fair?

Kathryn Parker: Yes.

Mr Stevens: Also, you referred to these as “happy sheets”. There is a low number of unsatisfactory scores there. Do you think it’s fair to say that some of the comments made did make substantive criticism of the course?

Kathryn Parker: I don’t know if the word “criticism” is right. Improvement opportunities, certainly. Although, you know, yes, maybe “criticism” is the right word. Maybe “criticism” is the right word. But there’s a disconnect between the scores people give and the comments that they have made and I think that points danger of relying on happy sheets alone.

Mr Stevens: As in, as the course is progressing, one should look the comments?

Kathryn Parker: You should always look that comments, yes.

Mr Stevens: Sir, that might be a good time to take a short break if that is okay with you. I think you are on mute, sir.

Sir Wyn Williams: Sorry. Could you just give me some indication of how much longer the evidence is likely to take.

Mr Stevens: I anticipate another half-an-hour.

Sir Wyn Williams: All right, fine. So what’s the time now?

Mr Stevens: It’s just past 2.25.

Sir Wyn Williams: 2.35, yes?

Mr Stevens: That works, sir. Thank you.

Sir Wyn Williams: Fine.

(2.28 pm)

(A short break)

(2.35 pm)

Mr Stevens: Please we bring up POL00039735. This is from you to Bruce McNiven on 9 April 1999 and it’s titled “Horizon Training: Competency”, and it encloses your Horizon competency report which starts at page 3.

Actually, stay there. Thank you.

In your introduction, you say, five or six lines down:

“The recent review of TK and its reallocation of training time towards improving the performance of ‘poor’ offices has gone some way to enabling us positively to affect competence after recruitment but there is still some way to go (and this is something that the Network Team will be looking and in 1999/2000.”

The reference to poor offices, what did that mean?

Kathryn Parker: I don’t remember exactly. I can surmise that that was talking about offices that had more errors than other offices.

Mr Stevens: Was there ever a process of performance management for offices that generated high levels of errors prior to Horizon?

Kathryn Parker: Not that we looked at nationally but what were they called? There was a post in the regions, retail network manager, something like that, it was called and they were responsible for managing networks of post offices in particular geographical areas. I think they had the responsibility for, you know, working with post offices that were not achieving the kind of levels of competency that others were as a sort of, you know, business as usual kind of management piece.

Mr Stevens: Can we take it from this, and the other documents we’ve read, was the Post Office interested in this stage at, on a national level, looking at performance management of its various subpostmasters’ branches?

Kathryn Parker: I don’t recall that it was at this point in time. I think that was one of the benefits of – or the perceived benefits of moving to Horizon, which was that you would get the data out that would enable you to spot where performance was lower, without having to go through a lot of, you know, analysis of separate documents that were coming in to Chesterfield, probably.

Mr Stevens: So, at the time, Horizon, one of the – it was perceived –

Kathryn Parker: Yes, I believe so. I couldn’t point you at a document that said that.

Mr Stevens: But your understanding from working there is that Horizon was – one of the advantages of Horizon is it would give you the data –

Kathryn Parker: Yes.

Mr Stevens: – to pinpoint poor performing –

Kathryn Parker: Well, it would give you the data do pinpoint what was happening in the network, you know. So whilst you could look at poor performing, you could also look and high performing and say, you know, why is this office particularly high performing? It would let you look at individual transactions and see whether or not there are errors across the piece or whether there were errors related to specific products or specific things that anyone working in a post office needed to do.

So the data would allow you to cut and slice and dice all of that to work out how effective performance was.

Mr Stevens: That recollection is that just a general or do you have any specific recollection of discussing that with a member of more senior management?

Kathryn Parker: I have no recollection of discussing that but I do, even after this passage of time find it pretty inconceivable that that wouldn’t have been a benefit of the Horizon System.

Mr Stevens: You say you go on to say about a definition of competency and, if we could turn, please, to page 11, we have annex A which is a competency statement, so what group had set out as its definition of competency, and on the left there is competency now and on the right competency post Horizon.

Do you recall what was done with this competency statement in the group or within Post Office Counters?

Kathryn Parker: I’m sorry, I don’t, no.

Mr Stevens: If we can turn the page, please, at the top there is “Balance Stock Unit” and, in the left-hand column, “Now”, that’s now section, pre-Horizon, it says the various things to do include “identify discrepancies”. In the column on the right, it says yes to all of those points, so that will continue. But relation to “identify discrepancies”, it says:

“Yes, system does this, based on what user has entered.”

Then:

“Additional Horizon requirements:

“need to understand what a stock unit is and understand the whole process using Horizon eg including balancing periods.”

Now, at this point – so the point of the system does this based on what the user has entered – did the competency group or the group that drafted this consider what a postmaster may need to do or may need to know to identify the cause of a discrepancy?

Kathryn Parker: I don’t remember that. I would have thought so but I cannot say that I can remember that specific issue, no.

Mr Stevens: At this stage, would you – do you think the group would have considered whether a subpostmaster needed to be able to determine whether a discrepancy was caused by the Horizon IT System itself?

Kathryn Parker: If they were looking at it in the way that we were looking at it I think they would have assumed that the system would have worked so they wouldn’t need to consider it was the system that was wrong. I would imagine they were thinking what have I done, using the system for it to come out wrong, but I can’t speak for everybody who was using the system. All I know is we believed the system did what the system needed to do 100 per cent of the time. So therefore, if there was a discrepancy, you would expect the subpostmaster or the counter assistant, or whoever it was using the system, to try and track back and work out “Have I put the wrong figure in, have I done X, Y or Z”, to work out what was the cause.

Mr Stevens: If we go down just slightly to when it all goes wrong on the left, it’s:

“Manual procedures (if ECCO) if equipment fails.”

Then on the right:

“Yes, need to know what to do if equipment fails, how to recover transactions (fallback and recovery procedures); manually balance?; revert to manual transactions?”

I take it from your evidence just now that’s referring to when the computer simply wouldn’t work rather than discrepancy?

Kathryn Parker: Yes, that would be disaster recovery in the event that you lost your electricity or you had a fire or, you know, whatever it would be, yes.

Mr Stevens: Can we turn, please, to page 7 of this document, paragraph 8. This is where you made various suggestions to the group makes various suggestions about what to do with the findings, which we don’t need to go through in detail. The second sentence says – it talks the competency gap, and then it says:

“It could be thought that one of the things that the data collected is telling us that although there was a pre-course competency of only 79%, the fact that only 3 people would have failed the Horizon training (2.37%) could be taken as an encouraging sign that a lack of competency currently would not be an inhibitor to using the Horizon system. There may however be other explanations eg that the Horizon competency test is ‘too easy’ or that isn’t predictive of live operation (eg that it’s measuring the wrong things).”

Which of those three options did you think was the real cause at the time?

Kathryn Parker: I don’t know. My take on each of those three right now, if you look at the first one, the reference to a lack of competency currently not being an inhibitor to using the Horizon System, if technology is intuitive it can eliminate errors because, you know, it gives you the options and choices that sort of eliminate errors. So my assumption is that that first one is saying that, you know, the system itself could be helpful in the event that people were not as rock solid as they could have been in terms of the process or the detail.

The Horizon competency test being too easy, well, this is where we launch back into the Kirkpatrick data thing because this is where Kirkpatrick level 3 data would give you some of the information that you would need to know in order to say whether the competency test was too easy. So that’s where the level 3 data really does help you and the level 4 data if you’re doing that would help you to know whether that was the case.

The predictive of live operation, I think, is the least likely of the three to have been the key one.

Mr Stevens: Do you have any recollection of anything being done to test which of those three was correct?

Kathryn Parker: I can’t remember if there was, no, I’m sorry.

Mr Stevens: Thank you that document can come down now. The Inquiry’s heard evidence about the process by which Post Office and ICL Pathway settled disagreements over whether or not this system matched the contractual specification, and one of those disagreements was called Acceptance Incident 218, which we’ve heard evidence that it concerned the training course, in particular the balancing aspect of it.

Were you consulted or in any way involved in the acceptance process?

Kathryn Parker: No.

Mr Stevens: As a result of that, there was a second – I say as a result of the acceptance process, a second supplemental agreement to the overall contractual agreement was drawn up. Please could we bring that up at POL00090428, and turn to page 64, please.

Sorry, it’s 65. My apologies.

If we could highlight the “Post Installation Competency Strategy”, this states:

“The joint workshop on 13 August accepted that not all users within the large population will ‘absorb’ Horizon. This may eventually call for closure of the outlet, replacement of the subpostmaster or training of additional staff. It has been agreed between POCL and ICL Pathway that other steps taken within this resolution plan should minimise the risk of this and that any residual fallout will be handled by POCL. POCL have agreed to review and strengthen the relevant process. This is reflected in the timetable.”

This agreement, were you ever aware of it?

Kathryn Parker: I don’t remember seeing any or hardly any of the commercial, in-confidence documents that were in the second bundle that was sent to me, so I don’t recall ever having a discussion of having that shared with me at the time.

Mr Stevens: This concept, though, that there may be some subpostmasters or end users who wouldn’t absorb Horizon, were you aware that that had been accepted?

Kathryn Parker: I think there was – I think I was aware of that, yes, that there was a belief that there would be a very small number of subpostmasters for whom this simply wasn’t going to work. There was particular concern about very elderly subpostmasters who had very limited exposure to technology and that, for some of them, they would choose or they would not be in a position to use it effectively.

Mr Stevens: What extra steps did Post Office Counters take to try to avoid the options of closure of the outlet or replacement of the subpostmaster?

Kathryn Parker: I can’t answer you definitively because I can’t line up all the documents in the right timeline but my assumption would be that this was where the provision of additional support to subpostmasters, after the standard training and the use of the helpline, came in. Whether that is actually the case and whether there was something else, I’m sorry, I can’t recall, but that’s my assumption.

Mr Stevens: So there’s the Horizon training programme and then, once that’s complete, anything further is the helpline or the additional training. Is that through the Horizon Field Support Offices?

Kathryn Parker: Well, either the Horizon Field Support Officers or the POCL trainers because I’m pretty certain they got involved post implementation as well. With an office that’s struggling, you know, it’s inevitable that you would try and provide that support first before saying “This is grounds for terminating a contract”.

Mr Stevens: Please could we bring up the POL00089738. It’s the “Conformance Strand 3 Business Case” document again. So it’s POL00089738. Thank you.

We went to this document earlier. Can we turn to page 14, please, down to “Supporting non competent outlets”. It says:

“The current training programme focuses on the Horizon operational aspects, without ensuring that the POCL processes and best practices are included. Also, there is an assumption that all personnel have similar base skills of working with the technology. This approach to training will have a more dramatic effect with the new release of Horizon as this version of the software includes the reconciliation processes. These processes require the POCL perspective to ensure that the daily and weekly reconciliation are [complete] (sic).”

It refers to competency testing and says, at the bottom of that paragraph:

“Therefore there is a potential that additional resource will be required to give remedial support to these non competent outlets. This remedial support will include:

“performing supplementary training to outlets, part or all outlet personnel.

“assisting outlets/personnel meet the defined competency criteria.

“This activity does not currently have an obvious owner, ie implementation or operational.”

Can you recall if or when an owner of that additional remedial training was found?

Kathryn Parker: I don’t. I mean, this document pre-dates my involvement with the training provision for Horizon. So I’m not sure that I’d ever seen it before it was sent to me. Yes, I can’t shine any more light on that one, unfortunately.

Mr Stevens: It goes on to say at the bottom:

“By November 1999, the number of non-competent outlets will have exceeded 1,200 that require additional support above and beyond the operational support provided by the Business Support Centre. At this point in the rollout programme, the support services will be at breaking point due to the speed of the roll out, ie a further 1,200 outlets per month. At this point the number of outlets becoming competent will increase with the result that the need for additional support will spiral upwards.”

Can you recall any additional resources being brought in to provide this remedial training or further training that was required?

Kathryn Parker: I don’t recall any additional resources coming in. No, I –

Mr Stevens: In your –

Kathryn Parker: It’s not to say that they didn’t; I just don’t recall.

Mr Stevens: You said in your evidence, as you say, these two things: the one-on-one support, training support measures and helpline support. That document can come down, thank you. In Phase 1 of the Inquiry, many subpostmasters gave evidence saying that they’d made requests for a further training which weren’t fulfilled.

When you say that you understood that there were one-on-one measures in place, what’s the basis for that understanding? Was that checked by you, that the resource was actually available when required by subpostmasters?

Kathryn Parker: I don’t know is the honest answer. The organisation had trainers embedded in regions who were there to provide support to people. So I would have – you know, my rationale is that that resource, as well as the Horizon trainers, would be there and available to provide that support. But no, I don’t know.

Mr Stevens: I want to just cover a last topic. One thing we’ve spoken about is using Horizon to drive conformance and back-end conformance. When Horizon was initially rolled out, subpostmasters were able to post discrepancies to a local suspense account so that it could be held there and then, when they rolled over to continue trading, the cause of the discrepancy could be dealt with on another day. Do you recall that?

Kathryn Parker: No, I never had that level of knowledge about how the transactions worked. That’s why others on the team were there. You know, so I wasn’t counter trained, which was the phrased used for, you now, people becoming competent in terms of how transactions are done, how reconciliations was done and how balancing was done. So that wasn’t something that I was competent in, which is why there were others on the team who were able to do that.

The differences between how Horizon did it and how it was done before, that will be down to the Horizon team to actually define how the process had changed. So I can’t help you with that one.

Mr Stevens: We discussed how one of the hopes for Horizon, or you said one of the thoughts it may be able to do, is provide data to establish well performing offices and poorly performing offices. When you remained at Post Office following Horizon’s rollout, did that come to fruition? Did you see that data being used to target poor performing offices?

Kathryn Parker: Yes, I left Post Office Limited in 2001; so I had no involvement beyond 2001. I would have expected that data should be collected because, you know, if we boringly go back to Kirkpatrick, that’s your level 4 evaluation data that’s tells you whether or not it was working as had been intended. So that, for me, would have been the data that would have proved or otherwise how it was going.

Mr Stevens: As part of – because you were involved in the work on conformance –

Kathryn Parker: Mm-hm.

Mr Stevens: – a decision that was later made in respect of Horizon was to take away a subpostmaster’s ability to put discrepancies into this suspense account and effectively the subpostmaster would have to, to continue trading, accept the discrepancy that Horizon said was there. Were you aware of that decision?

Kathryn Parker: No.

Mr Stevens: That wasn’t linked – that wasn’t discussed as part of the conformance project?

Kathryn Parker: No, I don’t remember that coming up at all.

Mr Stevens: Could we please bring up your witness statement, which is WITN6050100, page 8, paragraph 10, please. You are reflecting on matters with hindsight and you say:

“Given the passage of time and the issue which the Inquiry is now looking at, I wonder, however, if there should have been a change to the pacing and phasing of rollout. Although the approach to training, design and competency felt proportionate at the time, it may be the case that training duration should have been looked at in the light of data coming back from the competency testing process and other measures of effectiveness.”

Can you just set out your recollection of what data was coming back from the competency testing processes.

Kathryn Parker: Other than the documents that you’ve been able to share in the bundles with me, I don’t recall the specifics in terms of the data that was coming back. Data must have been coming back. You know, I’m not saying it didn’t; I just don’t have access to what that was and after this length of time, I’m sorry, I really can’t recall which data it was.

Mr Stevens: During all this time, you’ve said it a couple of times in your evidence, that you were working on the basis that Horizon would work and it would produce reliable data. If you were told that that wasn’t the case and that there were significant concerns as to Horizon’s ability to balance or produce accurate data, would you have done anything different?

Kathryn Parker: I think we would have looked at the design of the training and the duration of the training and the support that was provided because, if you can’t rely on the system to do what – in ridiculously simple terms to do the adding up for you, then you’ve got to find a way of making that happen. So had it been known that the system – that there might have been issues with the system, then you would absolutely have gone back to first principles and said, “Well, what is the expectation of competency for anyone using the system? Do they need to be able to do this sort of reconciliation of errors? Do they need to be able to work out what’s gone wrong and where and put that right?”

But as I said, as I’ve said in the statement and I’ve said a couple of times today, you know, the belief was that the system was working as it was meant to work and that therefore the training was there to help people to use it, not to put right any errors that were not the cause – were not caused by the person using the system, if that makes sense.

Mr Stevens: Do you think you should have been told about the problems that were evident within the Horizon System at the time?

Kathryn Parker: Yes, yes.

Mr Stevens: Before I close, is there anything else you would like to say either to the Chair or generally on this matter?

Kathryn Parker: I’d like to apologise that my recollection isn’t as good as it could have been given the passage of time. I have tried to be straightforward and truthful all the way through. If I have forgotten something, my apologies, but I’ve done my best.

Mr Stevens: Thank you, sir. I have no further questions I’ll just see around the room if there’s … no, no questions from recognised legal representatives.

Sir Wyn Williams: Well, thank you very much, Ms Parker, for coming to give evidence. I don’t think I’m saying anything which is controversial by saying that people trying to recollect events 21 or 22 years previously are going to find it very difficult. So I completely understand what you have to say about that.

Kathryn Parker: Thank you.

Sir Wyn Williams: So is that it for today, Mr Stevens?

Mr Stevens: Yes, sir, we’re back on Tuesday at 10.00 for Sandra McBride. Sir, I didn’t know if you wanted to say something about next week’s timetable.

Sir Wyn Williams: Only in the sense that I think everyone should keep a keen eye on the Inquiry website because I think there is a degree of uncertainty as to who might be called next week, for reasons which I needn’t explain at the moment, but everybody who’s following should, as I say, look that website from time to time to see when the Inquiry will be sitting and who will be giving evidence before the Inquiry when it is sitting.

Mr Stevens: Thank you, sir.

Sir Wyn Williams: Thank you, Mr Stevens.

Mr Stevens: Thank you, sir.

(3.04 pm)

(Adjourned until Tuesday, 17 January at 10.00 am)