Official hearing page

17 January 2023 – Sandra McBride

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(10.00 am)

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

Sir Wyn Williams: Yes, I can thank you very much.

Mr Beer: May I call Sandra McBride, please.

Sir Wyn Williams: Yes.

Sandra McBride

SANDRA LOUISE McBRIDE(affirmed).

Questioned by Mr Beer

Mr Beer: Thank you very much. As you know, Mrs McBride, my name is Jason Beer and I ask questions on behalf of the Inquiry. Can you tell us your full name, please.

Sandra McBride: Sandra Louise McBride.

Mr Beer: Thank you very much. Thank you very much for coming to give evidence to the Inquiry today and for previously providing us with a witness statement. We’re very grateful to you for the assistance that you have provided to our investigation. Can we start with your witness statement, please.

Sandra McBride: Sure.

Mr Beer: If you can open up the folder in front of you, you should find a witness statement in your name dated 12 December 2022, 15 pages in length, and at the end of it should be a signature. Is that your signature?

Sandra McBride: Yes, it is.

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

Sandra McBride: Yes.

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

Sandra McBride: Okay, sure.

Mr Beer: Can we start, please, with your background and experience. I think you joined the Post Office in 1986; is that right?

Sandra McBride: Yes.

Mr Beer: And you left in 2016?

Sandra McBride: That’s right.

Mr Beer: So had a 30-year career in the Post Office; is that right?

Sandra McBride: Yes.

Mr Beer: I think you started as a counter clerk; is that right?

Sandra McBride: Yes.

Mr Beer: Then in 1993 you moved to the training team as a subpostmaster trainer; is that right?

Sandra McBride: That’s right, yes.

Mr Beer: And was that training provided in branch to subpostmasters rather than classroom training?

Sandra McBride: It was, yes.

Mr Beer: And that wasn’t about the Horizon System because at that time it didn’t exist and hadn’t been rolled out; is that right?

Sandra McBride: Yes.

Mr Beer: At that stage, were you trained to be a trainer before you became a trainer, or did you just get appointed as a trainer because of the experience you’d had as a counter clerk?

Sandra McBride: Yes, it was because of my experience really as a counter clerk, and I did do a small amount of training in the local area. I think, in the same year, ‘93, there was a change to Royal Mail services, and I trained some subpostmasters on the new services, the new system.

Mr Beer: In 1997 you moved to become what you describe in your statement as a CM2 manager. What’s a CM2 manager?

Sandra McBride: Counter Manager level 2, I think it stood for.

Mr Beer: And your statement also describes yourself as a Transactional Knowledge Manager. What was Transactional Knowledge Manager?

Sandra McBride: Right. So there was a few of us around the country and our role was to take – deliver sessions for subpostmasters, mostly in the evenings, and we had a load of laptop computers which we took with us, and the subpostmasters completed a transactional knowledge quiz on these computers. So that was – we did that also at Crown offices as well but mostly subpostmasters.

Mr Beer: And so the Crown offices, I think you say in your statement, were during the day?

Sandra McBride: That’s right, yes.

Mr Beer: The SPMs were in the evenings?

Sandra McBride: That’s right, yes.

Mr Beer: Although you were using computers in order to train and to, I think, administer the quiz – is that right?

Sandra McBride: Yes.

Mr Beer: – that wasn’t training on Horizon because, similarly, at that stage Horizon hadn’t been rolled out?

Sandra McBride: That’s right, yes.

Mr Beer: That role was, I think, eventually dissolved, and you went into the classroom to deliver new entrant training; is that right?

Sandra McBride: That’s right, yes.

Mr Beer: I think, when you delivered that classroom training – is that right – you did use Horizon?

Sandra McBride: I’m not 100 per cent sure, to be honest, whether – because I can’t remember exactly when it went into the classrooms, but initially in ‘97 it would have just been the manual classroom training.

Mr Beer: Yes. If you just look at your statement –

Sandra McBride: Yes.

Mr Beer: – please, and look at the second page and the paragraph number 2, you say:

“As far as I recall, I used a training Horizon System (not live) during occasionally classroom training I delivered prior to my maternity leave in May 2000.”

I think that’s the period we’re talking about. Is that right there?

Sandra McBride: Without knowing exactly the dates when the Horizon was put into the CTOs, I can’t recall whether that was with Horizon or without, to be honest.

Mr Beer: You are referring to CTOs there. Can you explain what a CTO is.

Sandra McBride: It stands for Counter Training Office. It’s where the classroom-based training took place.

Mr Beer: Where was that for you?

Sandra McBride: For me that could have been lots of different places.

Mr Beer: What was your geographical area?

Sandra McBride: So I was based in Colchester. We did have CTO at Colchester at one point but I think that was quite early days. But I would work in Bury St Edmonds, Ilford, wherever I was asked to go really.

Mr Beer: So in the East Anglia area moving into East London; is that right?

Sandra McBride: Yes, yes.

Mr Beer: So that’s right, is it, that first part of the sentence in paragraph 2: before you went on maternity leave, you did use a Horizon training system in the classroom, but you can’t remember how far back before May 2000 that was?

Sandra McBride: No.

Mr Beer: Before you delivered training on Horizon, using Horizon, were you yourself trained in Horizon?

Sandra McBride: I remember having the two days’ training that everybody got. You know, I think managers got two days and clerks got one day, if I remember rightly.

Mr Beer: You say that, I think, in paragraph 6 of your witness statement, if we go over the page. You say:

“I’ve been asked how much experience I had using the Horizon IT System prior to training others on how to use it. As far as I recall, I received the standard 2 days Horizon training which I believe was delivered by the external trainers.”

Is that right?

Sandra McBride: That’s right.

Mr Beer: So you got the same training as everyone else, no special training because you were going to be a trainer?

Sandra McBride: Not that I – not that I recall. I remember having the two days, but to deliver the classroom training I must have had some kind of training on the system that was in the classroom because that was slightly different.

Mr Beer: Slightly different to …?

Sandra McBride: To the live environment.

Mr Beer: Can you remember the differences between it and the live environment?

Sandra McBride: I remember initially – we weren’t – initially with Horizon we had stand-alone units in the classroom. So, for example, if there were six positions in the classroom, each counter as such get its own unit. So they weren’t linked like they would be in a branch.

Mr Beer: We’re going to come to some of the detail of this later.

Sandra McBride: Okay.

Mr Beer: That’s one difference. If there were multiple counters in a live environment, that wasn’t replicated in the classroom?

Sandra McBride: No, that’s right.

Mr Beer: Can you remember now any other differences between the classroom system, the stand-alone terminals and out in the field?

Sandra McBride: Some of the transactions, I think I mentioned in my statement as well, we couldn’t do on the training system. For example, at a later date we couldn’t do pensions, cash pensions, through the system. We had to go into training mode for it. That was a workaround. That information is from the documents. So I didn’t really remember that, but that triggered that memory from the documents you sent to me.

Mr Beer: Yes.

Sandra McBride: So where – and also, where there was a third party involved as in, if the system had to retrieve data from elsewhere, like DVLA, then we didn’t have that facility in the classroom. So we had to have what’s called an emulator to emulate responses if we did those transactions. I think that was with Horizon Online rather than with the original Horizon.

Mr Beer: Thank you. So far as you were aware, was the position that you found yourself in, i.e. giving training, on the basis of the standard two days’ training that everyone got, the same for other trainers too?

Sandra McBride: I can’t recall. I can’t recall what the other trainers received.

Mr Beer: Can you recall a training course for trainers that you didn’t go on but other people did?

Sandra McBride: There may well have been actually; there may well have been.

Mr Beer: Why wouldn’t you have gone on it?

Sandra McBride: I might have gone on it. I can’t remember, sorry. I don’t remember.

Mr Beer: Your recollection as you have written down in your statement there is that you received the standard two days’ training that everyone got?

Sandra McBride: Yes, I definitely did do that; I do remember that.

Mr Beer: Did you ever receive any refresher training on Horizon?

Sandra McBride: Not specifically, no.

Mr Beer: Was it ever discussed whether it might be an idea? I think you continued to work with Horizon for 16 years essentially from when you returned from maternity leave I think in November 2000 until you left the organisation in 2016, that refresher training might be a good idea?

Sandra McBride: Yes, yes, it would have – I think we were really, as trainers, required to keep themselves up-to-date with the system.

Mr Beer: How would you keep yourself up-to-date with the system?

Sandra McBride: The same as anybody in the live environment, really. You’d be notified of changes and any updates that were made through the normal communication channels of updating everybody. I can’t remember exactly what they were at the moment.

Mr Beer: But, so far as you remember, no dedicated refresher training?

Sandra McBride: Not that I can recall, no.

Mr Beer: As I think we’ll discover in a moment, and as you’ve already mentioned, at this time you were using a training version of Horizon and not the operating version that was used in the live estate; is that right?

Sandra McBride: That’s right, yes.

Mr Beer: I think you undertook that role until May 2000. As I said already, you returned from maternity leave in November 2000 and from that time onwards you had an administrative function; is that right?

Sandra McBride: Yes.

Mr Beer: Would a fair description of that be having responsibility for the maintenance of the new entrant counter training materials?

Sandra McBride: That’s right.

Mr Beer: Was that a regional role or a national role?

Sandra McBride: National.

Mr Beer: Was it – I was going to say just you. That sounds terrible. Was it you or was there anyone else doing it?

Sandra McBride: Well, I was the only person who did that role, but I had support from the team, the wider training team.

Mr Beer: What support did the wider training team give you?

Sandra McBride: They would be involved in changes. So I organised a group from the team, sort of like so there was some trainers, some training managers, and a trainer coach which was sort of a high level of manager, and we had regular meetings to discuss changes to the course materials. So their input helped identify changes that we needed to make, any amendments.

So that’s where the support was in that their knowledge and experience of using the training materials sometimes identified improvements, and obviously then, if there were any changes to products, then we would as a group make sure that the changes were made to all the materials in the course.

Mr Beer: Did you hold the pen, as it were, over the changes to the manual or the materials?

Sandra McBride: Yes, I sort of like – you know, I was the custodian of them all and – yes, so I just made sure that those changes were made. Some of the changes I made myself, once somebody had identified what needed to be done. So a lot of those changes I did do after agreeing with the team, the working group that I worked with, what changes were needed.

Mr Beer: Just to be clear as to the extent or limitations of your role, you weren’t involved in the initial rollout of the Horizon training programme, i.e. existing subpostmasters and counter staff, their training on the new Horizon System?

Sandra McBride: No.

Mr Beer: That was down to, I think, the company responsible for the design and build and rollout of the system?

Sandra McBride: Yes.

Mr Beer: Which became Fujitsu?

Sandra McBride: Yes.

Mr Beer: Your role was to have responsibility, secondly, for the entire suite of training materials – is that right – for trainees on the new entrant counter training programme?

Sandra McBride: Yes, just the new entrant training, yes.

Mr Beer: And that obviously included an element, a significant element, of training on the Horizon System?

Sandra McBride: Yes.

Mr Beer: Now, you say in paragraph 17 of your witness statement, if we just turn to that, please, which is on page 5, in the third sentence, the fourth line:

“The training course changed in length and content over the years. Initially the classroom course was only available to Branch Office staff but after making changes it was offered to subpostmasters.”

When did that change take place?

Sandra McBride: I don’t recall exactly when that was.

Mr Beer: Can you recall why the new entrant training as a classroom course was only available to branch office staff?

Sandra McBride: No, I don’t know why.

Mr Beer: And only rolled out to those becoming subpostmasters later?

Sandra McBride: Yes, I don’t know why that decision was made to change that.

Mr Beer: I’m looking at it the other way round: why the decision was made not to include subpostmasters from the outset.

Sandra McBride: I don’t know because –

Mr Beer: I know it wasn’t your decision presumably.

Sandra McBride: No. The classroom training initially was offered to – or it was mandatory for branch office staff. That was in place when I joined in ‘86 actually. So I don’t know why that was how it was, but that was how it was when I joined.

Mr Beer: You say, picking up on what you’ve just said, if we go over the page to paragraph 21:

“New entrant training was offered to all new subpostmasters although was mandatory for Branch Office staff.”

Are you drawing a distinction there between one being optional and one being mandatory?

Sandra McBride: At a later date, once the classroom training was offered to subpostmasters, it was offered to them rather than being mandatory like it was for branch office staff.

Mr Beer: Why was that?

Sandra McBride: I don’t know, to be honest.

Mr Beer: Can you think of a reason why a distinction was drawn?

Sandra McBride: Because I’m guessing that, when a subpostmaster takes over a post office, they’ve got a lot to deal with. They may not have been able to take the time out to go to the classroom training. The location of the classrooms might not have been suitable.

Mr Beer: Why didn’t those things apply to counter staff?

Sandra McBride: I think with counter staff, as far as I’m aware, they were able to book into accommodation, like hotels, if they were a long way from a CTO counter training office, which – that didn’t apply to subpostmasters.

Mr Beer: So it was about accommodation relating to attendance that –

Sandra McBride: Yes, so they could get to a counter training office. So, if it was a long way from – because we had several around the country, but obviously not everybody was able to travel perhaps on a daily basis to a counter training office. So they were put up in hotels to enable them to attend.

Mr Beer: That was the reason why it was only voluntary attendance for subpostmasters?

Sandra McBride: No, I don’t believe that is why it was only voluntary for subpostmasters. I don’t think they were – the business would pay for them to go to the hotel, but I don’t know.

Mr Beer: Other than that you don’t know the reason?

Sandra McBride: That’s my assumption really.

Mr Beer: Okay, thank you.

Now, I think there came a time when the audit team merged with the training team.

Sandra McBride: That’s right, yes.

Mr Beer: After that time, you had responsibility for maintaining the audit documents and tools as well as the training documents and tools.

Sandra McBride: That’s right, yes.

Mr Beer: Again, was that a national responsibility?

Sandra McBride: Yes.

Mr Beer: So, if from whenever this date was – we’ll establish the date in a moment if we can – somebody was to ask who’s responsible for the maintenance of policy documents or protocol documents relating to audit nationally, that would be you?

Sandra McBride: Yes.

Mr Beer: Can you remember when you assumed that position, when you took up that role?

Sandra McBride: Not exactly, no. I don’t know when that –

Mr Beer: So it’s after November 2000?

Sandra McBride: Yes, it would have been, yes.

Mr Beer: And before 2016 when you left?

Sandra McBride: Yes.

Mr Beer: Any recollection as to, in that 15 or 16 years, when that might be?

Sandra McBride: From seeing a document on here that you supplied, it states that it was around about 2008.

Mr Beer: Yes. We’re going to look at that document a little later in the morning. But you have read that now. Does that jog your memory at all, or doesn’t it assist –

Sandra McBride: Well, it says 2008, so I trust it was 2008.

Mr Beer: Okay. What were the reasons, as you understood them, for the merger of the two teams, audit and training?

Sandra McBride: I think – I don’t know for sure, but my guess is that it was to utilise the number of trainers that we had, you know, to make the trainers multi-skilled, because there was – the training team was quite a large team, and I think that was one of the reasons to multi-skill the field trainers.

Mr Beer: I was going to ask you that. Were the existing teams, the teams of trainers and the teams of auditors, asked to carry out their existing roles, i.e. the trainers stayed as trainers and the auditors trained as – stayed as auditors or, after the merger, did auditors carry out training and trainers carry out audits?

Sandra McBride: Yes, they did, yes. They wanted all the advisers, as they became known, to be multi-skilled to be able to do both.

Mr Beer: Would it be right that sometimes a failure in training might manifest itself in the course of an audit? If somebody hadn’t been properly training about something –

Sandra McBride: Possibly, yes.

Mr Beer: – they might make mistakes?

Sandra McBride: Yes.

Mr Beer: And those mistakes might show up in an audit?

Sandra McBride: If they weren’t perhaps following procedures, it might do. The audit was primarily to check the assets in the branch against what the Horizon System, when Horizon was in, said there was. So I suppose, if somebody hadn’t been trained properly in those procedures, they could make errors.

The audit also included other areas such as compliance. So the auditors would check compliance as well.

Mr Beer: Compliance with what?

Sandra McBride: Anti-money laundering and areas like that.

Mr Beer: So regulatory compliance?

Sandra McBride: That’s right, yes.

Mr Beer: Would it ever be the case that a person that had been trained by a training and audit adviser would then be audited by that same person?

Sandra McBride: Possibly, yes.

Mr Beer: Is that because the pool was relatively small and geographically based?

Sandra McBride: The pool of –

Mr Beer: Training an audit adviser.

Sandra McBride: That was quite a large number of people, but obviously I think, when they were scheduled to attend an audit, the advisers would be allocated a branch fairly local to them, which would apply with the training aspect as well.

Mr Beer: So it’s the geographical limitation that means you might get the same person that trained you as a year or two later auditing you?

Sandra McBride: Yes.

Mr Beer: You refer – we needn’t turn it up – in paragraph 46 of your witness statement to trainers being trained on audit tools and shadowing auditors and vice versa. Is that because they were required to multitask?

Sandra McBride: Yes.

Mr Beer: Was that from 2008 again?

Sandra McBride: Yes, it would have been, yes.

Mr Beer: Can we look, please, at a document POL00043806. This is going to come up on the screen for you. It’s going to be so complicated to find where you are on that. This document, take it from me, describes you as the audit and training adviser.

Sandra McBride: I haven’t seen anything yet.

Mr Beer: I think it’s coming up on the screen now. If we go over to the next page, please.

Sandra McBride: I can’t see anything on my screen at the moment.

Mr Beer: Just wait a moment. Somebody will come out and help.

Can you now see?

Sandra McBride: Yes, I can.

Mr Beer: In the time that that’s taken, I’ve now lost you. Take it from me this describes you as an audit and training adviser.

Sandra McBride: Yes.

Mr Beer: Is that right?

Sandra McBride: That was the role I was at the time, yes. That would have been my title, yes.

Mr Beer: So, if you had to fill out a passport application and they said, “What’s your job title”, you would have written in it “audit and training adviser”?

Sandra McBride: Yes.

Mr Beer: Who did you advise, or is that a misdescription?

Sandra McBride: Yes, I didn’t sort of advise as such.

Mr Beer: Sorry, the document can be taken down now particularly as it was of no use to me.

Sandra McBride: I think we were all called advisers in some format, like the field support advisers, they were the trainers/auditors. The role name changed – my role name changed over the course of the years I did it but, you know, I don’t really call myself – I don’t recall being an adviser as such.

Mr Beer: You wouldn’t have seen yourself as an adviser?

Sandra McBride: Not really, no.

Mr Beer: Just like the people that were doing the training, you wouldn’t have seen them as advisers?

Sandra McBride: No.

Mr Beer: You would have called them trainers?

Sandra McBride: Yes.

Mr Beer: And the people doing the auditing, you would have seen them as auditors, not advisers.

Sandra McBride: No, not really, no.

Mr Beer: Did you in fact give advice at all to anyone?

Sandra McBride: Not really, no. I don’t think so.

Mr Beer: Did you advise over the content of the changes to the training materials and audit materials, or did you just administrate the changes that were made by others?

Sandra McBride: I did have – I suppose I would have had input into that, into the changes.

Mr Beer: What do you mean by you would have had input? Can you give us a feel for the extent of your involvement?

Sandra McBride: For example – I’m trying to think of an example …

Mr Beer: So when Horizon Online came in, say in 2010, there would have needed to be a change to the training manuals/materials?

Sandra McBride: Yes.

Mr Beer: Would you have sent a memo out to trainers or manager trainers and said, “This thing is coming in, we need some content, please suggest the content”, they send it in, you collate it, or would you have said, “No, I don’t think that’s a very helpful suggestion to a change to the materials. I think it would be better worded like this”?

Sandra McBride: Yes, I suppose I did have that sort of input, like I would perhaps make sure that it was – any training material, as in trainer notes that they would have to refer to if they were running a course, for example, was legible and easy to understand for the person delivering it, and that it was grammatically correct and that sort of thing. So that sort of thing, really.

Mr Beer: So that makes it sound as if your role was still relatively administrative –

Sandra McBride: Yes.

Mr Beer: – making sure that things were grammatically correct and made sense, rather than making changes to or suggesting changes to issues of substance?

Sandra McBride: Yes, yes, and I was responsible for making sure version control was kept up to date, and make sure things were – and communicated to the team. So, when changes were made, I would, you know, make sure that one was aware of those changes.

Mr Beer: Can we look, please, at POL00085658. This is a set of slides that you, I think, refer to in your witness statement because the Inquiry had shown them to you – that is paragraph 53 of your witness statement – and we can see this is a set of slides headed 28 September 2011, Audit Review Cascade. On the first page there’s mention of Sue Richardson, the Projects & Standards Manager.

On the second page of the slides under heading “Background”, it says:

“Early 2008 the network support field team (NSFT) took over responsibility for financial and compliance auditing from the national audit team.”

Is that the document you were referring to earlier when you referred to the date being 2008?

Sandra McBride: Yes.

Mr Beer: It refers to that team taking over responsibility for financial and compliance auditing. Was there any other kind of auditing?

Sandra McBride: No, not that I recall.

Mr Beer: So they took over all auditing?

Sandra McBride: Financial audits and the –

Mr Beer: Yes.

Sandra McBride: Yes.

Mr Beer: If we just go forwards to page 10 of this document, please, chapter 2 of the slides appears to refer to you and Mr Paul Humber giving the presentation.

Sandra McBride: Yes.

Mr Beer: Who was Paul Humber?

Sandra McBride: Paul Humber was a field support adviser. He was originally in the audit team prior to joining with the training team, and he was a very knowledgeable and experienced auditor.

Mr Beer: You probably don’t remember delivering this session but, looking at the slide, it suggests you maybe delivered it together with him.

Sandra McBride: Yes, that –

Mr Beer: Is that a fair inference?

Sandra McBride: Yes, I think so, yes.

Mr Beer: If we look over the page, please, to page 11, can you help us as to what this is describing or doing, what’s being presented here.

Sandra McBride: So I think what this is displaying is that the person named on the left would be the person who has suggested an update. The request, as it is detailed, what they’re suggesting and what we’ve done about and what the benefit of that suggestion or change was.

Mr Beer: I see. So you were essentially running through suggestions to changes, the response to them, and the believed outcome of them?

Sandra McBride: Yes, yes. So the review I think was – I think what we did or what Sue asked for, we would get feedback from the team and, I think, perhaps stakeholders as well involved. I don’t know if it was this document or a different one and, because I looked after chapter 2 with Paul, that’s why me and Paul were delivering this section, and these are the changes that were suggested for this particular section.

Mr Beer: And this is all about audit rather than training?

Sandra McBride: This is audit, yes, and – yes, so these are the feedback that we would have received, and that’s what, you know, the details what we did.

Mr Beer: In the course of the suggestions and the responses, there’s reference to debts in branch accounts being shown up on audit. What experience at this time did you have of debts or discrepancies showing up in branch accounts?

Sandra McBride: Not much, to be honest.

Mr Beer: That was the purpose of an audit amongst other things?

Sandra McBride: Yes, yes, to identify.

Mr Beer: To identify a discrepancy?

Sandra McBride: Discrepancies, yes.

Mr Beer: By this time – so September 2011 – how frequently – do you remember I got the date September 2011 from the front slide?

Sandra McBride: Yes, yes.

Mr Beer: How frequently to your knowledge were debts or discrepancies shown up in audits?

Sandra McBride: I don’t know. I don’t know. I wouldn’t know the data. I don’t know how frequently that would happen.

Mr Beer: Were the causes of such debts or discrepancies ever fed back to you?

Sandra McBride: No, no –

Mr Beer: Did anyone mention that by this time, September 2011, that Horizon itself might be causing debts or discrepancies to be shown?

Sandra McBride: No, not at all.

Mr Beer: That the system itself was responsible for creating and creating falsely shortfalls?

Sandra McBride: No.

Mr Beer: In your career – we’ll look at this in more detail in a moment – right up until 2016, had you ever heard of such a suggestion?

Sandra McBride: No.

Mr Beer: Overall, how did you regard the robustness and reliability of the data produced by Horizon from, say, November 2000 until you left the organisation in 2016?

Sandra McBride: I trusted it, I suppose. We worked with the system, we expected it to be right, and we trusted the information that it produced.

Mr Beer: And why did you trust it?

Sandra McBride: I don’t know really. I suppose it’s because we – we – I was just going to say trust again. I don’t know why I trusted it, because we hadn’t any other reason not to I suppose.

Mr Beer: Did you assume that it had been through some process of procurement and testing and validation, for example?

Sandra McBride: Yes, yes.

Mr Beer: That you assumed that the Post Office wouldn’t roll out a system that was riddled with errors?

Sandra McBride: That’s right, yes.

Mr Beer: To your knowledge, was that trust in the system ever called into question?

Sandra McBride: No, not from what I recall.

Mr Beer: Did anyone mention that the system had bugs, errors and defects in it –

Sandra McBride: No.

Mr Beer: – that were liable to produce false data?

Sandra McBride: No.

Mr Beer: Now, you have already told us – that document can come down, thank you – that the training machines used for training on Horizon were not live, in inverted commas, so were therefore different to those used out in the field; that’s right?

Sandra McBride: Yes.

Mr Beer: Do you know why that was, that the machines used to train people were in that respect different from those that they would then use when they got out into the field?

Sandra McBride: I think it’s so that there could be no danger of any transactions that were conducted in the training going into the live estate, if you like. I don’t know for sure.

Mr Beer: Do you know whether any consideration was given to partitioning the training system so that that couldn’t happen?

Sandra McBride: No.

Mr Beer: Still having it live but partitioning it so that the data couldn’t affect the actual operations on the ground?

Sandra McBride: When we had Horizon Online, I believe that we did have certain things – like the screen, certain screens were as were seen in the live environment. So we received it to us, but the data couldn’t go the other way. So the transactions couldn’t be, you know, added to the live estate data, if you like.

Mr Beer: We’ll look at that in a little more detail when we look at some documents later –

Sandra McBride: Okay.

Mr Beer: – the process after 2010 with Horizon Online. But, before then, can you recall whether any measures were taken in the training that explained to trainees that their appreciation of problems on the system might be different when they are out in the field?

Sandra McBride: I think we would – I say we – the trainers would say it would be different in the field, because the amount of transactions and stock and cash that we held within the classroom environment was very small. So, when they got to their branch, they’re more likely to have had a lot more of everything. So there’s those differences.

As I said to you about the emulator, you know, we had an emulator to emulate responses for certain transactions, and then also I mentioned about the pensions. Obviously, we had to do a workaround in the classroom to enable the pensions to be trained. So that was obviously different to what it would have been in the live environment for the trainees.

Mr Beer: Let’s look at some materials. Can we look at FUJ00001703. Just to familiarise ourselves with the date and the nature of the document, this is described as a “Counter Training Offices Strategy”. You’ll see that it’s a Fujitsu Services document and you’ll see that it’s dated 27 November 2002.

You’ll see that the distribution of it includes the Post Office and, amongst others, Sandra Lewis. Was that you?

Sandra McBride: Yes.

Mr Beer: Your maiden name?

Sandra McBride: Yes.

Mr Beer: If we go to page 9, please, and look at the hardware section under 3.2.1, you’ll see that this records that:

“Each CTO is equipped with freestanding Horizon training systems. A summary of the hardware is listed below” and you’ll see what it is.

Then under the bullet points:

“Each training system is a standalone counter. Two of the counters will be connected to the Epson 200 inkjet printers. There is no connection to any other counter or server and all the counters are identical in every way.”

So this is a reflection of the point that I think you were making earlier or the evidence that you gave earlier –

Sandra McBride: Yes.

Mr Beer: – that this would differ from any branch in which multiple counters were used out in the field?

Sandra McBride: Yes, yes.

Mr Beer: Do you know why that was?

Sandra McBride: No.

Mr Beer: If there was a particular problem with multiple counter operation out in the field, if there was a bug or an error or a defect in the system that particularly arose when multiple counters were operated together, that wouldn’t be apparent in the training setup?

Sandra McBride: No.

Mr Beer: So that couldn’t be trained on and, more importantly perhaps, it wouldn’t manifest itself to the trainers?

Sandra McBride: No.

Mr Beer: Then if we look at 3.2.2, please:

“The systems are built as standard training counters of the type and software level used for delivering classroom training to outlet managers and their staff during the national rollout of Horizon. At the time of installation the systems mirrored the functionality of the systems being installed in live offices at the start of national rollout. This release was known as CSR. Since then, an upgrade has been performed at release CSR+, at a level known as CI4.

“The systems also reflect the functionality described in the training workbooks issued on training courses during the national rollout. The training counter also features facilities to run and reset POLO~…”

Can you remember what that was?

Sandra McBride: No.

Mr Beer: – “and to reset training data. Note that, unlike training mode, the training data is not reset automatically at power up, power down or a logout. The CTO counter build currently contains both the standard UK training build and the Northern Ireland variant. The trainer is able to select which variant to load up and run. This build will also support use of the OKI8P Plus printer as well as the Epson Stylus 200. The systems feature the same set of training data used by Pathway in training mode and the delivery of training for the rollout programme both at CSR and CSR+. When the CTO systems were refreshed to reflect the functionality being introduced at CSR+, additional data was included allowing trainers to set exercises which use some of Post Office Limited’s own training aides: i.e. barcoded bills and barcoded order books.”

This is all detailed in another document.

Then can you help us then, with that in mind, from your knowledge, to what extent did the software in use in the training setup differ from that in the live environment?

Sandra McBride: I don’t know the specifics, to be honest. I believe from reading another document that we had updates via disks. Therefore, the training offices weren’t updated as quickly, I think, as the live environment. I can’t remember how the live environment was updated, but I know from reading a document that you’ve shown me that we received disks in the CTOs to update them. So that –

Mr Beer: There was a timelag?

Sandra McBride: I think so, yes.

Mr Beer: But can you remember whether the aim was to replicate from a software perspective everything in the live estate in the training setup, or whether in fact there were differences?

Sandra McBride: I can’t remember whether there were – what the differences were, if there were differences.

Mr Beer: Can you remember a part of the system called Riposte?

Sandra McBride: Vaguely, yes.

Mr Beer: Can you help us: if there were, as we now know that there are, errors, bugs and defects in the Riposte message servers operating in the field in the live environment, would you expect that also to be apparent in the training units?

Sandra McBride: Yes, I would – yes, I would expect so.

Mr Beer: Can you ever recall that being mentioned as an issue, that the message servers used by Riposte had defects within them?

Sandra McBride: No.

Mr Beer: About what information they were communicating?

Sandra McBride: No, I don’t think so, no.

Mr Beer: Can we just fast forward a moment to 2016, please, and see by the time you left what the position was then. Can we go to POL00035737. Can you see that this is a document, a Post Office document, headed “Counter Training Office PoS Training System Requirements”? It’s dated 15 February 2016, and you can see that you’re listed as one of the reviewers. I think they must be pre your leaving.

Sandra McBride: Yes.

Mr Beer: Do you remember this document at all?

Sandra McBride: Not before seeing it –

Mr Beer: More recently?

Sandra McBride: No, that’s right.

Mr Beer: Now you’ve seen it more recently, can you tell us what the purpose of the document was?

Sandra McBride: I think – well, as it says, it’s stating our requirements – our, this is Post Office requirements – for the training system.

Mr Beer: And so who was it issued to?

Sandra McBride: Fujitsu, I’m guessing.

Mr Beer: If we look at page 4 of the document, please, just familiarising ourselves with the background:

“Post Office undertaking a major transformation of its IT systems, hardware and networks. This is known as the Branch Technology Transformation programme.”

Does that ring a bell now?

Sandra McBride: Yes, vaguely – not so well, to be honest.

Mr Beer: “The replacement of the existing point of service system Horizon Online used in all Post Office branches, British Forces branches, some admin locations and counter training offices is part of the branch technology transformation programme and is known as the front office application, (FOA) programme. The CTOs (Counter Training Offices) are used to train all new postmasters, WH Smith colleagues and Post Office branch colleagues. Each counter training office classroom is a live branch on Horizon Online using live reference data, but all transactions processed are clearly differentiated so that training transactions are stored separately from the live transactions.”

That’s what I referred to earlier as partitioning.

Sandra McBride: Right, okay.

Mr Beer: Can you remember that by this time, by 2016, the position was that in the classroom, in the CTOs, each classroom was a live branch using Horizon Online and used live reference data?

Sandra McBride: Yes, with Horizon Online, yes.

Mr Beer: Can you remember when that change took place, that in the classroom live reference data was used for training?

Sandra McBride: No, I don’t remember exactly when that was.

Mr Beer: Was it timed at the same time as the introduction of Horizon Online, or did it come in after the introduction of Horizon Online?

Sandra McBride: I don’t remember.

Mr Beer: Do you know why the change was made, that live data was used, live reference data was used?

Sandra McBride: No.

Mr Beer: Can you therefore not help us as to what prevented that from happening whilst you were responsible for the national training documents before then?

Sandra McBride: No, I don’t know.

Mr Beer: Did anyone ever explore this: why can’t we do in the classroom the things that we’re going to expect these thousands of subpostmasters to do out in the field?

Sandra McBride: Yes, exactly, yes, yes.

Mr Beer: Train them in the same, using the same data that they’re likely to encounter when they get out there?

Sandra McBride: I remember we would – I can’t remember exactly when it was though, that we would often have feedback, if you like, from – well, not just – you know, from myself as well, that we should be training the same as what the live environment were seeing.

Mr Beer: When you say – this document come down thank you. When you say we would often have feedback –

Sandra McBride: Yes. So trainers and – it was just something that, you know, we – it was a – we weren’t able to always show exactly what was in the live environment, and we would express that. But I don’t know why – I don’t know what the reasoning was as to why we couldn’t always have that.

Mr Beer: Was this a constant sort of niggle or concern?

Sandra McBride: I think in the early days of Horizon it was, because of – but, once we got Horizon Online, obviously the screens that we could see were the same, and the processes, you know, were the same as well. But we weren’t able to do all transactions, if I recall – it’s hard to remember – on the training system.

Mr Beer: Can you remember, when these concerns or issues were raised, what the answer was that came back as to why we can’t do it? We want to train all of these subpostmasters using a system that’s the same as the one out in the field, using data that’s likely to be the same as the data that they will be processing out in the field. You can’t do that because … and what was the because?

Sandra McBride: I don’t think there was a definitive answer that I can recall. I have a feeling it may well have been around budgets possibly because – I don’t know for sure but that might have been an obstacle that, if we had to, or the Post Office had to pay, or the training team, whoever, had to pay for an upgrade, I think in the earlier days that might have been an issue, and that might have been a barrier to getting, you know, a more up-to-date system for training.

Mr Beer: Was it ever reported back to you that the system as operated in the classroom manifested bugs, errors and defects?

Sandra McBride: No.

Mr Beer: Can we turn to updates to the training equipment and software and in paragraph 32 of your witness statement, if we just turn that up please, 32 which is on page 8, you say:

“I can recall that the training Horizon systems in the CTOs were not always up-to-date so trainers had to talk through some transactions that could not be completed on the training Horizon system. When we first received the training Horizon systems, I don’t recall us having input into what was on the systems.”

So dealing with the first part of that first, the systems in the classroom not always being up-to-date and so trainers had to talk through some transactions without being able to demonstrate them or tutees being able to conduct them?

Sandra McBride: On the Horizon System, yes. We could explain how to do a transaction physically but not necessarily on the screen.

Mr Beer: Was that because of the system not being live? Is this a function of or a consequence of the system not being live?

Sandra McBride: Possibly, or that it was when we had the disks to update. I can’t remember exactly. Also, as I mentioned previously with the emulator, that would emulate responses, but with the pensions instance, that’s the main one really that comes to mind from looking at the documents. So, you know – I can’t remember exactly which transactions that we couldn’t do, but I know there were some that they couldn’t physically do on the system. But I think the thought was that it wasn’t a major issue, because the trainer could talk through it, and the person would then receive on-site training in their branch, so therefore they would see the transaction live.

Mr Beer: The emulator, was that connected to anything outside of the room?

Sandra McBride: I don’t know.

Mr Beer: We know that the way that Horizon operated is that there were connections to servers held in other parts of the country, up in Bootle, for example, and one of the issues that we’ve been exploring is errors, bugs and defects in the local servers’ communication with sending messages to and from the servers up in Bootle.

Sandra McBride: Right.

Mr Beer: Can you recall whether the emulator was connected to anything in that way?

Sandra McBride: I don’t think so. I don’t think it was. I don’t know.

Mr Beer: So the system was sort of standalone in the classroom?

Sandra McBride: I can’t remember how worked, to be honest. I think it was just in the classroom, I think.

Mr Beer: What did it emulate?

Sandra McBride: Responses from DVLA. So, if you scan a barcode of 11, it would emulate a response that you would receive in the live environment from DVLA. The same for banking, chip and PIN transactions.

Mr Beer: Any other examples, please?

Sandra McBride: I can’t remember.

Mr Beer: Was it supposed to emulate third party, as you called them, transactions?

Sandra McBride: Yes, yes. I can’t remember any others.

Mr Beer: Was it part of the training to do balancing?

Sandra McBride: Yes.

Mr Beer: Did the emulator have any role in balancing?

Sandra McBride: No.

Mr Beer: Can we go, please, back to Fujitsu00001703. Remember we looked at this a moment ago? Can we go to page 12, please, and under the heading “Upgrading the Software Level”, at number 5, the first paragraph, the document – remember this is late 2012:

“The systems will receive software upgrades as planned and agree between Pathway and Post Office Limited.”

I think that’s meant to read “and agreed between Post Office and Pathway”:

“… because of the standalone nature of the systems, it is not possible to keep them up to date with the reference data changes which are regularly sent to the networked systems installed in the live post office outlets. Each counter is fitted with a removable hard disk. This enables replacement disks to be easily swapped in and out on site for the purpose of upgrading the systems to a newer release when required.”

Is that what you were referring to earlier about updates not being automatic but there being a lag?

Sandra McBride: Yes.

Mr Beer: And then, if we go over to page 13, please, and scroll down, please, three paragraphs from the bottom there, the document provides:

“For clarification, there is no support in the training counter for PIN pads, debit card method of payment (or NBS) [Network Banking Services] since these features are not supported in training mode. Support for these features would require additional development and testing effort and would need to be requested separately.”

That reflects the fact, doesn’t it, that there were differences, perhaps significant differences, between the training machines operated as compared to a live operating environment; is that right?

Sandra McBride: Yes.

Mr Beer: Would you agree that one benefit of having the live reference data and essentially a live system operating in the CTOs would have been that, if there were errors, bugs and defects in the operation of Horizon, they would have manifested themselves to the trainers?

Sandra McBride: Yes.

Mr Beer: The same trainers who were going to be the auditors?

Sandra McBride: Yes – before 2008.

Mr Beer: Yes.

Sandra McBride: Or after – after 2008 rather, yes.

Mr Beer: Well, both before and after 2008.

Sandra McBride: Yes, yes, that is right, yes.

Sir Wyn Williams: I’m sorry, Mrs McBride, you dropped your voice in that last exchange. Could you just say what you told Mr Beer, please.

Sandra McBride: I was just saying – initially I said before 2008 and then I said after.

Sir Wyn Williams: Yes.

Sandra McBride: And then Mr Beer did say before as well and I said yes, that is right.

Sir Wyn Williams: Fine. Thank you.

Mr Beer: Now, you were involved in training, as we’ve discussed, and had responsibility for the training materials from when you returned from maternity leave in November 2000 until you took redundancy some 16 years later.

Sandra McBride: Yes.

Mr Beer: One of the things that training, good training, is supposed to prepare trainees for is – would you agree – when things go wrong with the systems that they are using?

Sandra McBride: Yes.

Mr Beer: And one of the things that training, good training, is supposed to prepare for is that, where there are known problems or difficulties in the operation of a system or in the operation of the processes that the trainees are going to be able to, or going to be required to use, good training informs them of such problems in advance?

Sandra McBride: Yes, yes.

Mr Beer: It shouldn’t be facing the training just towards a rosy world where everything is perfect; it should be looking at a world where things perhaps go wrong?

Sandra McBride: Yes.

Mr Beer: In that 16-year period that we’re talking about, were you ever told directly of any problems that arose with the Riposte messaging system?

Sandra McBride: No.

Mr Beer: Did you ever hear any discussion, even overhear discussion amongst others, about problems with the Riposte messaging system?

Sandra McBride: No.

Mr Beer: Were you ever told directly of any problems with Horizon’s EPOSS system?

Sandra McBride: No.

Mr Beer: Did you hear about any problems concerning the Horizon EPOSS system?

Sandra McBride: No.

Mr Beer: Were you ever asked by anyone else within Post Office to address problems in the field in the training materials?

Sandra McBride: No.

Mr Beer: No?

Sandra McBride: No, not that I recall.

Mr Beer: We heard evidence last week from Chris Gilding. Did you know Mr Gilding?

Sandra McBride: Yes, I do.

Mr Beer: He said that he found that subpostmasters and counter clerks, other people using Horizon, could make mistakes when they were using Horizon, including mistakes that would affect accounting and balancing.

Sandra McBride: Yes.

Mr Beer: Were you aware that that could happen out in the field?

Sandra McBride: Yes, yes.

Mr Beer: I think that some of the training documents for which you were responsible similarly appear to acknowledge that mistakes may need to be corrected by subpostmasters; is that right?

Sandra McBride: Yes.

Mr Beer: If we can look at one of them, please, POL00035624. Thank you. Can you help us as to what this document is.

Sandra McBride: I believe this is like a training brief for the trainer; that’s their script, if you like.

Mr Beer: So notes addressed to a trainer to tell them how to train?

Sandra McBride: Yes – how to deliver the –

Mr Beer: How to deliver the training?

Sandra McBride: Yes.

Mr Beer: Or this element of the training?

Sandra McBride: Yes.

Mr Beer: If we could go forwards, please, to page 6 of the document and look act the foot of the page, remming in stock. Can you now remember what remming in and remming out were?

Sandra McBride: Yes.

Mr Beer: Just describe for us, please.

Sandra McBride: So it’s a way of – I say remming in – adding stock and cash into the branch and, if you have excess stock or cash, then you – it’s a way of getting it out of the branch.

Mr Beer: And here we’re dealing with remming in stock, and the instructions to trainer are:

“To accept stock to a branch the individual pieces of stock will be entered manually once they have been checked. In the classroom setting, this is identical to the branch other than the scanning of the pouch barcode during the delivery stage. Talk the learners …”

The learners, that means the people being trained, yes?

Sandra McBride: Yes.

Mr Beer: “… through the path to the stock rem screen.”

Then some instructions are given. Are they keystrokes, F14 and F2?

Sandra McBride: Yes.

Mr Beer: “At this point, remind the learners that the quantity button needs to be used to stop errors in volume. If you rem in one book of 12 first class stamps instead of 50, you will have a gain that will result in a future transaction correction, and this mistake could mask losses that would have to be made good when the transaction correction was received.”

Can you explain what these instructions are telling the trainer about.

Sandra McBride: No, basically I think this area is around the example of the first class book of stamps. They came in packs of 50. So, if the learner had put in one book of stamps instead of 50, that would create a gain in their balance. But that wouldn’t necessarily show up as just that amount at the end of the balancing period, because there may have been other errors made during that period.

Mr Beer: And this was masking them?

Sandra McBride: Yes. So you may well have created an error which would cause a loss, in which case that gain would not show fully necessarily.

Mr Beer: And presumably this is an example, and there were many others like this?

Sandra McBride: Yes. Oh, absolutely, yes.

Mr Beer: To what extent was there knowledge within the training community that unintentional errors by users out in the field could lead to accounting discrepancies, including imbalances?

Sandra McBride: Yes, I think that was –

Mr Beer: Widespread?

Sandra McBride: Widespread absolutely, yes.

Mr Beer: To what extent was that known by the auditors, that a simple error of the type described here in the operation of Horizon – this isn’t about a bug, error or defect –

Sandra McBride: No.

Mr Beer: – this is in the simple operation of Horizon – could create imbalances like this unintentionally?

Sandra McBride: I would expect that to be the same as well.

Mr Beer: So equally known amongst trainers and auditors?

Sandra McBride: Yes.

Mr Beer: And that just because a loss is shown doesn’t necessarily mean a dishonest appropriation by a subpostmaster?

Sandra McBride: No, absolutely.

Mr Beer: Would that be your first thought, if there was an imbalance, it must be the subpostmaster that’s taken the money?

Sandra McBride: No.

Mr Beer: Why not?

Sandra McBride: Because they might have just entered a figure in incorrectly into the system. They might have miscounted their cash and then put the incorrect figure or stock in the same way.

Mr Beer: And how many of these – I mean, this is quite a neat example here that we’re looking at on the screen. How many of these types of issue were there?

Sandra McBride: With the example?

Mr Beer: Yes.

Sandra McBride: I don’t know for sure, but I would imagine it’s human error to perhaps – you know, to especially in that instance where something comes in as a block and you count it as one and actually it’s 50. So that – you know that would possibly happen initially until maybe you make a mistake once and then you learn, obviously from it, don’t you? But I would imagine that happened quite frequently.

Mr Beer: Were there any prompts in the system, for example, on this, where you could see that it’s an error easily made that came up on Horizon which said, “Check that you in fact mean one book of first class stamps rather than 50”?

Sandra McBride: I can’t remember. I don’t think so but I can’t remember for sure.

Mr Beer: I.e. the system recognising the likelihood or possibility of unintentional error, and prompting the user to say: “Stop, think, do you really mean that?”

Sandra McBride: I don’t recall.

Mr Beer: You don’t recall any?

Sandra McBride: No, I don’t – I’m not – no, I can’t remember what the system showed.

Mr Beer: Did the system communicate back to the user in that way, so user messages?

Sandra McBride: I can’t recall.

Mr Beer: In any event, this kind of error you would expect knowledge of it to be the same in the auditing community as in the training community?

Sandra McBride: I think so, yes, yes.

Mr Beer: Certainly after merger, because they are the same people?

Sandra McBride: Yes, yes.

Mr Beer: Sir, it’s just coming up to 11.20. I wonder whether we might take the morning break. Thank you very much, sir. Can we say 35 past?

Sir Wyn Williams: Yes, certainly.

Mr Beer: Thank you very much, sir.

(11.19 am)

(A short break)

(11.35 am)

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

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

Mr Beer: Thank you very much.

Mrs McBride, can we turn to the issue of on-site training and balancing in particular. The Inquiry has heard some evidence, and we’ll in the coming months hear some more evidence, about training on balancing being supplemented by on-site training in the field.

Did you have any involvement in the provision of that training or assistance?

Sandra McBride: No.

Mr Beer: It was carried out by people described, at one stage certainly, as field support advisers?

Sandra McBride: Yes.

Mr Beer: Were they within your area of responsibility?

Sandra McBride: On a couple of occasions I did manage some field advisers or trainers during that time.

Mr Beer: Can we look at a document that might assist us here, POL00034108.

Can you see the title of the document, “Information for Field Support Advisers on Post Office Local Branches”, and then that foot of the page you can barely see it’s dated December 2012?

Sandra McBride: Yes.

Mr Beer: Is this a document within the suite of documents for which you were responsible?

Sandra McBride: Yes.

Mr Beer: It is, okay. Then, if we look at the second page, “Introduction to Post Office Local”:

“This document will evolve as the project progresses …”

Can you help us with what the project Post Office Local was.

Sandra McBride: That’s when branches were open for longer hours. So they would be in a shop, for example, that opened at 7.00 in the morning until possibly 10.00 at night, and Post Office services would be available during that time, not just the core hours from 9.00 to 5.30. They would be able to provide certain Post Office services after that time or before.

Mr Beer: Can we go forwards, please, to page 7 and look in the middle of the page, please. Under the three bullet points:

“The FSA [the field support adviser] will be on site for normal core hours (approximately 8.30 until 6.00 pm Monday to Friday and Saturday morning until 12.30). A follow-up balance will be added at the end of the on-site support and, although Post Office Local branches can do their BTS…”

Can you remember what BTS was?

Sandra McBride: No, I don’t remember what that is. I should know but I can’t remember. Sorry.

Mr Beer: No, no, you’re six years out of the job and this is a decade ago.

“… at any time of the appropriate day under BAU” –

Sandra McBride: Business as usual.

Mr Beer: – “for the follow-up balance one FSA [field service adviser] will attend to support from 1600.”

Sandra McBride: I’ve remembered what BTS is now – Branch Trading Statement.

Mr Beer: Thank you. Can you tell us what this is referring to this follow-up balance?

Sandra McBride: That’s assistance at the next balance that the branch would be doing once the trainer had left. So a follow-up is like, once the trainer’s left on a certain date, and then the next balance that the branch would be required to do, then the trainer would be there to support them on that.

Mr Beer: What was the need or purpose of this?

Sandra McBride: It’s just to support the branch further with their balancing.

Mr Beer: Can you remember any reports coming back as a result of this that there were problems with balancing?

Sandra McBride: Not that I recall.

Mr Beer: Then, if we go forwards, please, to page 12 under the heading “Balancing and Trading Periods”, the document says:

“It’s at the operator’s discretion whether they complete an office balance on a Wednesday for a balance period between trading periods. The branch has to complete a trading statement on the Wednesday that their trading group is scheduled to end their trading period. This should be done at a quiet time …” et cetera.

Can you help us what led to this additional support or training out in the field being thought to be necessary?

Sandra McBride: No, I think, prior to this training, we would always give support after the branch has been on – you know, the subpostmaster has been on their own for a few days. So previously we would do on-site support training, and then leave them on their own and then support them at the balance. Because the balance was – I say a complicated thing but it could be, you know, complicated, I suppose, so the support was needed. It was thought that the support was needed in the balancing area.

Mr Beer: Putting it bluntly, was this introduced because there had been problems with balancing?

Sandra McBride: Yes, possibly. But I think the idea was that it wouldn’t really be right to let someone just – once a trainer had gone, just be out on their own without any support, you know. So the balance was the area that it was felt that they needed the support in.

Mr Beer: You’ve referred to it as being, or it could be complicated, the balancing exercise –

Sandra McBride: It could be. Some people found it a bit confusing, I think.

Mr Beer: And it was crunch time in the sense that it’s when all of the work of the previous trading period came together?

Sandra McBride: Yes.

Mr Beer: To your knowledge, were any additional staff recruited for this purpose, or was this a function carried out by the existing training and auditors?

Sandra McBride: It was carried out by the existing pool of trainers and, yes, FSAs, as they were known.

Mr Beer: Can we turn back then, please, to POL00032429 to an earlier upgrade to Horizon before it became Horizon Online.

You’ll see this is a note about the upgrade of Horizon in December 2002 and, if we go over the page, please, and look at the foot of the page, we can see that it’s authored by you. At this stage you’re described as a training or the training manager.

Sandra McBride: Yes.

Mr Beer: Did that accurately describe your job as at December 2002?

Sandra McBride: Yes. That was my role name at the time. I wasn’t a – I didn’t deliver training in that respect.

Mr Beer: Did you manage those that delivered training?

Sandra McBride: I possibly did at that point.

Mr Beer: What did you do to manage them?

Sandra McBride: That required having one-to-ones with the team, cascading any changes to them in team meetings, and seeing them on site periodically while they’re training in, or a classroom if they were doing classroom training.

Mr Beer: Did you have responsibility for documents that regulated when and in what circumstances a reference would be made to an investigation team?

Sandra McBride: No.

Mr Beer: Can you recall if there was a tipping point for reference of a subpostmaster off to an investigation?

Sandra McBride: No.

Mr Beer: Did you ever have cause to refer a subpostmaster for investigation yourself?

Sandra McBride: No, no.

Mr Beer: Can you recall whether any of the trainers for which you were responsible had cause to refer people for investigation?

Sandra McBride: No.

Mr Beer: You can’t recall or that didn’t happen?

Sandra McBride: As far as I’m aware, that didn’t happen.

Mr Beer: What about when they were auditing at branches?

Sandra McBride: I didn’t manage a team when they were auditors as well as trainers. They were just trainers when I was managing.

Mr Beer: So by that time, if it was 2008, by that time your responsibility had turned more to the administrative side of the maintenance of the suite of documents?

Sandra McBride: Yes.

Mr Beer: Were you aware of people being sent for investigation at that time?

Sandra McBride: No. Investigation in – can you explain a bit more.

Mr Beer: Yes. An audit had shown a discrepancy, and it was believed that the subpostmaster/member of counter staff were responsible for the discrepancy and it therefore required to be investigated.

Sandra McBride: Right.

Mr Beer: That they might be suspended or their branch closed or there might be civil proceedings against them or they might be prosecuted for a crime.

Sandra McBride: Okay. I was aware that there were discrepancies found at audits. I don’t know the details but I was aware that, you know, that was something that happened.

Mr Beer: Were you aware of the follow-on from that, when a discrepancy was found, what happened?

Sandra McBride: Not the full process but, yes, I was aware that there could be – they would be suspended, you know, if there was a certain amount, I think, that was found to be short, for example.

Mr Beer: Were the documents that regulated when somebody was suspended, when their branch was closed, when they might be investigated by Investigations Division or prosecuted, were those documents within the suite of documents that you were responsible for?

Sandra McBride: The tool that the auditors used to identify a discrepancy was, yes.

Mr Beer: What do you mean by the tool that was used?

Sandra McBride: The tool was known as a P32 which was its previous paper number and it was like – pretty much like a big calculator really that auditors used to enter all the details in from Horizon to get a figure, if you like, an outstanding figure, a balance or not.

Mr Beer: What involvement to your knowledge was there of any branch managers or area managers in decision-making over investigation or prosecution of subpostmasters?

Sandra McBride: I think the contracts advisers were involved in making a decision. That’s based really on when I was looking at the hearing from Friday that Chris was explaining, and I thought: oh, yes that is – that did remind me that that is, yes, that was the process I think that, if a certain discrepancy was found, then the contracts adviser would be contacted.

Mr Beer: From your memory rather than watching Mr Gilding, can you recall whether that was a consistent feature in the process?

Sandra McBride: I don’t know the results of all the audits, so I don’t know for sure.

Mr Beer: No, I meant the involvement of a contracts adviser in the decision-making process.

Sandra McBride: Yes, that would –

Mr Beer: That was a regular feature so far as you’re aware?

Sandra McBride: Yes, yes.

Mr Beer: Go back to this document, please, back to page 1. Thank you.

The first line says:

“The new training system is the same the live system on the counter, up until the middle of October 2002.”

Can you recall whether this upgrade that you’re speaking to in this document meant that from that date, the middle of October 2002, one which meant that the training system could operate as part of the live estate?

Sandra McBride: Sorry, can you say that again.

Mr Beer: Yes. You remember we discussed earlier whether the standalone unit in the classroom operated as part of the – in the same way and as part of the live estate, and you said not?

Sandra McBride: Mmm.

Mr Beer: I took you to a document that suggested that by 2016 they certainly did, and you said at some point there was that change. You couldn’t remember when.

Sandra McBride: No.

Mr Beer: I was asking you now, looking at this document, is that first sentence a reflection of the fact that the upgrade allowed the training system to operate as a live part of the system?

Sandra McBride: Yes, that’s what it says, that it’s the same as the live system. So I would assume then that the system would have been – as it says there, you know, would have been the same then up until October of that year.

Mr Beer: Well, it doesn’t say that the training system was operating as a live part of the system. It says in the first sentence that it is same as the live system; do you see?

Sandra McBride: Yes.

Mr Beer: I’m just trying to work out with your assistance exactly what it does mean. Can you help us?

Sandra McBride: I can’t really remember, to be honest.

Mr Beer: Put shortly, after this time, did the training units continue to be disconnected from the network, continuing to use an emulator?

Sandra McBride: Yes.

Mr Beer: So we are in the same position that any bugs, errors or defects that were manifesting themselves in the system, in the live estate, wouldn’t be replicated in the offline, standalone systems in the classroom?

Sandra McBride: No, no.

Mr Beer: If we scroll down, please, and under Barcoded Bills you refer to item 28/22H:

“Barcoded bill in the name of Ms I Lonely shows on the screen at £22.50 instead of £82 which is on the bill. This can be changed manually on the screen.”

That appears to be a reference to a discrepancy in a barcoded bill, yes?

Sandra McBride: Yes, although it does also highlight the fact that, if somebody was only part paying a bill, the amount could be amended on the screen manually.

Mr Beer: What does item 28/22H refer to?

Sandra McBride: It’s a barcoded bill. I don’t recall what type of bill it was.

Mr Beer: What is a barcoded bill?

Sandra McBride: So it could be a utility bill which has a barcode which could be scanned.

Mr Beer: So somebody comes in with a bill saying, “I want to pay this bill”?

Sandra McBride: Yes.

Mr Beer: They present the bill to the SPM or counter clerk?

Sandra McBride: Yes.

Mr Beer: Rather than looking at the bill and saying, “Right, the bill to be paid is £82” and typing in £82, they used the scanning gun; is that right?

Sandra McBride: That’s right, yes.

Mr Beer: And they scan a barcode like one does at the shops?

Sandra McBride: Yes.

Mr Beer: And that comes up on the screen and it show £22.50 whereas it should show £82, because the bill is for £82?

Sandra McBride: That’s right, yes.

Mr Beer: But it’s showing £22.50.

Sandra McBride: Yes.

Mr Beer: Why would it show £22.50 rather than £82?

Sandra McBride: I see what you’re saying. We’ve either communicated incorrectly and got the barcodes printed wrongly, the bills, because we used to get those printed ourselves, or we were told it was for that amount and it wasn’t. I don’t recall why that was different in that respect.

Mr Beer: Is this training materials you are talking about here?

Sandra McBride: Yes, 28/22H would have been something that we printed ourselves, but we would have had to obtain it from – now, would we have got that?

Some items we got from Fujitsu with certain barcodes on, and other things we could produce ourselves from our own – if you like, our own, bit like a – I used to joke and say we’re doing a Blue Peter job because we would be able to scan – like, I could have my own barcoded bill from – you know, from home, and we would change all the details, use the barcode, but change everything else, and we could use that in the classroom if we wanted extra examples.

But this one, I can’t remember whether that was one that was provided to us, or whether that was one – I’m not sure where that came from originally.

Mr Beer: Can I ask –

Sandra McBride: I don’t know why it was different. I don’t know why it was different.

Mr Beer: Can I ask: was the intention here to train people that sometimes there can be a mismatch between what the computer shows as the sum due as a result of scanning a barcode and the actual sum due as printed on the bill and, therefore, this was a training device intended to identify a mismatch between a barcoded sum and the actual sum?

Sandra McBride: I think from –

Mr Beer: Or was this a genuine mistake in your training materials?

Sandra McBride: I think it might have been a mistake although, as it says there, it’s the way it’s said, “This can be changed manually on the screen.” It’s not saying this has been done on purpose so that you can explain this. So I think that would be a mistake.

Mr Beer: In your training materials, made genuinely rather than a deliberate error in order to show trainees that there can be a discrepancy between the sum produced by the machine for barcodes and the sum on a bill?

Sandra McBride: Yes, yes, I think it is an error.

Mr Beer: Were you aware of problems in the live estate of barcoding producing a discrepancy between the sum generated by Horizon and the amount on the face of a bill?

Sandra McBride: No, I don’t think – I wouldn’t have enough experience on the live system to know that. But I wasn’t aware of that.

Mr Beer: This barcoded bill in the name of Ms I Lonely, it sounds like from the wording here that this is a piece of training material that’s rolled out widely; is that right?

Sandra McBride: Yes.

Mr Beer: Across the country essentially?

Sandra McBride: Yes.

Mr Beer: Why not change the barcode rather than – if the intention is to get the correct amount, why not alter the training materials to get the right barcode and therefore the right amount, rather than leave the wrong barcode in and require a manual change on the screen –

Sandra McBride: I think –

Mr Beer: – if this wasn’t a training aid?

Sandra McBride: I think this was one that we had previously that we had previously used, and whether the – and I think the upgrade made it so that the amount was different when it was scanned perhaps to what it was before. I don’t know – I can’t really remember.

Mr Beer: If you go back to the first page of the document –

Sandra McBride: Yes.

Mr Beer: – it sounds like that barcoding is a new thing.

Sandra McBride: Yes.

Mr Beer: If you look at the first paragraph:

“The main differences for us are” –

And then if you look at the fourth bullet point:

“Barcoded bills can now be scanned.”

Sandra McBride: Yes.

Mr Beer: Sounds like this is a new –

Sandra McBride: Yes, that is right. So we used it previously probably without having to scan the barcode, so we could do it without scanning perhaps. Now that the bills could be scanned, this one came back – why we didn’t take it out or – we couldn’t get the barcode changed, I don’t think. We perhaps could have done. I don’t know how we would have done that, but –

Mr Beer: Go forward a page, please, and scroll down.

Sandra McBride: Again I think the fact that it could be changed manually, it wasn’t perhaps a big risk as such to leave it in there, because it did show – as I said, it did show that you could change an amount if somebody didn’t want to pay a full amount of their bill, which they could do on some utility bills. It showed that we could change it manually on the screen.

Mr Beer: These are the final questions I ask on this issue. Just go back to the page, please, and scroll down and just read the whole of that barcoded bills point again.

Taking a step back, is this intended to tell trainers that there’s a problem with our system of training, and there’s a manual workaround to correct it, or is this saying there’s a deliberate error and we’re using this as a training tool to show people how manually to change an amount because of a problem with barcoding in the live estate?

Sandra McBride: No, I think it was your first point.

Mr Beer: Thank you.

Can we move forward, please – that can come down from the screen – to a review of the audit process in October 2011 and look at POL00085682.

You will see this document is headed “Review of Post Office Limited Audit Processes and Tools” of October 2011, authored again by Mrs Richardson. You are part of the project team listed there.

Sandra McBride: Yes.

Mr Beer: Your job title is given as Network Change Adviser, as we saw.

Sandra McBride: Yes.

Mr Beer: Of the people listed there, are you the most senior in the project team?

Sandra McBride: No.

Mr Beer: Who’s the most senior there?

Sandra McBride: That would be Sue.

Mr Beer: Under project team?

Sandra McBride: Under – oh, sorry. I think we’re all the same.

Mr Beer: So you were all the same grade?

Sandra McBride: Yes. I don’t know what Shirley’s grade was. So all the team leaders and the network services admin and scheduling team leader and myself are all the same grade.

Mr Beer: Can you remember this audit revision or review process?

Sandra McBride: Vaguely.

Mr Beer: What can you vaguely recall? How was it conducted?

Sandra McBride: I think, from looking at the other documents that have been presented, that we obtained feedback from the team. I’m trying to think. So each team leader was responsible for a chapter of the audit process manual, and they all reviewed their own chapters, and the review – that was what the review was. They had to review their own chapters, and I think this is what that review is. The team that taken over the audit processes were reviewing their own chapters.

Mr Beer: Which were you responsible for; can you remember?

Sandra McBride: Chapter 2.

Mr Beer: So that was the slide that we saw earlier?

Sandra McBride: Yes.

Mr Beer: Can you recall what the need was or the requirement for review of the audit process and tools was in October 2011, what prompted it?

Sandra McBride: No, I don’t know what prompted it.

Mr Beer: Can you recall whether there was an event, or was this just a cyclical thing that happened every so often?

Sandra McBride: I think maybe because it hadn’t been done since we had taken over the audit side of things in the team. So it was deemed it was in need of happening.

Mr Beer: I think we get a hint of that, if we go over a couple of pages to page 3 of the document under “Introduction”, where Mrs Richardson says:

“The network support field team took over responsibility for all POL financial and compliance auditing in June 2008. In Jan 2009 a revision was undertaken of all the audit process chapters, as a basic starting point for the new ways of working using a multi-skilled team of FSAs. However, the audit processes and tools remained largely unchanged until April 2010. Currently all of the audit process chapters are reviewed against an annual rolling timetable and are the responsibility of the network services team leaders.”

Does that explain why this audit was being conducted in October 2011 or not?

Sandra McBride: Yes, I think so, yes.

Mr Beer: What is this essentially saying is: we took over the function in June 2008 and there hasn’t been this fundamental review until now?

Sandra McBride: Yes.

Mr Beer: Is that what it’s saying?

Sandra McBride: Yes, I think so.

Mr Beer: Then the next sub-heading the need for a review:

“Since the initial revision of all audit chapters in January 2009, business as usual operational changes have been made. However, a complete review has not been undertaken and there has been no proactive identification or engagement with stakeholders to ascertain that the processes and outputs are fit for purpose and will deliver the business requirements.”

You remember the answers you gave a moment ago as to how the review of the audit was undertaken, and you said that there was feedback from individuals. Who were they?

Sandra McBride: Well, they would have been the stakeholders of the chapters, so weren’t necessarily the same stakeholders for each chapter because each chapter obviously was a different area. So I think the team leaders were asked to contact the stakeholders and to get their feedback on the process that we were currently using for whatever chapter it was and if it was meeting their requirements.

Mr Beer: When you refer to stakeholders, who are you referring to?

Sandra McBride: The people who were responsible for the area of that particular chapter. For example, somebody in compliance, for the compliance chapter there would be – you know, they would be a stakeholder.

Mr Beer: So, if we go forwards to page 7 of the document under “Stakeholders’ Approach for Feedback”, under the heading “Directorates”, do you mean the person listed against each of the names there?

Sandra McBride: Yes, yes.

Mr Beer: For each of the directorates listed there?

Sandra McBride: Yes, yes.

Mr Beer: And which of those was yours?

Sandra McBride: I don’t think we – I can’t remember actually, because chapter 2 was a tool rather than a process. So I think that if – so it was – because it was a tool, it was – I suppose the team were the stakeholders, the people who used the tool.

Mr Beer: So under “Other Stakeholders”, network services, field support team, regional managers, team leaders, field support advisers, scheduling and admin team, and field change adviser, that’s in fact you, isn’t it?

Sandra McBride: Yes.

Mr Beer: They would be the people that would give you feedback to allow you to make any necessary changes to your chapter; is that right?

Sandra McBride: Yes, yes.

Mr Beer: You see the list of the people on the right there, approached for feedback: Julia Marwood, Paul Meadows, Tracy Marshall, Susan Crichton, Paul Martin, and Dawn Brookes.

Can you recall whether any feedback was given by them about problems in the now 11-year operation of Horizon in the field, by way of errors, bugs and defects?

Sandra McBride: No.

Mr Beer: That’s something that never occurred to you in this 16-year period at all? When I say occurred to you, was said to you in this 16-year period at all?

Sandra McBride: No.

Mr Beer: Can we go back to the issue of balancing, please – that can come down from the screen, that document – and look at POL00034184. If we can just familiarise ourselves with the document, do you recognise this?

Sandra McBride: Yes.

Mr Beer: Can you tell us what it is, please.

Sandra McBride: It’s what we used to call the balancing handout.

Mr Beer: We can see at the foot of the page that it’s dated April 2013, so after the audit that was just conducted. Who was it handed out by, and who was it handed out to?

Sandra McBride: It was handed out by trainers. I think we handed it out as part of the training course, as in the classroom training, and that the on-site trainers would have access to copies, if a new entrant once finished in their classroom didn’t have it on site.

Mr Beer: And were you responsible for some of the content of this document?

Sandra McBride: Yes.

Mr Beer: Did you write it?

Sandra McBride: No.

Mr Beer: In what way were you responsible for the content of the document?

Sandra McBride: Just making sure that, if any changes were made to the procedure, they were then updated onto the handout and the person responsible for the handout updated it –

Mr Beer: I see.

Sandra McBride: – accordingly.

Mr Beer: So the level of responsibility you described to us right at the beginning of the session today, ensuring consistency, readability and no grammatical error, that kind of responsibility?

Sandra McBride: Yes.

Mr Beer: If we look at page 2 of the document, please, there is some guidance on dealing with discrepancies. We can see that at the foot of the page, that last point under “Rollover”. Just before we get there, can you tell us how the document works by reference to those grey scaled boxes with words and numbers in them?

Sandra McBride: So they represented the buttons they pressed on Horizon.

Mr Beer: On the screen?

Sandra McBride: Yes, on the screen, yes.

Mr Beer: So they are essentially a printed depiction of a tile –

Sandra McBride: Yes.

Mr Beer: – on the Horizon screen?

Sandra McBride: Yes.

Mr Beer: The pad?

Sandra McBride: Yes.

Mr Beer: And in relation to roll stock units, it reads:

“At the end of trading period the discrepancy settlement screen appears on the last stock to roll over into next trading period. Horizon will ask how you are going to settle the discrepancy, i.e. cash, cheque or provide you with an option to settle the discrepancy centrally if over £150. If this option is selected then you will receive a statement from our accounting team in Chesterfield which provides you with the option of paying by credit or debit card. If the discrepancy is due to a known specific error made at the branch, then contact MBSC with the details to enable further accounting investigations to be made and appropriate accounting corrections to be issued.”

Are you familiar with that part of the process, or were you familiar with that part of the process?

Sandra McBride: Not particularly.

Mr Beer: What do you recall about it?

Sandra McBride: I know that what is detailed on here would have been – as far as I’m aware, was taken from the operations manuals, so the manuals that the counter – that the branches were able to access to get the full procedures. I’m not really familiar with the process.

Mr Beer: Here provision is made, we can see, for where there is a known error in the branch, i.e. where the subpostmaster knows they have made a mistake.

Sandra McBride: Mmm.

Mr Beer: There’s no provision for where Horizon makes a mistake?

Sandra McBride: No.

Mr Beer: Is that reflective of the fact that it wasn’t believed that Horizon made mistakes?

Sandra McBride: I think so, yes.

Mr Beer: Were you aware of any process that enabled a subpostmaster to challenge a balance as a result of an error that he or she believed Horizon had made?

Sandra McBride: No.

Mr Beer: There was simply no provision for it?

Sandra McBride: Not as far as I’m aware, no.

Mr Beer: Can you remember any discussion of whether there should be such provision?

Sandra McBride: No.

Mr Beer: Can we move forward a little still further into May 2013 – that document can come down – and look at POL00034208. If you forgive me, I just need to catch up in the paper.

If we go to the penultimate page, page 3, can you see at the foot of the page an email exchange to which you’re not copied. It’s between Mr Parsons, Andrew Parsons, to Gareth Jenkins copied to Simon Baker on 27 April 2013.

“Gareth, Attached is the Horizon Online help for giro transactions. You’ll see at the top of page called [and then a character string is given] that the subpostmaster is required to ‘select to print the office copy’ of the giro daily report. This suggests that the printing of the branch copy of the daily report is not automatic as previously thought but requires manual input from the subpostmaster. Would you mind looking into this and confirming the position (for both giro deposits and giro withdrawals).”

Then go up the page, please. In fact, go up to the previous page to the foot so we can see who the email was from. It’s a reply from Mr Jenkins back to Mr Parsons copied to Mr Baker. Then forward a page:

“Andy, I’ve just had a play on our test system … It looks like the documentation is wrong. What surprised me particularly was the fact that the Post Office copy is actually printed out before the giro slips. Simon, is it worth getting James to put together a story board for this as he did for recovery? Also who in POL should be updating the user guide? In particular, there is no button to just print the Giro deposits report. It is included in the counter daily report … is this old Horizon documentation? Though it clearly say Horizon Online, I did think that the slip was printed before the office report, but that could be Horizon rather than Horizon Online.”

Then go to the previous page, Simon Baker to Lin Norbury:

“Who do I talk to to update Horizon documentation?”

Then up, Simon Baker again:

“Lin, are you able to get back to me? [so a chaser] I would like to make sure your documentation reflects reality.”

Then from Simon Baker to Lin Norbury, now copying in Craig Tuthill and Angela van den Bogerd:

“Craig, Angela, I think Lin might be out. Who owns the Help content for the Horizon system? Investigations found some errors that I would like to get fixed.”

Then over to the previous page, Lin, at the foot of the page, thank you:

“Hi Simon. Further to our earlier conversation I have struggled to identify an overall owner for Horizon Online Help. I’ve spoken to Sandra McBride, network change support adviser and she advises that, when training identifies the need to change any documentation, she approaches the specific product manager.”

Just stopping there, I don’t suspect for a moment that you remember this call.

Sandra McBride: No.

Mr Beer: Can you explain what you are recorded as advising there: when training identifies the need to change any documentation, you approached the specific product manager?

Sandra McBride: I think what I’m – I would approach the product manager if change – mainly it was when changes were coming in rather than retrospectively. But they owned the product, so they would be the experts, if you like, on their products. So, if we had any clarification needed, then we would contact the product manager, and they would also – we also worked with them, as I said, when changes were coming in, so that we could make the changes in time for those changes, when they went live, if you like, with our materials and things like that.

Mr Beer: We saw from the email exchange, summarising it I hope fairly, that there was Horizon legacy material still in the user guide for Horizon Online. I think that was the nature of the email exchange.

Did you do anything as a result of that issue being raised with you beyond explaining who had ownership of Horizon Help?

Sandra McBride: No, not as far as I recall, no.

Mr Beer: Whose responsibility was it to correct that kind of thing?

Sandra McBride: I suppose once – whoever was responsible for Horizon help. So I’ve identified it as being the product manager – well, that’s who we would contact regarding products. So whoever was responsible for the maintenance of Horizon Help, who I don’t know who that was – I can’t remember who that was.

Mr Beer: So your answer is –

Sandra McBride: Although Julia says it is the product manager.

Mr Beer: Yes. I mean –

Sandra McBride: Yes.

Mr Beer: Lin Norbury continues:

“I’ve also spoken to Julia Marwood.”

Who was she?

Sandra McBride: She might have been the head of the training team at that point. She was at one point.

Mr Beer: “… and she has confirmed that each product manager is responsible for the content of their respective pages within the Help menu, but that it is less black and white when it involves issues around general accounting. Within her network team she has managers that face up the different product areas, and Stephanie Rush is responsible for engagement with the banking team which is where this particular query lies. As to an overall owner I will keep making enquiries.”

Can you add anything else to this exchange beyond what you’ve said already?

Sandra McBride: No.

Mr Beer: Okay, I’ll move on.

That document can come down, thank you.

In your statement you give some evidence that you have limited recall of feedback that was provided by stakeholders. Can we look at a document, please, that does record some POL00033423. Are you familiar with this document?

Sandra McBride: Yes, it was part of the documents that you sent to me to review.

Mr Beer: We can see a date of it at the foot of the page as April 2011 and we can see, I think, your name, your maiden name, as you were the author of it?

Sandra McBride: Yes.

Mr Beer: And do you recall now writing it?

Sandra McBride: Yes, vaguely.

Mr Beer: What was the purpose of it?

Sandra McBride: Well, it’s reviewing the post transfer visit, PTV, to get feedback from subpostmasters.

Mr Beer: So three months into the job; is that right?

Sandra McBride: I think it was three months, yes.

Mr Beer: Why is it called a post transfer visit?

Sandra McBride: I don’t know. It was a visit that was arranged after the subpostmaster had been in post for X amount, about three months. I don’t know exactly why it was called that, to be honest.

Mr Beer: What were they transferring from and to?

Sandra McBride: It was from when they transferred – so a transfer is when a postmaster takes over a branch.

Mr Beer: So this whole exercise is about people who have moved branches?

Sandra McBride: So, it’s a new – it would be a new postmaster.

Mr Beer: As well. So they haven’t moved branches, they are new into a branch?

Sandra McBride: No. So they are transferring from the old postmaster to a new postmaster.

Mr Beer: I see.

Sandra McBride: So that’s what the transfer – it was called a transfer.

Mr Beer: So this would incorporate old and experienced subpostmasters who happened to have moved branches, no?

Sandra McBride: No.

Mr Beer: Only new entrants?

Sandra McBride: New subpostmasters.

Mr Beer: Okay.

Sandra McBride: So when a new subpostmaster went into a branch, bought a branch, a shop with a post office in, they would transfer. It was just called a transfer from the old to the new. So it was from the day they took over the branch, that was a transfer.

Mr Beer: You say in this document following the training review feedback was sought from new agents that three-month post transfer visit. What does “agents” refer to there?

Sandra McBride: Postmasters.

Mr Beer: Does it refer to any counter staff as well or not, or is it only subpostmasters?

Sandra McBride: No, it would be just subpostmasters.

Mr Beer: And why are they called agents? What’s the –

Sandra McBride: Again, the terminology changed over the years of what subpostmasters were referred to as. So the common one was subpostmasters, but they were also referred to as agents.

Mr Beer: Looking at the questions asked and answered, question 1:

“Do you feel you have had sufficient training to enable you to process all Post Office transactions?”

Only 76 per cent said yes. Was that regarded as a low figure?

Sandra McBride: No.

Mr Beer: Why? What was taken from that then? Was that regarded as evidence of sufficiency or success of training?

Sandra McBride: Well, there was only 88 responses, I think it says at the top there.

Mr Beer: Yes.

Sandra McBride: So I think that was felt that that was a positive figure. I don’t think we had a target. You know, we weren’t expecting 100 per cent yeses or noes.

Mr Beer: I can understand that that you wouldn’t expect 100 per cent – was there not a target, a metric by which successful training could be measured by reference to feedback?

Sandra McBride: Not that I recall.

Mr Beer: Question 2:

“Which transactions do you feel most confident in dealing with?”

34 per cent of answers included AP and banking transactions; 33 per cent included mail transactions; 24 per cent included all transactions; 14 per cent included daily or regular transactions; 5 per cent included the basic transactions.

Then, by contrast:

“Which do you feel least confident in dealing with and why?”

You’ll see the answers there: 4.5 per cent answered:

“Balancing.”

Then over the page, please, sorry to the next page:

“Do you feel you’ve had sufficient training to enable you to prepare the office balance?”

72 per cent answered yes. Again can you remember what was taken from that, that 72 per cent – admittedly a relatively small sample of 88 – felt confident in preparing the office balance?

Sandra McBride: I would think – I can’t remember exactly, but I think that we thought we were probably on the right track, you know, what we were providing was sufficient for – you know, it was a good response, I think, really.

Mr Beer: Again, why would that be taken as a good measure of success?

Sandra McBride: I suppose because it wasn’t the other way round, that it wasn’t 22 per cent said they were – you know, they had sufficient training.

Mr Beer: And then question 6, please:

“In which area of the Post Office operation do you feel least confident and why?”

It seems that people didn’t include a why answer. 17 per cent felt least confident in balancing.

Then question 8, at the foot of the page:

“Are there any areas where you feel you need more training or support?”

18 per cent felt they needed more training in balancing and the trading period.

Can you help us as to whether anything was taken from this customer feedback, that there was a significant minority of individuals who felt that the training they had received on balancing was inadequate and they wished for more of it?

Sandra McBride: No. I think the – further down the page –

Mr Beer: Is set out your analysis?

Sandra McBride: Yes.

Mr Beer: If we go to page 5.

Sandra McBride: We did – what our response was to feedback.

Mr Beer: Scroll down, please. There’s your narrative explaining the result. You say:

“From the above results the majority of new agents who completed the feedback questionnaire feel that they have received sufficient training to enable them to process transactions and prepare the office balance.”

That of course is statistically correct because a majority did, more than 50 per cent did.

Sandra McBride: Yes.

Mr Beer: But can you remember why the 72 per cent figure was not seen as a concern?

Sandra McBride: No, I don’t.

Mr Beer: Seen by you as a concern?

Sandra McBride: No, no, I don’t recall.

Mr Beer: Because it’s close to a third of individuals not feeling they’ve received sufficient training to enable them to prepare transactions and prepare an office balance.

Sandra McBride: I think – no, I don’t know.

Mr Beer: At the foot of the page:

“Half of respondents felt they didn’t need any further training or support. From those who did feel they needed further training or support 18 per cent replied that they required further [over the page, please] training in the weekly and TP balances.”

Can you remember what was done as a result of that?

Sandra McBride: Well, only from what it says here:

“As part of the new training offered the agent receives coaching on (… read sotto voce …) they are assessed on the quality of their conversations.”

That doesn’t relate to that, does it?

Mr Beer: No. I can’t see anything that relates to the balancing issue that has been pulled up from –

Sandra McBride: I’m sorry, no, I don’t know then. Sorry.

Mr Beer: We’ve heard some evidence in the Inquiry that, in the testing stage of Horizon in the late ’90s, in the acceptance phase of Horizon, when Horizon was being tested against some contractual provisions to determine whether the Post Office should agree that the project could proceed further to national rollout, and in the course of national rollout concerns were expressed by subpostmasters about the balancing process, and here a decade on there is a significant minority of people saying that they have issues or concerns with the balancing process. It’s one of the top concerns of those that expressed a view.

Can you recall whether this was escalated within the Post Office or not?

Sandra McBride: No, I can’t.

Mr Beer: Who would this report have gone to?

Sandra McBride: This one? My line manager.

Mr Beer: Who was?

Sandra McBride: I think it would have been Sue Richardson.

Mr Beer: Still at April 2011?

Sandra McBride: Possibly, and I don’t know where else it would have gone.

Mr Beer: Were you aware of the things that I’ve just mentioned, that concerns had been consistently expressed by subpostmasters and others in testing acceptance and rollout over balancing?

Sandra McBride: No.

Mr Beer: So for you this was just a standalone analysis of 88 responses to a request for feedback?

Sandra McBride: Yes.

Mr Beer: Thank you. Then turning to the end of your time in the Post Office, please, can we look at POL00088953.

I think we can see you are a recipient of this email in January 2015 from Simon Drinkwater. You’re second in the distribution list.

Sandra McBride: Yes.

Mr Beer: So this is a year or so before you take redundancy?

Sandra McBride: Yes.

Mr Beer: Mr Drinkwater, if we just scroll down a little bit, we can see he was part of business transformation. Do you remember him?

Sandra McBride: Yes.

Mr Beer: Can you remember what role he performed in business transformation?

Sandra McBride: No.

Mr Beer: He says:

“Hi everyone. Natalie Liff …”

Is that field support adviser again?

Sandra McBride: Yes.

Mr Beer: “ … has worked on producing a quick guide to balancing for postmasters who have a loss or gain. See attached. This has been produced because there doesn’t seem to be a clear process to follow in the event of a misbalance.”

Do you know why it was that, 15 years after the introduction of Horizon, there wasn’t a clear process to follow in the event of a misbalance?

Sandra McBride: No, I don’t.

Mr Beer: If we look at the top of the page, please, and look at the distribution list there, could you talk us through, if you know, what role those people were performing at this time. So Sue Richardson?

Sandra McBride: She was my line manager.

Mr Beer: So her title and role would be?

Sandra McBride: I can’t remember her title at the time.

Mr Beer: Her role would be?

Sandra McBride: I think it was projects, something projects manager. I can’t remember exactly the title. Her role – well, no, I don’t remember. I should remember, but sorry.

Mr Beer: Jackie Newton?

Sandra McBride: She was training, something to do with training, but I can’t remember her full role.

Mr Beer: Angela van den Bogerd?

Sandra McBride: Higher up but I don’t know exactly her role.

Mr Beer: Craig Tuthill?

Sandra McBride: I know the name – I can’t remember his title and role.

Mr Beer: Ann Allaker?

Sandra McBride: I’m not going to be very helpful here, sorry.

Mr Beer: Cutting things short, for the remainder of the people on the To list, is there anyone you recognise and the job that they did?

Sandra McBride: I recognise my husband’s name Drew McBride and his role at the time. I can’t recall actually exactly the title. He was head of something. I should know that. Sorry, Drew.

Then there’s Natalie Liff, who was the FSA who produced the handout. Chris Gilding –

Mr Beer: We know.

Sandra McBride: Yes.

Mr Beer: And Tim Gordon Pounder?

Sandra McBride: He’s FSA similar to Natalie.

Mr Beer: Of the people mentioned in that distribution and copy list, did any of them have responsibility for or connections to investigations?

Sandra McBride: I don’t know. I don’t think so, but I don’t know.

Mr Beer: We’ve seen that the email says that there doesn’t seem to be a clear process to follow in the event of a misbalance, and then a series of questions are asked by reference to the document that’s attached a quick guide to balancing, and four questions are asked.

Can you recall whether you answered them?

Sandra McBride: No, I don’t recall.

Mr Beer: You can’t recall whether you answered any of these questions or not?

Sandra McBride: I think I would have done. If we were asked to respond, then I would have responded. But I don’t recall what I said.

Mr Beer: If we go over the page, please, I think this is the document that was described as the quick and easy guide to balancing. Can you recall whether you regarded this as a quick and easy or clear and easy process to follow for a subpostmaster to reconcile his or her cash and stock on Horizon as at 2015?

Sandra McBride: From reading it, it looks straightforward enough to me, but I don’t have enough Horizon experience to know whether in practical terms that would have been an easy guide to follow.

Mr Beer: Thank you. Those are the only questions that I ask, Mrs McBride. There may be some questions from others starting – no? No, thank you very much. Those are all of the questions that you are to be asked. Thank you.

Sandra McBride: Thank you.

Sir Wyn Williams: Well, Mrs McBride, thank you very much for coming to the Inquiry and for answering a good deal of questions this morning. I’m grateful to you. Thanks again.

Sandra McBride: You’re welcome. Thank you.

Mr Beer: Sir, we’re not sitting this afternoon or, tomorrow and so the Inquiry reconvenes at 10 am on Thursday.

Sir Wyn Williams: Fine, all right. Thank you very much. See you then. Goodbye.

Mr Beer: Thank you, sir.

(12.45 pm)

(Adjourned until Thursday, 19 January at 10.00 am)