8 March 2023 – Andrew Dunks
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(10.00 am)
Announcements by Sir Wyn Williams
Sir Wyn Williams: Before we hear evidence this morning, there’s just some announcements that I’d like to make.
The first announcement is to report that over the last few months two of the Inquiry’s Core Participants have passed away. Mrs Isabella Wall died shortly before Christmas and Mrs Lynette Hutchings died more recently. Each of those ladies were Core Participants, made Core Participants shortly after the Public Inquiry was constituted as such.
Each of them made a written statement, a written witness statement, and the summary of that evidence was read into the record, in Mrs Hutchings’ case on 10 March last year and, in Mrs Wall’s case, the 17 March 2022. The evidence demonstrates the hardship which both those ladies suffered.
On behalf of the whole of the Inquiry Team and on my own behalf, I extend condolences and deepest sympathy to their family and close friends.
Mr Moloney, do you know whether compensation payments were finalised in Mrs Hutchings’ case?
Mr Moloney: Not finalised, sir.
Sir Wyn Williams: Mr Jacobs, what’s the position with Mrs Wall?
Mr Jacobs: Sir, the letter concerning interim compensation was in the post at the time of her death. Sadly, sir, she died without ever knowing the sum.
Sir Wyn Williams: That relates to interim compensation. Can I take it that final compensation has not been determined in her case?
Mr Jacobs: That is correct, sir, yes.
Sir Wyn Williams: Thank you very much.
The second announcement I wish to make relates to a letter which I sent to the Department, BEIS, last week, which I copied to the legal representatives of the Post Office, concerning the statutory instruments which were published by the Government relating to the exemption from taxation for those participating in the overturned Historic Convictions Scheme and the newly constituted Group Litigation Scheme.
I queried whether or not such exemptions would, in due course, apply to those who’d made applications to the Historic Shortfall Scheme. I was hoping for a reply from the Department by last evening but perhaps, understandably, the Department have made a request which I have granted for a short extension to respond to my letter. Can I simply say at this stage that, once that response has been received, I will disclose both my letter and the response to Core Participants and publish the letters on the Inquiry website.
The third announcement I wish to make relates to today’s programme. Much to my surprise, I managed to get here from South Wales this morning but I’m told that there is further snow forecast for this afternoon and this evening and, for peace in the Williams household, therefore, I wish to return before I am marooned. So today’s proceedings will cease at 1.00 pm.
I am told that will be sufficient time for Mr Beer to ask the questions which he wishes to ask of Mr Dunks. He also tells me that it’s almost inevitable that Mr Dunks will be asked to return in later phases of this Inquiry and, accordingly, I am going to ask the Core Participant representatives to bear with me and reserve their questions for that later time so that I can hopefully get on a train and go back to South Wales. So thank you.
Over to you, Mr Beer.
Mr Beer: Thank you very much. May I call Andrew Dunks, please.
Andrew Dunks
ANDREW PAUL DUNKS (sworn).
Questioned by Mr Beer
Mr Beer: Thank you very much, Mr Dunks. As you know, my name is Jason Beer and I ask questions on behalf of the Inquiry. Can you tell us your full name, please.
Andrew Dunks: Andrew Paul Dunks.
Mr Beer: Thank you very much for coming to give evidence to the Inquiry today and for the provision of your witness statement.
In the hard copy bundle in front of you at tab A1 there should be a copy of that witness statement. Can you open it, please.
Andrew Dunks: Yes.
Mr Beer: It should be an 18-page witness statement dated 20 February –
Andrew Dunks: Yes.
Mr Beer: – 2023. If you turn to the 18th page you should find your signature.
Andrew Dunks: Yeah.
Mr Beer: Is that your signature?
Andrew Dunks: It is, yeah.
Mr Beer: Are the contents of that witness statement true to the best of your knowledge and belief?
Andrew Dunks: It is, yes.
Mr Beer: I’m going to ask you questions primarily about issues that arise in Phase 3 of the Inquiry, albeit there are some references to your engagement in individual prosecutions, and the Group Litigation proceedings, where those matters are relevant to the role that you performed and the tasks that you undertook, which is relevant to Phase 3 of the Inquiry. As the Chairman has said, in any event, it was the intention to recall you in Phases 4 or 5 of the Inquiry, and that’s because, as I think you know, you gave evidence in a number of prosecutions and civil claims, including those of Josephine Hamilton, Seema Misra and Lee Castleton.
Can I start with your background and experience, please. You left school, I think, at the age often 16; is that right?
Andrew Dunks: Mm-hm.
Mr Beer: You went to a college undertaking a training course in electronics; is that right?
Andrew Dunks: Yes, yeah.
Mr Beer: You then worked building residential extensions; is that right?
Andrew Dunks: Mm-hm.
Mr Beer: Then took another job in installing acoustic vents?
Andrew Dunks: Yes.
Mr Beer: You tell us in your witness statement that, in 1996, a friend who worked for ICL offered to get you a job in desktop computer support?
Andrew Dunks: Yes.
Mr Beer: Did you get that job?
Andrew Dunks: I did.
Mr Beer: Did that job involve providing IT support to ICL employees?
Andrew Dunks: Yes, it did.
Mr Beer: You tell us in your witness statement that you had no experience at all in that sort of work. Was that correct?
Andrew Dunks: Yes.
Mr Beer: And no qualifications to undertake it; is that right?
Andrew Dunks: No. That’s right, yeah.
Mr Beer: To be clear, though, none of that work involved the Post Office, Horizon, or the provision of IT support outside ICL; is that right?
Andrew Dunks: That’s correct.
Mr Beer: Did you carry on doing that job until about 2002, so about six years?
Andrew Dunks: Yeah.
Mr Beer: You moved to the Customer Service Post Office Account Security Team; is that right?
Andrew Dunks: Mm-hm.
Mr Beer: That is sometimes abbreviated to CPSOA (sic)?
Andrew Dunks: CSPOA.
Mr Beer: CSPOA, thank you very much. By that time, 2002, ICL had become Fujitsu?
Andrew Dunks: I believe so, yeah.
Mr Beer: By that time, when you took up this new role in the security team, did you know anything about the operation or integrity of the Horizon System?
Andrew Dunks: Not at all.
Mr Beer: I think you were the cryptographic key manager for the team?
Andrew Dunks: I was, yeah.
Mr Beer: Although you were described as a manager, is it right that you didn’t manage anyone?
Andrew Dunks: Correct, yeah.
Mr Beer: You had no reports to you?
Andrew Dunks: Correct.
Mr Beer: You say in your statement that you reported to the operational security manager?
Andrew Dunks: Mm-hm.
Mr Beer: Can you remember who that was, please?
Andrew Dunks: Well, at the time of joining, I think it was someone called Bill Mitchell.
Mr Beer: Bill Mitchell?
Andrew Dunks: Yes.
Mr Beer: They, in turn – Mr Mitchell – reported to the information security officer?
Andrew Dunks: I – yes, I think so.
Mr Beer: Who was that?
Andrew Dunks: I don’t know. I can’t – I don’t remember.
Mr Beer: Was the information security officer essentially the head of this department?
Andrew Dunks: Um … yes.
Mr Beer: Where were you based?
Andrew Dunks: In Feltham.
Mr Beer: How many people were in the Post Office Account Security Team?
Andrew Dunks: I think at the time about four.
Mr Beer: Did you receive any formal training prior to taking up the role?
Andrew Dunks: No.
Mr Beer: Did you ever receive any formal training from Fujitsu?
Andrew Dunks: In what respect? I went on network – I did a number of courses within Fujitsu.
Mr Beer: What kind of courses?
Andrew Dunks: Antivirus course, a networks course.
Mr Beer: What was the networks course?
Andrew Dunks: Um … I can’t remember. It’s about integrity – not integrity, sorry. It was about how networks work and IP addresses and things like that.
Mr Beer: Who was it provided by?
Andrew Dunks: I can’t remember.
Mr Beer: Was it internal to Fujitsu or did you extend –
Andrew Dunks: I think it was an external company.
Mr Beer: How long did it last?
Andrew Dunks: It was probably – I think it was a day.
Mr Beer: Was that the nature of the training you got, sort of a day here and a day there?
Andrew Dunks: Yeah.
Mr Beer: How many days up until the time, say 2016, 2017?
Andrew Dunks: I can’t remember.
Mr Beer: Did you have an annual training programme?
Andrew Dunks: There was an annual training programme but that didn’t mean we took it up or did any training.
Mr Beer: It was there on paper but you didn’t necessarily always do it?
Andrew Dunks: Agreed, yeah.
Mr Beer: Why was that?
Andrew Dunks: There was – it was – only went on a training course that was specific or a need for it.
Mr Beer: Can you recall now any formal training that you undertook with Fujitsu that was relevant to your role, or has it passed into the ether?
Andrew Dunks: Relevant to my role at the time of joining the Post Office Account was a handover from the previous person who looked after the cryptographic keys.
Mr Beer: How long did the handover last?
Andrew Dunks: It would have been a week or two weeks. I really can’t remember.
Mr Beer: Did anyone in the Post Office Account Security Team have any formal qualifications in information technology or computer science?
Andrew Dunks: I don’t know. I can’t remember.
Mr Beer: As you sit here now, nobody stands out in your memory as being expertly qualified in those disciplines?
Andrew Dunks: Not specifically, no, but I believed to become a CISO you have to take the qualifications – industry qualifications.
Mr Beer: What happened did your job as a cryptographic key manager involve?
Andrew Dunks: Basically was to refresh the cryptographic encoding keys on the counters of each branch.
Mr Beer: Just tell us what a cryptographic key is, please?
Andrew Dunks: A cryptographic key encodes the data while it’s being transferred through the network to the database or the Horizon system. It will encode it at source in the counter that goes through the networks and will be decrypted at the other end. So it’s a secure transfer of data, and those keys were refreshed every two years.
Mr Beer: So that was the period of periodic refreshment?
Andrew Dunks: Yes.
Mr Beer: How was that done under Legacy Horizon? Do you understand my use of the phrase Legacy Horizon, the Horizon system before came along?
Andrew Dunks: How was it done? I would have generated the new keys in a secure room.
Mr Beer: How did you generate the new keys?
Andrew Dunks: On a terminal in the secure room, there’s a piece of software, key generation software, and then from the secure standalone PC they would be transferred from there onto another PC which would be connected to the Horizon system –
Mr Beer: Just pause a moment, it looks like something is being said.
Can we just pause a moment, I think there’s a problem with the transcript. (Pause)
Sir, can I ask you to rise please whilst the problem with the transcript is being fixed.
(10.18 am)
(A short break)
(10.26 am)
Mr Beer: Sir, apologies for the interruption and to Mr Dunks.
You were just telling us about the way in which you provided, refreshed or updated cryptographic keys to branches –
Andrew Dunks: Yes.
Mr Beer: – and telling us that you generated them on a standalone system at the Feltham office.
Andrew Dunks: Yes.
Mr Beer: What happened then?
Andrew Dunks: They were – um, no, it wasn’t at the Feltham office, if I remember correctly, it would have been at – oh, actually I’m not sure. It was either Feltham or Bracknell at the time. Once they were generated they were transferred on a cassette onto another PC within the room, and that had secure connection to the network, the Horizon network, and that would then push the keys out to the appropriate counters.
Mr Beer: How would the counters know about their new cryptographic key?
Andrew Dunks: I can’t remember how that worked.
Mr Beer: Did they receive a communication separately from that which was pushed out electronically?
Andrew Dunks: I can’t remember.
Mr Beer: Did the system change when you moved from Legacy Horizon to Horizon Online?
Andrew Dunks: Yes, it did.
Mr Beer: Was this your principal function: cryptographic key manager?
Andrew Dunks: Yes.
Mr Beer: You tell us in your witness statement that your rollover time expanded to include other areas of information technology security?
Andrew Dunks: Mm-hm.
Mr Beer: Before it expanded into those other areas, did you receive bespoke training in relation to each of the areas?
Andrew Dunks: We were given training to be able to do the job we were asked to do, yes.
Mr Beer: Was that internal to Fujitsu?
Andrew Dunks: Yes.
Mr Beer: I think you mentioned five areas. They are user management, intrusion prevention, processing applications for security checks, performing audit data extractions and performing transaction reconciliations?
Andrew Dunks: Mm-hm.
Mr Beer: Can I look at each of those five roles or functions in turn?
Andrew Dunks: Sure.
Mr Beer: Firstly, user management. You tell us in your statement, it’s paragraph 9, that user management involved maintaining a database of all of the Fujitsu employees with access to the Horizon System; is that right?
Andrew Dunks: Yeah.
Mr Beer: How many employees, broadly, were there within Fujitsu who had access to the Horizon System?
Andrew Dunks: I can’t remember.
Mr Beer: Are we talking 5, 50, 500 or 5,000?
Andrew Dunks: Oh, in the hundreds, yeah.
Mr Beer: In the hundreds?
Andrew Dunks: It could have been 100 or 200 because not everybody within the Post Office Account had access or log-on access to the Horizon System itself.
Mr Beer: Were there different levels of access?
Andrew Dunks: Yes.
Mr Beer: Can you describe, in broad terms, the different levels?
Andrew Dunks: It varied from being able – it depended on what system they were – that person or support person needed to log on to and their level of access on what they were able to do on that platform. So it would have been, if I remember correctly, view only or read and then it went up to an admin level where they were able to log on and fix a problem or look at a problem at a higher level on whatever database they had access to.
Mr Beer: Is that the best of your recollection now?
Andrew Dunks: Yeah, that’s still the same now.
Mr Beer: I forgot to ask you, what are you doing at the moment?
Andrew Dunks: I’m still doing it the same job but specifically just the key management.
Mr Beer: You don’t do the other five things that I mentioned?
Andrew Dunks: I haven’t done for a while, no.
Mr Beer: Why is that?
Andrew Dunks: We – I think our teams expanded to seven or eight people, so it’s more bespoke and you’re looking after your area.
Mr Beer: Can we look at a document, please, FUJ00088036. Can you see that this is a document entitled “Secure Support System Outline Design”, version 1.0 and it’s dated 2 August 2002.
Andrew Dunks: Yeah.
Mr Beer: So it’s dated at the beginning of your role in the Post Office Account Security Team; would that be right?
Andrew Dunks: Yes.
Mr Beer: Can we please look at page 15 of the document, please, and under paragraph 4.3.2, if we can just read the first paragraph and the first bullet together:
“All support access to the Horizon systems is from physically secure areas. Individuals involved in the support process undergo more frequent security vetting checks. Other than the above controls are vested in manual procedures, requiring managerial sign-off controlling access to post office counters where update of data is required. Otherwise third line support has:
“Unrestricted and unaudited privileged access (system admin) to all systems including post office counter PCs …”
Did that reflect the position as you understood it, that those in the SSC, the third line support, had unlimited and unrestricted privilege access to all systems including post office counter PCs?
Andrew Dunks: I don’t know. I don’t recall the level of actual access that each individual had, although – because we would have given the access – asked for and required for their role and asked from their line manager.
Mr Beer: Did your team have the function of regulating such access?
Andrew Dunks: Only to the extent that we gave them the access that was requested.
Mr Beer: So yes, you carried it out –
Andrew Dunks: Yes.
Mr Beer: – ie limiting or expanding access?
Andrew Dunks: It was more we got the request for access to, yes, a system, and we would have passed on that request to whoever then would set up the access. So we weren’t physically going in and editing or changing that specific person’s access, somebody else within another team would do that.
Mr Beer: So who did you get the request from and to whom did you send it?
Andrew Dunks: I can’t remember directly who it came from but it would have been – it would have come from a line manager, there would have been a process in place.
Mr Beer: A line manager within Fujitsu?
Andrew Dunks: Within whoever that person worked for. Line manager of the person requesting or needing that access.
Mr Beer: Would it be within Fujitsu or from the Post Office –
Andrew Dunks: Oh no, it would be within Fujitsu, the Post Office Account itself.
Mr Beer: Right. So – and then you would send it to who?
Andrew Dunks: We would – I’m trying to think. We would pass it on to the admin team that managed NT user accounts at the time, which I believe, if I have remembered correctly, and I think still is, is a support team in Belfast.
Mr Beer: Why was it sent through you or your team?
Andrew Dunks: So we could keep records of who’s got what access – not who’s got what access – who’s got access to systems, not the level of access. They’ve got to log on. They’ve been granted permission for a log-on and it’s been set up.
Mr Beer: Was any conscious thought or brainpower applied to the request that was coming in or did the fact that a line manager had asked for expanded access mean that it was always granted?
Andrew Dunks: Yes. No, we – for want of a better word, we were sort of administering that request and passing on for it to be actioned.
Mr Beer: So it was just an administrative function?
Andrew Dunks: Yes, mm-hm.
Mr Beer: Did anyone, to your knowledge, apply what I’ve described as brain power, ie think, “I’ve had a request in to expand Mr X’s access, the following reasons have been given. I accept” or “I decline this request, pass on to the accurate team to administer”?
Andrew Dunks: No, that wasn’t in question because we were – no. We just processed the request.
Mr Beer: This describes the third line support having unrestricted and unaudited privileged access, including to counter PCs, yes?
Andrew Dunks: Yes.
Mr Beer: In your 21 years performing this function, did you know that?
Andrew Dunks: No, because I – no, I didn’t.
Mr Beer: You, I think – we’re going to come on perhaps next time to discuss – provided a witness statement in High Court proceedings, the Bates litigation –
Andrew Dunks: Mm-hm.
Mr Beer: – which I think you describe it as, the Group Litigation, where you set out in a statement 12 control measures –
Andrew Dunks: Yeah.
Mr Beer: – the purpose of which, is this right, was to ensure or assure the integrity of access to the system?
Andrew Dunks: Those 12 controls were the controls put in place when we extracted the ARQ data.
Mr Beer: They weren’t a broader description of controls over access to the system more generally?
Andrew Dunks: No.
Mr Beer: So they’re specifically about the control measures concerning extraction of data?
Andrew Dunks: Yes.
Mr Beer: You also provided – we’re going to come to discuss in a moment – witness statements in a number of criminal investigations and prosecutions, in which you said words to the effect of “I’ve looked at records of calls made to helpdesks and there’s nothing in those which leads me to believe that the system was operating improperly or the substance of the calls is relevant to the integrity of the data”.
Andrew Dunks: Mm-hm.
Mr Beer: Wouldn’t you want to know this kind of information that we’re looking at on this page in order to say that kind of thing?
Andrew Dunks: No. I wouldn’t have needed to know that.
Mr Beer: There’s a whole class of people who have got unrestricted and unaudited access to a computer system and, therefore, can make changes to it.
Andrew Dunks: My witness statements were purely on individual calls logged to the helpdesk and I went through each and every of those calls and based my assumption or my resolution on those specific calls.
Mr Beer: In the course of your time performing this function, were you aware of any changes made to tighten or restrict access to the third line support, the SSC?
Andrew Dunks: During that time, I believe there was a project to address or look at levels of – or if people had the right access within their log-ins.
Mr Beer: Why was there a project to look at whether people had the right levels of access?
Andrew Dunks: I don’t know. I wasn’t involved in it. I was aware of it.
Mr Beer: How were you aware of it?
Andrew Dunks: Because I think my line manager at the time was involved in that project.
Mr Beer: Who was your line manager at the time?
Andrew Dunks: It was very difficult. We had so many line managers come and go. But I can’t remember who specifically it was at that time during that project.
Mr Beer: Can we look at page 1 of this document, please, and scroll down. Starting from underneath the word “Approved” in capital letters.
Andrew Dunks: Mm-hm.
Mr Beer: Can you run through, please, the people mentioned, starting with Peter Robinson, the IPDU Security.
Andrew Dunks: Peter Robinson?
Mr Beer: Did I say a different word?
Andrew Dunks: You see – oh, sorry. I beg your pardon. I was looking further down.
Mr Beer: Peter Robinson.
Andrew Dunks: Mm-hm.
Mr Beer: What function did he perform?
Andrew Dunks: I don’t know who he was.
Mr Beer: Simon Fawkes?
Andrew Dunks: Again, I don’t know who he was.
Mr Beer: Colin Mills?
Andrew Dunks: No.
Mr Beer: Then looking at the table, please, towards the foot of the page, Ian Morrison?
Andrew Dunks: No, the only person that I recognise is Mik Peach.
Mr Beer: What do you recognise about Mik Peach?
Andrew Dunks: He was the head of or manager of the SSC’s third line support team.
Mr Beer: So the head of the team that we were just looking at that had this unrestricted and unaudited access?
Andrew Dunks: Yes, because it said the SSC, yes.
Mr Beer: What dealings did you have, how frequently and of what nature with Mr Peach?
Andrew Dunks: Actually – infrequently, actually.
Mr Beer: What was the nature of your – what was the purpose of them, what was the reason for them?
Andrew Dunks: I can’t remember. I can’t remember.
Mr Beer: Can we go over the page, please, and scroll down. In that list of names is there anyone that you recognise?
Andrew Dunks: Steve Parker, who was a member of the SSC team, who worked –
Mr Beer: And –
Andrew Dunks: Sorry?
Mr Beer: I’m sorry, go ahead.
Andrew Dunks: Who worked for Mik Peach.
Mr Beer: Was your contact with him at the same level as with Mr Peach?
Andrew Dunks: I would probably have spoken to Steve Parker a lot more, because – to ask questions or get some information from him.
Mr Beer: About?
Andrew Dunks: Generally about the system or calls logged or – it was a number of different reasons why I would have spoken to Steve.
Mr Beer: Could you outline to us in broad terms in what circumstances you would go and speak to Mr Peach – sorry, Mr Parker?
Andrew Dunks: No, I can’t remember specifics that I spoke to him. It would have been support issues and questions or help that we needed at the time.
Mr Beer: Help about what?
Andrew Dunks: About anything on the account, because they were very knowledgeable about things.
Mr Beer: What things?
Andrew Dunks: About Horizon.
Mr Beer: What about Horizon?
Andrew Dunks: The workings of Horizon.
Mr Beer: What workings of Horizon?
Andrew Dunks: Calls that would have been logged, that I actually had to look into for the witness statements. It wouldn’t have just been Steve. There were many members of the SSC we would have had dealings with. Within the reconciliation process, we would have spoken to the SSC and that could have been Steve Parker.
Mr Beer: Would you just speak to them or would your communications be documented in any way?
Andrew Dunks: I would say most of the time it was a phone call or I’d walk up to the sixth floor and have a chat.
Mr Beer: The reason for me asking this, just so you understand, is that you ended up providing witness statements in a series of prosecutions –
Andrew Dunks: Yeah.
Mr Beer: – which made certain assertions.
Andrew Dunks: Yes.
Mr Beer: We’re later going to explore whether those assertions were true or misleading –
Andrew Dunks: Mm-hm.
Mr Beer: – and, if untrue or misleading, what they were based on, what you based your information on. So at the moment I’m just trying gently to explore where you get your information from; do you understand?
Andrew Dunks: Mm-hm.
Mr Beer: So can you, with that background in mind, tell me a bit more about when and in what circumstances you might go to someone in the SSC?
Andrew Dunks: If there was an area within calls that we’d passed on to do reconciliation that we didn’t quite understand the wording that they’d put in within the call, um –
Mr Beer: Did you treat them as the subject matter experts in Horizon?
Andrew Dunks: Yes, I did.
Mr Beer: Was there anyone else that you treated as a subject matter expert in Horizon?
Andrew Dunks: There were a number of different support teams, because within the – my remit of cryptographic keys there were the development team for the cryptographic keys; the audit system, they had a support and development team. So whatever areas we worked in, there would always be like a first point of contact we’d go to.
Mr Beer: Does the SSC stand out in your memory as –
Andrew Dunks: Oh, probably – yes, yes, we would have gone through them quite a lot.
Mr Beer: But the communications you had with them were mainly verbal, either face-to-face or on the phone?
Andrew Dunks: Yeah.
Mr Beer: That can come down, please. Can we turn to the second of the five additional roles that your job expanded to include and that’s intrusion prevention. You tell us in paragraph 10 of your witness statement that this involved ensuring that antivirus software was updated appropriately on the Horizon System.
Andrew Dunks: Mm-hm.
Mr Beer: What was your role specifically in relation to that?
Andrew Dunks: I wasn’t heavily involved in that one but part of that role was to have a look at all the platforms within the Horizon System to see that they’ve had their virus updated, signatures updated.
Mr Beer: Were you trained to do this?
Andrew Dunks: I was trained and shown how to do that, yes.
Mr Beer: So you were shown how to do it?
Andrew Dunks: Yes.
Mr Beer: So what did it involve doing?
Andrew Dunks: Sorry?
Mr Beer: What did it involve you doing?
Andrew Dunks: We’d log on to a piece of software or a platform, and that would list all the platforms that were taking or being updated with the antivirus, and if one hadn’t been update for a period of time, we would either – I can’t remember what we did, either log a call or investigate why it hasn’t accepted the updates, and got it resolved.
Mr Beer: How would you get it resolved?
Andrew Dunks: I can’t remember.
Mr Beer: Is somebody in your team still doing this?
Andrew Dunks: We’re doing ESET updates. I believe so, yes.
Mr Beer: But you now can’t remember or don’t know?
Andrew Dunks: No, it was a long time ago, though, that I had involvement in ESET updates or antivirus updates.
Mr Beer: The way you describe it sounds like an administrative function –
Andrew Dunks: Again –
Mr Beer: – rather than involving any technical expertise on your part; is that fair?
Andrew Dunks: Yes.
Mr Beer: Can I turn to the third role that you say you performed, which is processing applications for security checks, and you tell us in paragraph 11 of your statement that this concerned providing administrative assistance to facilitate the vetting being carried out on new subpostmasters; is that right?
Andrew Dunks: Yes.
Mr Beer: What was the nature and extent of the good character checks carried out on subpostmasters before they were appointed, to your knowledge?
Andrew Dunks: I don’t know the exact – what checks were carried out, because that was carried out by – oh, the team – it was a security team based on the ground floor.
Mr Beer: A Fujitsu team or a Post Office team?
Andrew Dunks: Fujitsu team.
Mr Beer: So there was a team on the ground floor, a security team carrying out what I’ve described as character checks, good character checks –
Andrew Dunks: Yes.
Mr Beer: – on subpostmasters?
Andrew Dunks: Yes.
Mr Beer: Why were Fujitsu carrying out the character checks on subpostmasters?
Andrew Dunks: I have no idea.
Mr Beer: Do you know what those checks involved?
Andrew Dunks: No, I’d be guessing.
Mr Beer: You tell us in your statement that your role was processing applications for security checks. What did that involve, your role, processing the applications for security checks?
Andrew Dunks: It would have been receiving – if I remember correctly because they stopped quite a long time ago – we would have received an email application from the Post Office, including photographic evidence of passports and – I can’t remember what else. I remember passports. We would have passed all the information of that applicant down to Fujitsu security. They would then carry out whatever checks, financial/background, I don’t know, checks to them – for them. If it – most of the time it came back okay. Nearly all the time it came back – I can’t recall when it didn’t.
They would then come back and say, “Yes, all good”. We would then request a pass to be created with the subpostmaster’s photograph and name and I think a unique ID number. We would get that and then put it in the post to the Post Office.
Mr Beer: You said that you can’t recall a check ever coming back as a negative, meaning that it couldn’t be refused?
Andrew Dunks: Been refused – yeah. No, I don’t remember.
Mr Beer: At this time, say between 2000 and 2015 – so admittedly you only came into the role in 2002 – were you aware in general terms that subpostmasters were being prosecuted for criminal offences?
Andrew Dunks: Yes, I was aware.
Mr Beer: I think the answer must be yes because you provided witness statements –
Andrew Dunks: Oh, yeah, yeah –
Mr Beer: – to help to prosecute them?
Andrew Dunks: Yeah.
Mr Beer: Were you aware of the numbers involved of the prosecutions?
Andrew Dunks: No.
Mr Beer: Was there ever any conversation in the office? I mean, we know now that between, I think, the year 2000 and 2015 there were about 850 prosecutions brought resulting in over 700 convictions?
Andrew Dunks: I wasn’t aware of numbers, no.
Mr Beer: Was there any conversation in the office that you heard about –
Andrew Dunks: No.
Mr Beer: – that “We’re putting all these people through these good character checks, they’re all coming back okay, and then they’re turning out to be people who engage in criminal conduct”?
Andrew Dunks: No, I don’t recall any conversation along those lines.
Mr Beer: So it wasn’t coming back down the line that “A large number of our subpostmasters are criminals”?
Andrew Dunks: No.
Mr Beer: Again, this sounds like you were just performing an admin function; would that be fair?
Andrew Dunks: Correct.
Mr Beer: Is that why you might not know about the bigger picture that I’m describing, namely looking at the whole dataset, how many prosecutions there have been, how many people are being convicted, despite the character checks we’re carrying out on these people?
Andrew Dunks: Correct. I’m unaware.
Mr Beer: The fourth task that you mention or role that you mention is performing audit data extractions. You tell us in paragraph 12 of your witness statement this involved responding to audit record queries, ARQs?
Andrew Dunks: Mm-hm.
Mr Beer: Is that what you understood the acronym ARQ to stand for, an audit record query?
Andrew Dunks: Yes.
Mr Beer: Would an ARQ, a query, refer to a common dataset or would there be subsets within it, the request?
Andrew Dunks: No, they were specifically requesting specific –
Mr Beer: So if somebody said “Give me the ARQ for this Post Office branch”, that would be an absurd request. They would have to say, “within this date range and this type of data”?
Andrew Dunks: Correct.
Mr Beer: Were you aware of any difference between Credence data, ARQ data, raw data, and enhanced ARQ data?
Andrew Dunks: No.
Mr Beer: Do you understand what Credence data is? Do you understand the reference to Credence data?
Andrew Dunks: No, I’ve heard of Credence data but I didn’t know what it was.
Mr Beer: In what context had you heard of Credence data?
Andrew Dunks: I don’t know. I don’t remember.
Mr Beer: Had you heard of reference to raw data?
Andrew Dunks: No.
Mr Beer: Had you heard any reference to enhanced ARQ data?
Andrew Dunks: No.
Mr Beer: You tell us in paragraph 12 of your witness statement how ARQ extractions were carried out. We’ve heard some evidence in the Inquiry from Gayle Peacock to the effect that part of the contract between the Post Office and Fujitsu included the provision of an agreed number of ARQ files that could be requested free of charge –
Andrew Dunks: Correct.
Mr Beer: – or without specific charge. Is that something that you knew about?
Andrew Dunks: Yes.
Mr Beer: But that if the Post Office exceeded the ceiling of the permissible requests for ARQ data then there was a charge to be levied to the Post Office; did you know about that?
Andrew Dunks: Yes.
Mr Beer: What did you understand about the nature of the charge if they exceeded the ceiling of permissible requests?
Andrew Dunks: I don’t know. I wasn’t involved in those conversations.
Mr Beer: Had you heard of a figure of £400, for example?
Andrew Dunks: No.
Mr Beer: What was the annual limit, to your understanding, of the permissible number of ARQ requests that could be made by the Post Office without incurring specific individual charges?
Andrew Dunks: I can’t remember specific because that number went up over the years. It either started below or above 700, 7 – I can’t remember.
Mr Beer: 700 or?
Andrew Dunks: 750.
Mr Beer: Can you recall how many requests were made within that ceiling –
Andrew Dunks: No.
Mr Beer: – and then above that ceiling, if it was exceeded –
Andrew Dunks: No –
Mr Beer: – for which a charge was made?
Andrew Dunks: – I can’t remember.
Mr Beer: Presumably there was a record kept of the number of requests that were made to your team, so that Fujitsu would know whether the –
Andrew Dunks: Yes.
Mr Beer: – ceiling was being reached or not?
Andrew Dunks: Well, the ARQs had a specific number, so it started on 1 April as ARQ1 and it incrementally went up during the year.
Mr Beer: So the number of the ARQ itself will tell you whether you had exceeded or they had exceeded the ceiling or not?
Andrew Dunks: Correct.
Mr Beer: Can you recall in your years working, performing this extraction function, how frequently the Post Office exceeded the ceiling?
Andrew Dunks: I can’t recall, no.
Mr Beer: Were you aware of any of the other commercial arrangements between the Post Office and Fujitsu for the provision of ARQ data –
Andrew Dunks: No.
Mr Beer: – such as turnaround times?
Andrew Dunks: There were SLAs for certain amounts of data that were requested, yes.
Mr Beer: Can you help us with those?
Andrew Dunks: I can’t remember what they were. It may have – sorry. I can’t remember but I would be guessing that some were – it depended on the number of days requested, how long we had to extract it and return it to the Post Office.
Mr Beer: Ie the size of the dataset –
Andrew Dunks: Yeah.
Mr Beer: – that you were asked to harvest –
Andrew Dunks: Yes.
Mr Beer: – affected the timeliness of the provision of it?
Andrew Dunks: That’s what I remember, yes.
Mr Beer: Can you recall anything else about the commercial arrangements between the Post Office and Fujitsu, for example whether the provision of witness statements was included within the price –
Andrew Dunks: No.
Mr Beer: – for which no additional fee was levied or whether a witness statement came at a cost?
Andrew Dunks: I have no idea no.
Mr Beer: Is that because you now can’t remember or it wasn’t something that you would ever have known about?
Andrew Dunks: I don’t believe I ever knew the cost or charges that Fujitsu had the Post Office.
Mr Beer: You were the person, as we’ll come on to discover, that was actually providing the witness statements –
Andrew Dunks: Mm-hm.
Mr Beer: – about the extraction of data?
Andrew Dunks: Yes.
Mr Beer: How you’d gone about it, what it consisted of, and what you thought it showed?
Andrew Dunks: Yes.
Mr Beer: Were there never any discussions about how much Fujitsu was earning from this function and therefore the work that you put into it?
Andrew Dunks: No, never.
Mr Beer: Was there any limitation ever put on the work that you put into the investigatory activity that you carried out before providing a witness statement?
Andrew Dunks: No.
Mr Beer: So they didn’t say, “We’re getting [X] pounds, Fujitsu are getting [X] pounds for providing this witness statement” –
Andrew Dunks: No.
Mr Beer: – “and therefore you should only spend [Y] time doing the work”?
Andrew Dunks: No, not at all. I’d never heard of that. That was never a discussion.
Mr Beer: So you could spend as much time as was necessary in order properly to research the issue that you were being asked to address in the witness statement before providing the witness statement?
Andrew Dunks: Oh, definitely. I would have needed as much time as I needed to understand the nature of the call.
Mr Beer: It’s correct, isn’t it, that in broad terms ARQ that was branch data that related to all of the key strokes on the system that somebody in the branch had undertaken?
Andrew Dunks: Not key strokes. That probably was part of the data. It was more the transaction and what was paid for, what was – and how much each transaction.
Mr Beer: It was an insight into what tasks were being undertaken in branch, at what the end user was doing on the system and when?
Andrew Dunks: Yes.
Mr Beer: So it was a good window, a good insight into what was going on in the branch?
Andrew Dunks: I would say so, yes.
Mr Beer: You tell us in your witness statement that the requests for ARQ data would specify the branch, the date range, and the data type to be extracted; is that right?
Andrew Dunks: The?
Mr Beer: The branch, the date range and the data type to be extracted?
Andrew Dunks: Not the data type. It just would have been the data within that date range.
Mr Beer: Just look at WITN00300100. Please look at page 3, and look at paragraph 12 at the bottom and look at the third line. If this could be highlighted please:
“Each ARQ would specify the relevant Post Office branch, date range, and data type to be extracted.”
That’s where I got that from.
Andrew Dunks: The data type would have been the transactional data.
Mr Beer: I don’t understand what you’re meaning by saying, “Ah, but it would have been the transactional data”. Can you explain, please?
Andrew Dunks: They were – the request on the ARQ would have been the archived transactional data and that’s the data type.
Mr Beer: So what different specifications could there be for data type?
Andrew Dunks: There wouldn’t have been any that I can recall.
Mr Beer: So why did each ARQ need to specify the data type to be extracted, if there was only one type?
Andrew Dunks: I don’t know.
Mr Beer: What was the purpose of – I mean, where did this appear on the form or the document: “Data type to be extracted”, and then it would always say the same thing?
Andrew Dunks: I can’t remember if it specifically said “This data type”.
Mr Beer: Can you just explain what you were meaning, then, in this sentence in your witness statement:
“Each ARQ would specify … the data type to be extracted.”
Andrew Dunks: That would have meant that they were after – the ARQ meant that they were after the transaction data. That’s my meaning of that.
Mr Beer: Was it explained on the request the purpose to which the ARQ data that had been requested was to be put?
Andrew Dunks: Sorry, say it again?
Mr Beer: Was it set out on the request, was it explained on the request, the purpose to which the data that had been asked for was going to be put?
Andrew Dunks: No.
Mr Beer: What did you understand the purpose to which the data that you were being asked to provide was going to be put?
Andrew Dunks: They would be using it for investigation of any type.
Mr Beer: What do you mean investigation of any type?
Andrew Dunks: Investigating any fraud that was possibly going on. That was my understanding.
Mr Beer: So you knew that it was about a fraud investigation?
Andrew Dunks: Yes.
Mr Beer: There wasn’t a field on the request form that said, “This is for [X] purpose or [Y] purpose”?
Andrew Dunks: Not that I remember, no.
Mr Beer: Was the request filled in by someone in Fujitsu or the Post Office?
Andrew Dunks: The Post Office.
Mr Beer: How did you receive the request?
Andrew Dunks: Via email.
Mr Beer: In a standard form –
Andrew Dunks: Yes.
Mr Beer: – or –
Andrew Dunks: Yeah, yeah, yeah. Sorry, it would have come to – the CSPOA Security Team had a shared email account and that would have come into that account asking for, “Can you please supply the attached data”, and the attached would have been the ARQ in a Word document.
Mr Beer: Right. So that would be an email directly from somebody in the Post Office?
Andrew Dunks: Yes.
Mr Beer: The attached Word document, was that a pro forma?
Andrew Dunks: When you say pro forma?
Mr Beer: A template document?
Andrew Dunks: Yes.
Mr Beer: Whose template document was it?
Andrew Dunks: I –
Mr Beer: Was that a Fujitsu one or a Post Office one?
Andrew Dunks: I have no idea where it originated from.
Mr Beer: But that template document would have fields in it which said, “Post Office branch”, “data sought from this date to that date”.
Andrew Dunks: Yes.
Mr Beer: Were there any other fields in the template document?
Andrew Dunks: I’m trying to remember. There were ones which asked whether HSD call hardware calls were required.
Mr Beer: Yes, explain to us what that additional request might – why that additional request might be made?
Andrew Dunks: Because they wanted to see what calls – helpdesk calls were logged at that particular branch between that date – at that date range.
Mr Beer: So that was an add-on, was it? That wasn’t always requested?
Andrew Dunks: Correct.
Mr Beer: So that might be specifying the type of data sought, just thinking back to your witness statement?
Andrew Dunks: Yes, I suppose it could, yes. Yeah.
Mr Beer: Yes. Please continue. Were there any other types of add-ons, as I’ve called them, that might be specified on the template?
Andrew Dunks: There were whether a witness statement was required, yes or no.
Mr Beer: Yes.
Andrew Dunks: Within – oh, God – I think there was a section of “Any other” or “Any additional”, and they would possibly sometimes specify a specific transaction, or “Can you find or highlight a transaction that took place on”, a certain day for a certain amount of money. That again would be another request, within the – on the ARQ form.
Mr Beer: So a much more targeted request?
Andrew Dunks: Yes.
Mr Beer: Anything else?
Andrew Dunks: I can’t remember anything else, no.
Mr Beer: Were you told within the request form whether the audit extraction sought, the product of it, was to be used for civil or criminal litigation purposes?
Andrew Dunks: I don’t think it – no, I don’t think so.
Mr Beer: The request for a witness statement might give a clue to that, mightn’t it?
Andrew Dunks: Yeah, sorry, yes, if it was requesting a witness statement, yes.
Mr Beer: Was there any difference in the way that you went about harvesting the data sought or the means by which you supplied it if you knew it was going to be used for those purposes, criminal or civil litigation?
Andrew Dunks: None whatsoever.
Mr Beer: There wasn’t an additional standard applied or different steps undertaken?
Andrew Dunks: No.
Mr Beer: It was all the same?
Andrew Dunks: Yes.
Mr Beer: When were you first asked to perform these audit extractions?
Andrew Dunks: I couldn’t tell you. I joined, as I said, 2002. Somebody else was running ARQs at the time. I may have done some in 2002 or 2003, if that person was on – there was only one person doing the ARQs at the time.
Mr Beer: Who was that?
Andrew Dunks: I can’t remember her name and I can’t tell you the exact date of my very first ARQ that I ran.
Mr Beer: Was that person, the lady you can’t remember the name of, the person that gave you the on-the-job introduction to how to do this?
Andrew Dunks: Yes.
Mr Beer: Was there anything more developed or involved than that?
Andrew Dunks: No, no.
Mr Beer: Who was your boss at this time?
Andrew Dunks: I can’t remember at the time who my boss was when I joined.
Mr Beer: Why did you take over or your role expand to include this function?
Andrew Dunks: I think it was because that person left.
Mr Beer: What did you think of the task that you were being asked to perform?
Andrew Dunks: What do you mean what did I think about it?
Mr Beer: Did you think, on the one hand, “This is data extraction, it’s a process driven function, I get a request in, I type into a computer the information sought and then I pass it on” –
Andrew Dunks: Correct.
Mr Beer: – or did you think, “I’m performing an important function, the data which I produce may be used in criminal prosecutions, which prosecutions may seal the fate of an individual subpostmaster”?
Andrew Dunks: It would have been the first.
Mr Beer: So did you have any sense or idea of the significance of the function that you were performing?
Andrew Dunks: The significance was that we were extracting the data and it had to be the exact data that was requested. So it was what they required, no more. They hadn’t –
Mr Beer: So you had to get the date range right?
Andrew Dunks: Yes, we had to get the data that they requested was correct and pass it on, yes.
Mr Beer: Can we look, please – in fact, that might be an appropriate moment for a morning break. Could we take a slightly shorter break –
Sir Wyn Williams: Yes, of course.
Mr Beer: – and maybe come back at 25 past, please?
Sir Wyn Williams: Certainly, yes.
Mr Beer: Thank you, sir.
(11.14 am)
(A short break)
(11.26 am)
Mr Beer: Thank you, sir.
Mr Dunks, can we look please at FUJ00002000. This, is, you’ll see from the title, a “Service Description for the Security Management Service”. It’s dated 6 March 2006, it’s version 3. Then if we just scroll forward to page 3 of the document. The first box at the top of the page, “Issued for Information – Please restrict this distribution list to a minimum”.
You are one of the people to whom it was distributed?
Andrew Dunks: Yes.
Mr Beer: I use this document because it provides a description of some of the data that could be requested and provided on an ARQ and other request. Can we go, please, to page 11 of the document and go to beyond halfway down to paragraph 3.10. You’ll see that there are some definitional sections. I’m not too worried about the purpose to which these were put but I just want to see whether you recognise the distinctions that are being drawn in this description of the security management service of which you were a part.
You will see firstly there’s a defined term:
“‘Banking Transaction Record Query’ means a Record Query in respect of a Banking Transaction which the Data Reconciliation Service has reconciled or has reported as an exception, the result or records of which are subsequently queried or disputed by the Post Office or a third party …”
Then:
“‘Audit Record Query’ [an ARQ] means a Record Query which is not a Banking Transaction but which relates to Transactions …”
Do you recognise the distinction being drawn between those two things?
Andrew Dunks: Yes, I think so, yes.
Mr Beer: Would you sometimes receive requests for banking transaction record queries and sometimes receive requests for ARQ, audit recovery queries?
Andrew Dunks: I don’t recall or remember them being a distinction on the ARQ form.
Mr Beer: Can we continue and look at “Old Data”, do you see “Old Data is defined as meaning:
“… extraction of records created before 3rd January 2003, but not earlier than 18th May 2002 before which data was automatically deleted …”
Just stopping there, does that ring a bell with you? Does that accord with your recollection that there was a time at which data was automatically deleted from the system?
Andrew Dunks: Yes.
Mr Beer: Can you remember what the period of deletion was and whether it was uniform across all datasets?
Andrew Dunks: My recollection is that it was six or seven years.
Mr Beer: This document was written in March 2006 and it suggests that data just under 4 years old had been automatically deleted. Your recollection is different?
Andrew Dunks: No, my recollection is when I knew it was being – there was a deletion, was, I think around six or seven years. At the time of this I wouldn’t have known that it was being deleted.
Mr Beer: Why was that? In what circumstances did you come to know about the automated deletion of data?
Andrew Dunks: Later on in years, when we were requesting or we got an ARQ, and the date range included and it came back, and there was no data – part of that data, was, say, missing, there weren’t any transactions for certain dates, then I had queried the missing data and then was informed it’s gone past the date of deletion.
Mr Beer: I understand, I think. It continues in the third line of “Old Data”:
“… relating to Transactions, other than Banking Transactions meeting the Search Criteria.”
“Search criteria” is itself a defined term. If we go over the page, please, and scroll down:
“‘Search Criteria’ means:
“In the case of an Audit Record Query …”
You remember it distinguished earlier by saying audit record queries are not banking transaction record queries:
“‘Search criteria’ means …
“(a) Date or dates (not exceeding 31 consecutive days) Branch FAD and PAN (or equivalent identifier); or
“(b) Date or dates (not exceeding 31 consecutive days), and Branch FAD code; or in the absence of a FAD Code the full Branch Postal Address …”
So can you remember what a branch FAD or FAD code was?
Andrew Dunks: I don’t know what FAD stood for but it was the unique branch code.
Mr Beer: It was a unique identifier that related to an individual branch?
Andrew Dunks: Yes.
Mr Beer: Would it relate to an individual counter on the branch –
Andrew Dunks: No –
Mr Beer: – or the branch as a whole?
Andrew Dunks: – the branch as a whole.
Mr Beer: Thank you. PAN?
Andrew Dunks: PAN is the unique – I can never remember what it was. It’s in my witness statement. It was the unique number associated to, I believe, a credit card.
Mr Beer: A credit card?
Andrew Dunks: Yeah, a card used for payment.
Mr Beer: So was that one of the search criteria that you were provided with?
Andrew Dunks: Yes, I was, yes. Because within the ARQ, where it was asking for certain transactions for certain amounts, they would then ask for if it was there, for the PAN number to be supplied, as well.
Mr Beer: You think “PAN” might refer to a Primary Account Number –
Andrew Dunks: Yes, sorry, yeah.
Mr Beer: – rather than a credit card?
Andrew Dunks: Yes. I wouldn’t fully – yes. Yes, it was. We always associate it with a card number. I don’t know why.
Mr Beer: So the account number would be what, of the subpostmaster?
Andrew Dunks: No. I believe it’s the person who is making the payments –
Mr Beer: The customer?
Andrew Dunks: Yes.
Mr Beer: Okay. Does this section here, looking at the specification of what the search criteria should be, reflect your understanding of how ARQ data was extracted?
Andrew Dunks: Yes.
Mr Beer: You tell us in paragraph 12 of your witness statement that the person undertaking a search would log on and enter the parameters, you describe them as. Would the parameters be the search criteria here?
Andrew Dunks: Yes.
Mr Beer: Yes?
Andrew Dunks: Yes.
Mr Beer: Could audit data be extracted for a date period longer than 31 days?
Andrew Dunks: Yes, it could, but they would have been the split-up into individual ARQs. An ARQ would have been a month’s worth of data. So if they wanted two months of data, it would have been two ARQs.
Mr Beer: So if a search period exceeded a 31-day consecutive date period, that would count as a multiple request for the purposes of charging the Post Office?
Andrew Dunks: I believe so. As I say, I wasn’t aware of charging the Post Office. I just knew we were allowed – we had a set/finite number of ARQs to process so I wouldn’t have known how much one was or two was being charged. I didn’t believe that we were charging on an individual – I wasn’t aware we were charging on an individual basis. I think they were charged for the total and if they used that total or below that total, we were still being charged – or they were still being charged that set amount. That’s my belief.
Mr Beer: So if a single ARQ request came in seeking to extract data for a period of years, would that be chunked up by you into a series of ARQs, each for a 31-day period?
Andrew Dunks: We wouldn’t have chunked it up. The Post Office were aware that we only did that in 31 days so they would have supplied the ARQ numbers to represent the amount of days.
Mr Beer: So if ARQ data was sought for, say, a two-year period, Post Office would know that they would need to put in 24 ARQs?
Andrew Dunks: Yeah.
Mr Beer: Did that happen, that you would have ARQ requests for a considerable period of time, a number of years?
Andrew Dunks: Yes, that did happen, yes.
Mr Beer: How frequently did that happen? What was the typical period for which you were asked to extract data?
Andrew Dunks: (The witness laughed)
Mr Beer: Was it generally a period within a month or was it generally multiple months?
Andrew Dunks: It varied. It could have been two days or a day’s worth of data. It could have been two months, six months or a year. It varied each time.
Mr Beer: Can we look at page 13 and the table on it, please. This I think sets out the limits of queries, both ARQs and banking transactions, in successive tables. Can you see the way that the table is constructed? Along the top are the “Limits on Banking Transaction Record Queries”, and I think you said you weren’t aware of those coming in as a species on their own?
Andrew Dunks: I couldn’t remember those coming in as – no.
Mr Beer: Therefore, if we look on the right-hand side, “Limits on Audit Record Queries Carried out by Security and Risk for Post Office”, and the “Limit & Target Times”:
“Subject to [another paragraph], the limit per year … shall be the first of the following to be reached:
“720 [ARQs] consisting of Old or New Data or APOP Voucher Queries.”
Can you remember what APOP voucher queries were? It’s a defined term in the document. I just wanted to see whether –
Andrew Dunks: I don’t know what – I can’t remember what APOP stood for.
Mr Beer: Did you ever conduct such queries, so far as you can remember?
Andrew Dunks: I may have done. I can’t remember.
Mr Beer: In any event, 720 in a year or “15,000 Query Days”. Can you remember that approach, a query day? That’s a defined term meaning each date against which an audit record query is raised?
Andrew Dunks: I don’t remember that being a limit.
Mr Beer: Then:
“The limit per … month, allowing a ‘burst rate’ of 14% …”
Do you remember that, a discussion of a burst rate of 14 per cent?
Andrew Dunks: No.
Mr Beer: So:
“The limit per … month … shall be the first of …
“100 [ARQs], of which not more than 10 shall be APOP Voucher Queries or.
“2,100 Query Days subject to the constraints of the agreed annual limits above.”
Do you remember that?
Andrew Dunks: No.
Mr Beer: Did any of this that I’m showing you now affect the way you carried out your work?
Andrew Dunks: No.
Mr Beer: You just got a query in and you did it?
Andrew Dunks: Yes.
Mr Beer: Is that –
Andrew Dunks: Yes.
Mr Beer: – a fair way of describing it?
Andrew Dunks: Yes.
Mr Beer: Would you again see your role as an administrative one?
Andrew Dunks: Yes.
Mr Beer: The 720 sounds like something that you were familiar with because you mentioned it earlier?
Andrew Dunks: Yes.
Mr Beer: Did that ever change over time?
Andrew Dunks: I recalled it going up but I can’t recall what it went up to.
Mr Beer: What did you understand the purpose of the limitation to be?
Andrew Dunks: That’s what we were contracted to do. That was the limit.
Mr Beer: Did you understand it was about money, essentially?
Andrew Dunks: No, no, I didn’t. Well, yes, because that’s what they paid for, 720 queries so, yes, it was about money.
Mr Beer: So did you know that if they went above that, there would be additional money needed to change hands?
Andrew Dunks: I don’t recall because I wasn’t involved in any of those discussions at that level.
Mr Beer: Can we turn on, please, to page 15 of the document, and look at the bottom of the page, under paragraph 3.10.8, “Litigation Support”. Can we just read it together:
“Where Post Office submits an Audit Record Query or Old Format Query, at Post Office’s request Fujitsu Services shall, in addition to conducting that query:
“a) Present records of Transactions extracted by that query in either Excel 95, Excel 97 or native flat file format, as agreed between the parties …”
Does that ring a bell?
Andrew Dunks: The Excel does but not the native flat file format. I wouldn’t know what that was.
Mr Beer: So did the extractions always occur in Excel?
Andrew Dunks: That I recall, yes.
Mr Beer: Over the page, please:
“b) Subject to the limits below:
“Analyse:
“The appropriate Fujitsu Services Helpdesk records for the date range in question;
“Branch non-polling reports for the Branch in question; and
“Fault logs for the devices from which the records of Transactions were obtained.”
So the request that came in on the template document, would that specify which of these three things the Post Office wanted you to do?
Andrew Dunks: I only recall the first one, which was the helpdesk calls.
Mr Beer: Did you ever do the second or third things?
Andrew Dunks: Not that I remember, no.
Mr Beer: Would you know how to do the second and third things?
Andrew Dunks: No.
Mr Beer: So the template document, did that include these things, and they weren’t ticked or they were crossed through?
Andrew Dunks: I can’t remember, actually.
Mr Beer: So the request didn’t come in a batch lot, essentially saying, “Please do all of these things”?
Andrew Dunks: No.
Mr Beer: You were only ever asked to analyse the appropriate Fujitsu Services helpdesk records for the date range in question?
Andrew Dunks: No, it wouldn’t have said “analyse”, it would have said, “Please supply the helpdesk calls”.
Mr Beer: Well, there’s a difference between the supply of a record of something and an analysis of it, isn’t there?
Andrew Dunks: Yes.
Mr Beer: Where did you get the understanding from that your duty was limited to the supply of existing records, rather than the analysis of them?
Andrew Dunks: From our training that we had and from our management team.
Mr Beer: Who gave you the training? When was that given?
Andrew Dunks: For audit retrieval, it would have been the person who was running it at the time I joined the team.
Mr Beer: So the lady whose name you can’t remember –
Andrew Dunks: Yes, yes.
Mr Beer: – who gave you some on-the-job training?
Andrew Dunks: Yeah.
Mr Beer: You said your managers. Can you remember any conversations or discussions with them as to whether your job was just to supply the records of helpdesk calls or whether you needed to conduct an analysis of them, ie to set out what they showed, in your view?
Andrew Dunks: That wasn’t a request. That was never a request, unless it was a specific request from the Post Office Security Team.
Mr Beer: How would the Post Office Security Team make such a specific request?
Andrew Dunks: On the ARQ form.
Mr Beer: So when the Post Office Security Team made a specific request to analyse, that was identified on the form?
Andrew Dunks: No. Again, the form would have said, “Can you please supply”, I don’t know the exact wording but it was basically “Supply a list of all the helpdesk calls in that date range”.
Mr Beer: So did you never understand that it was your role to analyse the data that you were supplying?
Andrew Dunks: It wasn’t a specific role. But that’s something that I undertook later on when –
Mr Beer: Why did you undertake it later on?
Andrew Dunks: Because we had a request for a statement for analysis of those calls.
Mr Beer: So it was only when you were asked to provide a witness statement, did you analyse the data that you were providing?
Andrew Dunks: Correct.
Mr Beer: So does it follow that, save where there was actually a prosecution or civil proceedings afoot, ie it had got to that stage, the Post Office never asked you to analyse the data that you were providing to set out what it showed?
Andrew Dunks: Yes.
Mr Beer: What kind of litigation did you think the witness statements were being used for?
Andrew Dunks: Like I said earlier, it was for prosecutions.
Mr Beer: Did you know about civil proceedings?
Andrew Dunks: No, I didn’t – wouldn’t know what the difference was.
Mr Beer: If we carry on reading, the third thing under the heading “Litigation support”, if the Post Office submitted an ARQ then Fujitsu shall, in addition to conducting that query:
“c) In order to check the integrity of records of Transactions extracted by that query;
“Request and allow the relevant employees of Fujitsu Services to prepare witness statements of fact in relation to that query, to the extent that such statements are reasonably required for the purpose of verifying the integrity of records provided by Audit Record Query or Old Format Query, and are based upon the analysis and documentation referred to in this paragraph 3.10.8 …”
The contractual requirement or Fujitsu’s own description of it is, in some cases, to provide a witness statement of fact. When you were providing witness statements, did you understand the distinction between a witness statement of fact and a witness statement that provided opinion?
Andrew Dunks: Yes.
Mr Beer: Did you consciously limit your witness statements to statements of fact?
Andrew Dunks: Sorry, say that again?
Mr Beer: When you provided witness statements, did you consciously limit them to include only statements of fact?
Andrew Dunks: No, because I’d supplied two different types of witness statements.
Mr Beer: What were the two different types?
Andrew Dunks: One regarding ARQ data and one regarding helpdesk calls.
Mr Beer: For ARQ data was that a statement of fact?
Andrew Dunks: Yes, it was.
Mr Beer: Was that really producing records?
Andrew Dunks: Yes.
Mr Beer: For the other species of witness statement, did that include statements of opinion?
Andrew Dunks: Yes.
Mr Beer: When you were making those witness statements, you realised that you were doing something different from the first type of witness statement?
Andrew Dunks: I believe so, yes.
Mr Beer: Was that ever a discussion point between you and other people in the team or your managers?
Andrew Dunks: No, I don’t believe so, no.
Mr Beer: Now, speaking in general terms here at the moment, what differential level of analysis and investigation did you undertake when you were providing a witness statement that included opinion?
Andrew Dunks: Sorry, can you –
Mr Beer: Yes. What difference of approach did you have, if any, when you were providing a witness statement that included opinion?
Andrew Dunks: The different approach I would have taken was to fully understand the information that was listed and so I could make that judgement of opinion.
Mr Beer: What analysis would you therefore undertake when you were providing these statements of opinion?
Andrew Dunks: I would have looked at each – because these referred to individual calls to the helpdesk, so I would have analysed each of the calls on an individual basis, using what knowledge or tools I had to my – that were – that I could have.
Mr Beer: Did you ever speak to anyone when you were providing that opinion?
Andrew Dunks: Yes.
Mr Beer: Who would you speak to before you provided the opinion in the witness statements?
Andrew Dunks: To get a clear understanding of the call, I would either – if I didn’t need an opinion, and to my knowledge of the Horizon account I would have based that on my knowledge of the account, and the Horizon System – I would either – then if I – I would have spoken to a member of the team.
Mr Beer: Which team?
Andrew Dunks: The security operations team.
Mr Beer: Your colleagues in –
Andrew Dunks: The yes.
Mr Beer: – in the four or five growing to seven or eight?
Andrew Dunks: Yeah. I would have looked at the detail specifically for that helpdesk call or the text and everything contained within it, and I would – another option would be to speak to the SSC to gain their knowledge around what’s happening on the call.
Mr Beer: They were the people whose actions were recorded in the records of the helpdesk option?
Andrew Dunks: Yes.
Mr Beer: So you’d go back to the people whose documents you were looking at?
Andrew Dunks: Sorry?
Mr Beer: You’d go back to the SSC?
Andrew Dunks: Yes, I mean, most of the – I say most, I think all of the calls were dealt with by the SSC. So I would have spoken to them to get a clear understanding, so I could make my judgement on that particular call.
Mr Beer: Did anyone give you any instruction or guidance as to what you should include in your witness statement that reflected the background work that you undertook before you wrote the witness statement?
Andrew Dunks: Sorry, say that again, sorry?
Mr Beer: Yes. Did you receive any guidance or instruction about including in the witness statement a narrative of what investigatory work you had undertaken –
Andrew Dunks: No.
Mr Beer: – who you’d spoken to?
Andrew Dunks: No.
Mr Beer: So does it follow that you just decided to do what you thought you needed to do and that was best?
Andrew Dunks: Well, the –
Mr Beer: Because when we look at your witness statements, you’ll see that the thing that you’re describing is all dealt with in a single sentence, essentially –
Andrew Dunks: Yes.
Mr Beer: – and it’s pretty much the same sentence in each witness statement?
Andrew Dunks: What I would have based my witness statement – the first one that I actually did was – again, would have been a request of helpdesk calls logged from that branch. I would have then – which – where I was coming from was to enable the Post Office to understand what type of calls those calls were logged – that were logged involved and what type of call it was. And that’s what I was – my witness statement and the details were about.
Mr Beer: We will see in due course that you include a sentence in the witness statement when you’re dealing with the calls to the helpdesk along the lines of “None of these calls to the helpdesk relate to faults that would have had an effect on the integrity of the information held on the system”.
Andrew Dunks: Mm-hm.
Mr Beer: Something like that?
Andrew Dunks: Yes.
Mr Beer: Was that taken from your predecessors’ production of witness statements?
Andrew Dunks: I believe so, yes.
Mr Beer: So were you using a wording that had been sort of passed on, like some oral tradition, from one person to the next?
Andrew Dunks: Yes, there would have been a template to use.
Mr Beer: No one said to you, “When you say that kind of thing, you really need to say what work you’ve done to reach that opinion, who you’ve spoken to, what they’ve told you and the extent to which it affected your opinion”?
Andrew Dunks: No.
Mr Beer: You just thought, “So long as I am of that view, I can reprint the standard line”?
Andrew Dunks: Yes, because that’s what I believed at the time.
Mr Beer: You seem to have provided witness statements in many of the cases involving subpostmasters and many of the significant cases which this Inquiry is going to look at. Did you undertake more of this litigation support role than anyone else in the security team?
Andrew Dunks: No. That was really run – the litigation support side of it was run by a colleague, Penny Thomas.
Mr Beer: When you say the litigation support was run by Penny Thomas, what do you mean by “run”?
Andrew Dunks: She controlled or managed what went on.
Mr Beer: Was she a manager of you?
Andrew Dunks: No.
Mr Beer: Was she the same level or grade as you?
Andrew Dunks: Yes.
Mr Beer: So it was just her job function to manage?
Andrew Dunks: Yes.
Mr Beer: So how did it come about that you appear to have provided many witness statements involving significant cases that this Inquiry is looking at?
Andrew Dunks: I don’t know, actually. Because I believe I was running – doing ARQs before Penny joined the team and then the majority of ARQs – I wouldn’t say ARQs – anything to do with litigation would have been picked up by Penny Thomas.
Mr Beer: Was it just the pair of you that provided witness statements or was there anyone else in the team, to your recollection?
Andrew Dunks: I think it was just the two of us.
Mr Beer: Did you have any contact with anyone from the Post Office’s Legal Division about what it was permissible or impermissible to say in a witness statement?
Andrew Dunks: I had no contact like that at all, no.
Mr Beer: Were you aware of the Post Office making ARQ requests for the purposes of deciding whether or not to prosecute a subpostmaster in a criminal court?
Andrew Dunks: No.
Mr Beer: Were you aware that the Post Office was not requesting ARQ data prior to or when prosecuting some subpostmasters in relation to their shortfalls?
Andrew Dunks: Can you say –
Mr Beer: Yes, were you aware that they were proceeding with prosecutions without having first asked for ARQ data?
Andrew Dunks: No, I wasn’t aware.
Mr Beer: Were you aware of any discussions within your team about that?
Andrew Dunks: No.
Mr Beer: “They’re going ahead with prosecutions without having come to us first asking for ARQ data”?
Andrew Dunks: No, I would – no.
Mr Beer: Can we look at FUJ00095195. If we just look at the whole page first so we can capture Mr Simpson’s name and his signature block. Can you recall Alan Simpson, security incident senior in Post Office operations in Ashford?
Andrew Dunks: I remember – yeah, there was an Alan Simpson, yeah.
Mr Beer: What was your understanding of Mr Simpson’s role?
Andrew Dunks: That he worked in the Fujitsu – Fujitsu? – Post Office Security Team.
Mr Beer: Your team was described in some documents as the security team, was this different, then?
Andrew Dunks: I don’t know what – the workings or what their security team did.
Mr Beer: Anyway, he’s emailing you on 12 April 2010, under the subject “Monthly incident log for March 2010” and there’s attached a spreadsheet called “IncidentLog”, and says:
“Hi Andy,
“Attached is the incident log for last month.
“32 calls [and he gives the references]. I have tried to find closing details for as many as I can but the following funds are awaiting updates from Fujitsu …”
Then he sets them out, including:
“642 – Horizon alleged system integrity issues.”
Can you see that.
Andrew Dunks: Yes.
Mr Beer: He ends his list:
“Could you please chase these ones up and I will see you on Friday.”
Can you assist what Mr Simpson was asking you to do by following up these incidents?
Andrew Dunks: I can’t remember exactly what that was about.
Mr Beer: Was this a regular occurrence, an incident log for the previous month –
Andrew Dunks: I don’t –
Mr Beer: – sent to you by Excel spreadsheet?
Andrew Dunks: I don’t remember an incident log.
Mr Beer: He says that he’s going to come and see you. Was that a regular occurrence?
Andrew Dunks: I don’t remember meeting him.
Mr Beer: The mention of an alleged Horizon System integrity issue, do you remember those being raised with you?
Andrew Dunks: No. I mean, from this, I would take that he’s asking for updates on those particular calls. I wouldn’t have had any dealings with the calls. I think I would have gone and asked for an update with whoever is dealing with the call.
Mr Beer: Which area of your five roles is this concerned with, then? Which one of your five roles is this about?
Andrew Dunks: Erm … I don’t remember. As I say, I don’t remember this type of email or the email, so I don’t know which role that fitted in.
Mr Beer: But the calls would be from who to who? 32 calls, these are the reference numbers.
Andrew Dunks: The only calls that I remember were PEAK calls. So these could be referencing PEAK calls.
Mr Beer: In what respect would they need following up?
Andrew Dunks: They may have not actually been resolved yet.
Mr Beer: Why would it be your function to resolve them?
Andrew Dunks: Oh, I wouldn’t have resolved them; I would have chased up whoever is dealing with those calls. I would have asked for an update.
Mr Beer: Why was it your function to chase up unresolved PEAK calls?
Andrew Dunks: At the time I – no idea.
Mr Beer: Did you have access to PEAKs?
Andrew Dunks: Yes.
Mr Beer: Therefore, to take 642, if the description of this is correct, “system integrity issue” with Horizon, you’d be aware from being able to look at that call, that an issue had been raised about the integrity of the Horizon System?
Andrew Dunks: If I wanted to, yes.
Mr Beer: Would you want to?
Andrew Dunks: I hadn’t – I probably wouldn’t have had any need to. I would have probably passed this on to whoever – if they were PEAK calls, and they were being dealt with by the SSC, I would have put a chase on members or the SSC for an update on those calls.
Mr Beer: Why is somebody in security speaking to you when, and emailing you to chase up something that rests with the SSC?
Andrew Dunks: I think because we had a dialogue between – I don’t think he had access or contacts within – I’m only assuming here – but within the SSC.
Mr Beer: In your witness statement, you suggest that you had limited knowledge of the technical operation of Horizon –
Andrew Dunks: Yes.
Mr Beer: – and less still knowledge of any bugs errors or defects in the system?
Andrew Dunks: Mm-hm.
Mr Beer: Yes?
Andrew Dunks: Yeah.
Mr Beer: You explain in paragraph 19 that, aside from your limited role in the transaction reconciliation process, you had no role in the investigation of errors reported by the system or by system users?
Andrew Dunks: Correct.
Mr Beer: You explain that you didn’t work in the helpdesk and had no role within it, yes?
Andrew Dunks: Yes.
Mr Beer: You say that on occasion you were requested to provide the Post Office with records of calls made by the helpdesk by a particular Post Office branch and, if requested, to summarise these in witness statements? That’s paragraph 20 of your witness statement; is that right?
Andrew Dunks: That’s correct.
Mr Beer: Was your role a purely procedural, administrative or mechanical one, therefore?
Andrew Dunks: Mm-hm.
Mr Beer: You describe in that paragraph that your role, if requested, was to summarise the calls in a witness statement. Our discussion earlier suggests that you went further than that: that you analysed the calls and offered an opinion about the calls; is that fair?
Andrew Dunks: Yes.
Mr Beer: Why in paragraph 20 of your witness statement did you say that your role was to summarise?
Andrew Dunks: Well, that – to summarise – my understanding is to summarise the calls and – but part of the witness statement is the wording of the witness statement. The summarisation is of the calls, not the wording of the witness statement.
Mr Beer: Can I try and understand what you mean there. You said that, if you were just asked to provide ARQ data and nothing more, you wouldn’t analyse it, you would just provide it?
Andrew Dunks: Yes.
Mr Beer: If you were asked, however, to provide a witness statement, you would analyse it?
Andrew Dunks: If the witness statement – no – I’d analyse the helpdesk calls.
Mr Beer: Yes.
Andrew Dunks: Yes.
Mr Beer: And you would offer an opinion about it, you agreed earlier.
Andrew Dunks: Yes.
Mr Beer: That’s different from providing summary of it, isn’t it?
Andrew Dunks: Not that I understand, no. The summary would have been an overview of each call.
Mr Beer: But you went further than that, didn’t you?
Andrew Dunks: Yeah, based on that summary, I made a statement.
Mr Beer: Were you trying to minimise your role, in this paragraph?
Andrew Dunks: No, not at all.
Mr Beer: Were you trying to paint the picture in the witness statement that your role was a purely procedural, administrative or mechanical one?
Andrew Dunks: Not really, no.
Mr Beer: Do you believe that you had the qualifications, experience and technical understanding to offer an opinion as to whether issues raised in helpdesk calls that you were analysing went to the integrity of the Horizon System?
Andrew Dunks: Based on my investigation or using due diligence for each call, I would have based my – that statement on my knowledge and understanding.
Mr Beer: What was the due diligence that you conducted?
Andrew Dunks: As I think I said earlier, it would have been my current knowledge of Horizon, speaking to members of the security team, looking at the PEAK itself and going through the PEAK and the wording and what was done to resolve that PEAK and, if needed, I would have spoken to a member of the SSC to clarify what was going on.
Mr Beer: But you wouldn’t maintain a record of all of those things that you did?
Andrew Dunks: No.
Mr Beer: You wouldn’t explain them in the witness statement itself?
Andrew Dunks: No.
Mr Beer: So the reader wouldn’t know what background work or homework you’d undertaken in order to offer the opinion that you were offering?
Andrew Dunks: No.
Mr Beer: Did you ever feel uncomfortable about doing this?
Andrew Dunks: No, I didn’t, no, because I believed at the time – when I wrote that statement, I believed the wording and I was happy. I wouldn’t have signed it, otherwise.
Mr Beer: Can we look, please, at FUJ00080215. Can we see the date of this document at the foot of the page, please. 14 June 2011 and it’s version 2. Then look at the top of the page, the title of the document, “Reconciliation and Incident Management Joint Working Document”.
The abstract describes the document as a:
“Joint Working Document to support the Reconciliation Service provided to Post Office Limited by Fujitsu Services.”
We can see the author is Penny Thomas who you’ve described and the distribution includes you. Can you see under the internal distribution?
Andrew Dunks: Yeah.
Mr Beer: Were you part of the team who provided this service, reconciliation and incident management?
Andrew Dunks: I don’t remember the incident management side of it but we were – I was a member of the security operations team that took on the reconciliation role.
Mr Beer: So you do remember providing reconciliation services –
Andrew Dunks: Correct.
Mr Beer: – but not incident management; is that right?
Andrew Dunks: Yeah, I think so, yes.
Mr Beer: If we look, please, at page 9 of the document, a description of what reconciliation is:
“End-to-end Reconciliation within [Horizon Online] is the mechanism by which [Post Office] and Post Office Account … establish which transactions are complete and correct, and which are not. An incomplete transaction is not necessarily a Reconciliation error, but it might become one if it is not completed in a timely manner. An incorrect transaction is a Reconciliation error.”
Does that fairly describe what you understood reconciliation to be?
Andrew Dunks: Correct.
Mr Beer: “Each and every reconciliation error is the result of some system fault. That might, for example, be a software bug (introduced through either design or coding), a system crash, or a telephone line being dug up. Such faults may affect transactions, thus it is the job of Reconciliation Service to detect when and how any transaction is affected by any system fault.”
Andrew Dunks: Yes.
Mr Beer: Does that fairly describe the nature of the bugs, crashes or other faults that might require a reconciliation to occur?
Andrew Dunks: Yes.
Mr Beer: When did you first become involved in reconciliation?
Andrew Dunks: No idea when we started doing that.
Mr Beer: Was there an equivalent service for Legacy Horizon?
Andrew Dunks: I’ve no idea.
Mr Beer: Or can you recall was it only established in order to support Horizon Online?
Andrew Dunks: I have no idea.
Mr Beer: From at least this time onwards then, from at least 2011, you would have been aware that bugs, errors and defects could cause imbalances within the subpostmaster accounts, discrepancies, yes?
Andrew Dunks: I wasn’t aware that bugs and errors caused reconciliation.
Mr Beer: This says, the fault might be “a software bug”.
Andrew Dunks: Yes.
Mr Beer: Why wouldn’t you be aware that a software bug could cause a reconciliation error?
Andrew Dunks: Reading this, and I don’t remember this document – and if I’d read this at the time, yes, I would have known that a bug would have – may have caused a reconciliation error.
Mr Beer: Did you read documents that were sent to you?
Andrew Dunks: Not every document.
Mr Beer: Why not?
Andrew Dunks: Because they were really – they were aimed at a certain distribution list and we would receive documents to review, loads of documents to review, and not any of them – not all of them would have been relevant to our role.
Mr Beer: Why were you being sent a document that wasn’t relevant to you?
Andrew Dunks: Because sometimes there’s a scatter-gun approach on documentation.
Mr Beer: So this document that records that reconciliation errors might be the fault of Horizon software bugs is one that didn’t make it into your conscience; is that right?
Andrew Dunks: I may have read this. I don’t remember.
Mr Beer: Were you aware that software bugs within Horizon might cause reconciliation errors?
Andrew Dunks: I don’t recall. I don’t know.
Mr Beer: When you were carrying out the task of reconciliation, did you ever think “Hold on, it might be a software bug that’s causing the error, we’d better look at that”?
Andrew Dunks: No.
Mr Beer: So, so far as you were aware, you worked on the basis that Horizon had such integrity that no bugs within it, either introduced through design or coding errors, could cause reconciliation errors; is that right?
Andrew Dunks: To an extent, yes, because the reconciliation within the team was a process and it didn’t involve the investigative side of that transaction or an incomplete that needed reconciliation.
Mr Beer: Was your view a commonly held one amongst your team, do you think, that reconciliation errors are not caused or could not be caused by Horizon software bugs?
Andrew Dunks: I honestly couldn’t tell you.
Mr Beer: Well, had you ever had a discussion with other members of the team “We’ve got a reconciliation error here, let’s think of the possible causes of it. Is it due to a telephone line being dug up, is it due to a system crash or a power failure or is it due to a software bug? We’d better look at these alternatives”?
Andrew Dunks: No, that wasn’t part of the remit within the reconciliation team.
Mr Beer: Whose job was that?
Andrew Dunks: The SSC.
Mr Beer: It was their job to investigate, on your understanding –
Andrew Dunks: Yes.
Mr Beer: – the causes of the reconciliation error?
Andrew Dunks: Yeah.
Mr Beer: Did you ever read documents from the SSC that revealed that they considered that a software bug within Horizon might be the cause of a reconciliation error?
Andrew Dunks: I don’t recall, no.
Mr Beer: Can we look, please, at POL00039193. This is a record of an investigation report concerning a complaint made by Mr Thomas – give me a moment to catch up in my papers – as part of the Complaint Review and Mediation Scheme. Within it, if we just look at page 4 of the document, please, in the second box down, in the third paragraph, it is recorded that:
“… a witness statement provided by Andy Dunks of Fujitsu dated 6th April 2006 for the purposes of the criminal proceedings … states that during the period 1st November 2004-30th November 2005, he [that’s you] reviewed 13 calls made to the [Horizon Service Desk] from the Gaerwen Post Office Network. His professional opinion was that ‘none of these calls related to faults which would have had an effect on the integrity of the information held on the system’.”
I’m dealing with things at a relatively high level at the moment. In the future we’ll come back and look at the detail here. That sentence, “none of these related to faults which have had an effect on the integrity of the information held on the system”, that was the standard line that we were talking about earlier?
Andrew Dunks: Mm-hm.
Mr Beer: Was that the line you took from your predecessors’ witness statements?
Andrew Dunks: I believe so. I can’t recall.
Mr Beer: We know that, in relation to the ARQ data obtained in relation to Mr Thomas’s case, that it was a dip sample only, that it was checked only for evidence of zero transactions and that the data was not checked for any bugs, errors or defects. Was that a common approach, that you would dip sample?
Andrew Dunks: I have got no idea what a “dip sample” was.
Mr Beer: So you would look at a period only, rather than the entirety of, for example, the period over which the subpostmaster was accused of theft and false accounting?
Andrew Dunks: We would only have looked – I would only have looked at what was requested from the Post Office.
Mr Beer: In the witness statement you provided to the Inquiry, you have suggested that you had limited technical knowledge of the operation of Horizon and of any bugs, errors or defects within it.
Andrew Dunks: Mm-hm.
Mr Beer: How would you go about satisfying yourself that none of the calls in this case related to faults which would have had an effect on the integrity of the information held on the system?
Andrew Dunks: I would have done – as I said before, I would have conducted my own due diligence of an investigation of that – each and every call, within its own merits.
Mr Beer: Did you intend, by making a statement that included a line such as that, to convey the impression that you had conducted an analysis of information exchanged in the calls and concluded that there was no question of any error, bug or defect within Horizon?
Andrew Dunks: I’m not quite sure what you’re asking.
Mr Beer: To a person that’s not familiar with the nature of the role that you were, in fact, performing, that statement – “None of these calls related to faults which would have had an effect on the integrity of the information held on the system” – might give the impression that you had conducted an analysis of the information exchanged in the calls and reached the view that, of the things mentioned, there could be no question of errors, bugs or defects within Horizon.
Andrew Dunks: I still don’t really understand the question.
Mr Beer: Well, let’s take – let’s look at it a different way. Can we turn up POL00003219.
It can’t be displayed. That would have been a document setting out the number of occasions on which you provided witness statements or cases for a period between August 2004 and March 2005. How frequently do you think you provided witness statements?
Andrew Dunks: Hazarding a guess, it may have been one a month, one every two months. From my recollection, it was very, very infrequent.
Mr Beer: Who else was providing witness statements?
Andrew Dunks: The only person that I can recall would have been Penny Thomas. I don’t know, prior to that – or the person before me running ARQs – whether they did.
Mr Beer: When you made the witness statement, did you anticipate being required to attend court?
Andrew Dunks: No, I didn’t.
Mr Beer: Were you ever called to court?
Andrew Dunks: Yes, I was.
Mr Beer: On how many occasions?
Andrew Dunks: Again, I can’t remember. Half a dozen times?
Mr Beer: Were they spread around the country?
Andrew Dunks: Yeah. I can’t remember every one.
Mr Beer: So about half a dozen, you think?
Andrew Dunks: Yeah, I think so, yes.
Mr Beer: Did you engage with those that were conducting the prosecution, people from Post Office Legal, before you gave evidence?
Andrew Dunks: I don’t believe that – I can’t recall. I’m not saying – I may have met them before at the case – at the court itself, but I don’t recall that happening.
Mr Beer: Were you given any advice or assistance on the proper limits of the evidence that you could give, whether you in particular were a witness of fact who was producing documents or an expert witness statement who was analysing what the documents showed?
Andrew Dunks: I wasn’t told the limits of what I could give evidence-wise, no. My understanding was I was there to elaborate my witness statement, to be true.
Mr Beer: Can we look, please, at POL00073280. This is an exhibit sheet to your witness statement prepared in the case of Post Office v Lee Castleton, a civil claim. Can you see that?
Andrew Dunks: Yes, I can.
Mr Beer: Dated 27 September 2006.
Andrew Dunks: Mm-hm.
Mr Beer: It’s your exhibit AD1.
Andrew Dunks: Yeah.
Mr Beer: If we just go over the page, please, and just expand it, thank you. This a call log, isn’t it?
Andrew Dunks: Yes, it is.
Mr Beer: If you just keep skipping, please, Frankie, and keep going. There is a series of call logs, yes?
Andrew Dunks: Mm-hm.
Mr Beer: Was it your practice always to exhibit the call logs in this way when you provided a witness statement for the purposes of legal proceedings?
Andrew Dunks: I can’t remember. I can’t actually remember supplying the witness statement, that witness statement, with that call log in it.
Mr Beer: Can we look, please, at FUJ00083726. This is a summary of call logs prepared for the purposes of Jerry Hosi’s prosecution. If we just expand it so we can see the whole page. You can see there’s a breakdown at the top, and then:
“Call reference details and an overview of each call is given in date order below.”
Then an example is given, that the reference, who the call was taken by, the resolution and the outcome. Then if we go over the page, please, there’s another one and another one and another one?
Andrew Dunks: Yeah.
Mr Beer: Was it your practice, again, always to exhibit the call logs as we’ve seen in the civil proceedings of Mr Castleton or to provide a summary analysis of the call logs, as we can see for Mr Hosi’s – sorry, Jerry Hosi’s prosecution?
Andrew Dunks: What, you’re asking whether that – it was standard? I would have supplied exactly what I was asked for from the Post Office.
Mr Beer: When you were trying the witness statement, what was your understanding of what you needed to do for the witness statement?
Andrew Dunks: Again, the instruction from the Post Office. If they’d asked for a breakdown of the calls that were logged.
Mr Beer: Did you understand that you also needed to exhibit them, produce them?
Andrew Dunks: I don’t recall that, no.
Mr Beer: That can come down, thank you.
Did you know anything about the contractual obligations placed on Fujitsu as to the provision of evidence and data that was compliant with a legal standard –
Andrew Dunks: No, I wasn’t aware of that, no.
Mr Beer: – that if the contract existed as between Post Office and Fujitsu, which said when Fujitsu provides information for the purposes of a criminal prosecution, it’s got to hit this mark, it’s got to reach this standard?
Andrew Dunks: No, I never – I wasn’t aware of anything like that.
Mr Beer: Were you provided with any training in relation to this is aspect of your role, the provision of evidence in court proceedings against subpostmasters and your obligations and duties to the court?
Andrew Dunks: There was no trading on the production of witness statements. They were quite – it’s quite straightforward to understand what was required. There was no specific training for attending court either. So …
Mr Beer: I think that’s a no.
Andrew Dunks: Yeah, if that answers your question, yes. Yeah.
Mr Beer: I’m thinking about somebody who provides opinion evidence, analysis evidence –
Andrew Dunks: Mm-hm.
Mr Beer: – the steps that they ought to take to satisfy themselves as to the accuracy of what they’re saying and also describing within their evidence the steps that they have been taking. Was there any training or instruction or guidance or help on those issues?
Andrew Dunks: No. No. I would have used the standard template as before, for producing the witness statements.
Mr Beer: In all of the prosecutions where you gave evidence against subpostmasters, did the template always say the same thing, “There’s nothing in the documents I have looked at that would affect the integrity of the data”?
Andrew Dunks: No, they did vary over time.
Mr Beer: Did any of them say that the faults that were being reported did have an effect on the integrity of the information held on the system?
Andrew Dunks: No.
Mr Beer: They always said that it didn’t?
Andrew Dunks: Correct, yes.
Mr Beer: Did you ever disclose anything about the ability of Fujitsu staff, including in the third line of support, remotely to access Horizon terminals without the knowledge of subpostmasters?
Andrew Dunks: Did I what with that information?
Mr Beer: Did you ever give any evidence about that?
Andrew Dunks: Evidence in court?
Mr Beer: Yes.
Andrew Dunks: No.
Mr Beer: Evidence in witness statements?
Andrew Dunks: No.
Mr Beer: Did it ever occur to you that that might affect the ability – or that might affect the ability to say that “There’s nothing in the information I’ve looked at that would affect the integrity of information held within the system”?
Andrew Dunks: No, not at all.
Mr Beer: The fact that there are people in Fujitsu who have access, and can change data at the terminal end, without the subpostmaster’s knowledge?
Andrew Dunks: I wasn’t aware that was possible.
Mr Beer: Was that ever a topic of discussion?
Andrew Dunks: No.
Mr Beer: Can I turn back to the transaction reconciliation process. Can we look, please, at FUJ00080215. Can we look at page 9, please. We’ve looked at the first and second paragraphs under paragraph 1.1, yes?
Andrew Dunks: Mm-hm.
Mr Beer: We looked at those a moment ago. Was it your understanding that errors created as a result of software bugs were identified by the system itself?
Andrew Dunks: Was I what, sorry?
Mr Beer: Were you aware that any reconciliation errors caused as a result of software bugs –
Andrew Dunks: No, I wasn’t.
Mr Beer: That follows because you weren’t aware of any software bugs, or the possibility of software bugs; is that right?
Andrew Dunks: No, sorry, I was aware of software bugs within the Horizon System, but not all of those, or any of them that I am aware of, were the result of a reconciliation error. I was not – did not believe, or was aware that any of those bugs caused reconciliation issues.
Mr Beer: What were the causes of reconciliation errors, then, if they never included software bugs?
Andrew Dunks: Reconciliation – a reconciliation error is the breakdown of the transaction somewhere along the line. So it hadn’t been completed, and that’s what we dealt with.
Mr Beer: All of these were faults caused by the system, weren’t they?
Andrew Dunks: No, no.
Mr Beer: Not by the sub –
Andrew Dunks: No they weren’t, no. Because I think it said before, it could have been caused by a power outage or a loss of connectivity to the branch. These were the main causes that I was aware of, of reconciliation issues.
Mr Beer: So looking at that second paragraph again, under 1.1, where it says, “Each and every reconciliation error is the result of some system fault”, and then three examples are given: a software bug introduced through either design or coding; the second one is a system crash; and the third one is a telephone line being dug up, you’re only aware of the second and the third them; is that right?
Andrew Dunks: Yes, I don’t recall any reconciliation issues that resulted – or the resolution was to do with a software bug.
Mr Beer: So in the decade or more that you were performing this function, did you never hear any discussion that there might be something wrong with the system itself, by way of coding or design error?
Andrew Dunks: No.
Mr Beer: It was never mentioned?
Andrew Dunks: No, not – no.
Mr Beer: Did you see the same problem coming back to you time and time again for a transaction correction to be made?
Andrew Dunks: For a reconciliation?
Mr Beer: Yes.
Andrew Dunks: Yes, yeah. The most common – there were a number of common reasons.
Mr Beer: What were the common reasons?
Andrew Dunks: The common reasons were loss of connectivity to the branch.
Mr Beer: Do you remember a Computer Weekly article being discussed in 2009 onwards?
Andrew Dunks: No. I never read Computer Weekly.
Mr Beer: I’m not suggesting you read it; I’m asking whether you remember it being discussed within Fujitsu?
Andrew Dunks: No, no.
Mr Beer: Do you remember a campaign starting from about 2009 onwards?
Andrew Dunks: Yes, I was aware of something going on, yes.
Mr Beer: What was the something you were aware of going on?
Andrew Dunks: Erm … it would have been a postmaster’s – how do you say it? – were appealing or saying that they weren’t at fault for the losses, and it was –
Mr Beer: What were they saying was at fault?
Andrew Dunks: The Fujit – the Horizon System.
Mr Beer: What was the discussion in the office about what they were saying?
Andrew Dunks: I honestly can’t remember if there was a discussion at all about it. I was aware of it through probably press or whatever, but I don’t recall having a conversation with anybody about it. Not – I’m not saying I didn’t, but I don’t recall one.
Mr Beer: You were producing witness statements to courts?
Andrew Dunks: Mm-hm.
Mr Beer: Around the country?
Andrew Dunks: Mm-hm.
Mr Beer: Saying, “I’ve analysed the records of calls by these very same subpostmasters to the helpdesk”?
Andrew Dunks: Yeah.
Mr Beer: Saying that, “On occasion, there’s an imbalance or a discrepancy which I cannot explain. I believe it’s the fault of the Horizon System”.
Was there no discussion in the office: “Well, hold on, is anyone looking into this?”
Andrew Dunks: No.
Mr Beer: You just carried on providing the witness statements?
Andrew Dunks: In my – our area of the team, no, I don’t think we did discuss it at all.
Mr Beer: Looking back, do you think it ought to have been the topic of some discussion?
Andrew Dunks: At a higher level, possibly. Whether that went on, I don’t know. It wasn’t for us to discuss or make judgement.
Mr Beer: You were the one that was going along to court or providing witness statements?
Andrew Dunks: Yeah.
Mr Beer: It was your name at the bottom of the piece of paper that was signed?
Andrew Dunks: Mm-hm.
Mr Beer: Saying, “This is true”?
Andrew Dunks: Mm-hm.
Mr Beer: “I know I can be prosecuted”, I think it would have said.
Andrew Dunks: Mm-hm.
Mr Beer: “… if I have stated in it anything which I know to be false.”
Andrew Dunks: Yes.
Mr Beer: Did you not think that was quite a serious undertaking you were engaged in?
Andrew Dunks: Yes, I did.
Mr Beer: You heard, through the media and the like, that the subpostmasters were saying, “There were faults in the system, the Horizon System, that are causing discrepancies for which I am not responsible.”
You were providing witness statements at the same time, saying, “There is nothing that I’ve seen in the documents I’ve examined that could explain a system-generated discrepancy”?
Andrew Dunks: Well, as you just stated, I would have probably taken it as it’s their opinion that there’s something wrong. I’m not – wasn’t aware there was something wrong, so I still believed my statement, on the witness statements I gave, were true at the time.
Mr Beer: Can we look, please, at FUJ00086882. Can we just go to the last page, please, and scroll up. Thank you. It’s an email chain to which you were copied; can you see that?
Andrew Dunks: Yes.
Mr Beer: Of 26 January 2010. Ernst & Young. Who did you understand Ernst & Young to be?
Andrew Dunks: Auditors.
Mr Beer: “They’re in the process of auditing the Royal Mail Group financial systems. Part of the audit includes systems that are managed by Fujitsu on behalf of the Royal Mail Group, particularly the Horizon and Credence POLMI systems.”
When did you read that, did you think: hold on, that’s talking about Credence – I don’t know what Credence is?
Andrew Dunks: No, I don’t remember thinking that, no.
Mr Beer: Anyway:
“One area of the audit concerns user access, and whether an individual should have continued access. Ernst & Young have identified a sample of users based on the existence of the user in the ACE Server Database.”
Do you remember what the ACE Server Database was?
Andrew Dunks: No, I don’t.
Mr Beer: “… and are requesting that confirmation – the user still requires access to Horizon’s own Credence. Each of you have been identified as the line manager for an individual or individuals excluded within the sample. Each user has access to the system since January 2009. Can you please confirm if the users associated with your name are still employed by Fujitsu and if they require access to Royal Mail Group systems as part of their job role.”
Then, please, if we go on to FUJ00086945 and scroll forwards. This document is a 2011 production by Ernst & Young which raises issues about access to, and integrity of, the Credence system. Can you remember getting this document?
Andrew Dunks: No, I don’t remember seeing this document.
Mr Beer: Can you remember, by reference to the previous email and to this document, whether concerns were raised by the auditors over the integrity of the system and access to it?
Andrew Dunks: No, I wasn’t made aware.
Mr Beer: That can come down; thank you.
You were somebody who was responsible for the cryptographic keys?
Andrew Dunks: Mm-hm.
Mr Beer: And that was for the subpostmasters?
Andrew Dunks: The counters.
Mr Beer: Yes.
Andrew Dunks: Yes.
Mr Beer: Did part of your role involve consideration of who was able to access, within Fujitsu, the Horizon System?
Andrew Dunks: No, it wasn’t.
Mr Beer: Was that the responsibility of anyone within your team?
Andrew Dunks: No, not that I believe so, no.
Mr Beer: Were you responsible, at a mechanical level, for granting or removing access, as instructed, of Fujitsu employees?
Andrew Dunks: Not on a mechanical level. I wouldn’t – we wouldn’t be – we wouldn’t administer the physical change.
Mr Beer: Was that not a function of anyone within your team?
Andrew Dunks: No.
Mr Beer: Can we look, please, at FUJ00083703. Can you see this is a witness statement signed by you?
Andrew Dunks: Mm-hm.
Mr Beer: Just if we expand it a little bit, please, and just scroll over the page and over the page and over the page. Over the page. Thank you. Keep going. Keep going. Keep going – and again and again. Just keep going, and that’s the end.
So back to the beginning, please. You’ll see this was a witness statement of the species that provided summaries.
Andrew Dunks: Mm-hm.
Mr Beer: – of call logs.
Andrew Dunks: Yes.
Mr Beer: Was that the normal way in which you did things?
Andrew Dunks: There was no normal way, because it depended on what the request from the Post Office was.
Mr Beer: Would the Post Office specify “We want you, in your witness statement, either to (or not to) exhibit call logs”?
Andrew Dunks: I can’t remember specifically how it was requested.
Mr Beer: Or would they just ask you to provide a witness statement?
Andrew Dunks: Erm … I can’t remember, actually.
Mr Beer: Can you try and help us how you went about your task of deciding whether to summarise records of calls, the helpdesk calls, or whether you exhibited them?
Andrew Dunks: When you say “exhibited them”, as in on the witness statement?
Mr Beer: Attach them, like we saw in the Castleton case?
Andrew Dunks: Yeah, whether that was a request from the Post Office or not, I can’t remember the process of how I was asked to exhibit them, or I vaguely remember them saying, “Can we have a list of calls”, or how many there were. And they may, I think, may have come back to me saying, “Oh, can you expand on this?” I really cannot remember how that process worked.
Mr Beer: If we just look through your witness statement, please, in this case. This is for the Porters Avenue branch, Mr Jerry Hosi’s case. Can we see that it’s dated 3 June 2008, and you say:
“I have been employed by Fujitsu on the Post Office Account since 11th March 2002 as an IT security analyst …”
Is that an accurate, short description of your job, a “security analyst”?
Andrew Dunks: It was the title we had. I believe everybody within that team was called an IT security analyst.
Mr Beer: Does it accurately describe your job that you’re –
Andrew Dunks: Analyst? No.
Mr Beer: Why were you called something that didn’t accurately describe what you did?
Andrew Dunks: That was the job title.
Mr Beer: An analyst might be understood to be somebody with technical expertise who would undertake a qualitative assessment of data, mightn’t they?
Andrew Dunks: Could be.
Mr Beer: How would you describe your job, shortly, if you were to provide a job description that wasn’t an IT security analyst?
Andrew Dunks: It’s difficult to put it in words, because although we were classed as an IT security team, a lot of the roles and jobs that we did didn’t really fall into IT security. So it was a hard one to describe our role.
Mr Beer: The way you describe it in your witness statement provided to us for this Inquiry, you might describe yourself as an administrator? Or is that being unfair to you?
Andrew Dunks: No, it’s more than that. The role involved a lot of administrative and procedural work, but there was more to it than that, at times.
Mr Beer: In any event, you say:
“I’ve a working knowledge of the computer system known as Horizon.”
How did you gain that working knowledge?
Andrew Dunks: Through experience of working on the account, and furthered by speaking to – having conversations, and my interaction with other account members, the SSC, support teams.
Mr Beer: Did you ever undergo the training that subpostmasters underwent on the operation of the system?
Andrew Dunks: I did once, I think many years ago. I can’t remember the date. I think Penny and I went and did a half day or a day’s course, and I can’t remember where that was.
Mr Beer: You continue:
“I’m authorised by Fujitsu to undertake extractions of audit data held on the Horizon System …”
Why was it called audit data? Wasn’t it just data?
Andrew Dunks: I don’t know why it was called audit data.
Mr Beer: Why did you call it audit data?
Andrew Dunks: Because that’s what it was referred to as. It was the audit system, so it’s audit data.
Mr Beer: “… and to obtain information regarding system transaction information processed on the Horizon System.
“I make this witness statement from facts within my own knowledge unless otherwise stated.”
In the witness statement, do you state otherwise, ie that you have made it from information that’s not within your knowledge?
Andrew Dunks: No, because when I made the statement, my knowledge was enough to make that statement.
Mr Beer: So for the purpose of making this witness statement, you didn’t speak to anyone else?
Andrew Dunks: No, I probably did.
Mr Beer: That line suggests that when you go through what you’re about to say, you’re going to identify if you have spoken to anyone else, or have obtained information from anyone else?
Andrew Dunks: Mm-hm.
Mr Beer: Ie matters that are not within your own knowledge.
In the pages of the statement that follow, the 13 pages of it, take it from me, you don’t identify that you’ve spoken to anyone else.
Andrew Dunks: But within my due diligence, my knowledge I’d undertook for each call, my knowledge was then suffice to make this statement.
Mr Beer: You continue:
“Any records to which I refer in my statement form part of the records relating to the business of Fujitsu. These were compiled during the ordinary course of business from information supplied by persons who have or may reasonably be supposed to have personal knowledge of the matter dealt with in the information supplied, but are unlikely to have any recollection of the information or cannot be traced, since the nature of the Helpdesk involves many engineers at, all at differing levels, and any number could be involved in a particular call. As part of my duties I have access to these records but I was not involved with any of the technical expects of these calls. This area is not my particular area of expertise and I make this statement simply to help clarify the call logs for the benefit of the court.”
Was that paragraph essentially standard wording?
Andrew Dunks: Yes.
Mr Beer: From where did you obtain it?
Andrew Dunks: From the standard witness statement, or previous witness statements.
Mr Beer: From your predecessor?
Andrew Dunks: Yes.
Mr Beer: You continue at the foot of the page:
“An important element of the support provided to subpostmasters and counter clerks is the Horizon System Helpdesk (HSH). The HSH is the Horizon user’s first ‘port of call’ in the event of their experiencing a problem with the Horizon System or requiring advice and guidance. If the system were to malfunction, upon discovery the Horizon users (ie the subpostmaster or counter clerk) would raise a call to the HSH seeking clarification or advice. HSH is a service run by Fujitsu or the Post Office. I have been asked to provide details and information on the calls for advice and guidance logged by HSH recorded during the period 1/9/05-29/11/06 for the Porters Ave branch. A report outlining each call was created and I produce the resultant CD as exhibit APD/01. This CD was sent to the Post Office investigation section by Special Delivery on 19th February 2007.”
Then this:
“I have reviewed the HSH calls pertaining to the Porters Ave branch during the period. There were 33 calls from the branch to HSH and all the calls are of a routine nature and do not fall outside the normal working parameters of the system and in my opinion would have had no effect on any counter discrepancies.”
What does “routine nature” and “do not fall outside the normal working parameters of the system” mean?
Andrew Dunks: My understanding of that statement is they weren’t extraordinary calls. A lot of the calls were of a routine – it says “routine”, I keep saying routine – was expected, or common faults or common calls to the helpdesk.
Mr Beer: So you would describe calls of a routine nature, meaning ones that were made frequently?
Andrew Dunks: Yes.
Mr Beer: What about the substance of the call? If the subpostmaster was saying, “There is a discrepancy for which the system is responsible that I cannot explain”, and a number of them were saying that, time and time again? Would that be a routine call or a call of a routine nature?
Andrew Dunks: I don’t recall seeing calls that said that that I had a look at, but you could call them a routine call, yes.
Mr Beer: You continue:
“In my opinion, it would have had no effect on any counter discrepancies.”
What steps would you take to satisfy yourself that the substance of the calls would have had no effect on any counter discrepancies?
Andrew Dunks: I would have based that statement on my due diligence and the steps I had mentioned earlier.
Mr Beer: Looking back now, do you think you were technically qualified to make that statement?
Andrew Dunks: Yes, I do.
Mr Beer: Why?
Andrew Dunks: Because I’d gained enough knowledge of those particular calls from the appropriate people to satisfy myself that – to make that statement.
Mr Beer: Sir, that’s all I’ll ask for the moment. Thank you. We have reached 1.00. There is in fact still more for me to do, but maybe we can do that on a future occasion.
Sir Wyn Williams: Yes. I think that’s probably right, Mr Beer.
Mr Dunks, it’s inevitable, I think, that you will be asked to return to give further evidence.
The Witness: Yes.
Sir Wyn Williams: There may be many more questions to come. So you’ll be notified in due course when that will be, and you will be given, I hope, significant notice of that, so that it doesn’t disrupt your life unduly.
All right, we’ll break off until tomorrow now.
Mr Beer: 10.00 tomorrow, sir. Thank you very much.
(1.01 pm)
(The hearing adjourned until 10.00 am the following day)