FUJ00083683 - Witness statement of Andrew Paul Dunks - V 4.0 (unsigned)

Evidence on official site

FUJ00083683
FUJ00083683

Witness Statement

(CJ Act 1967, s9; MC Act 1980, ss 54(3)(a)
and 5B, MC Rules 1981, r 70)

Statement of Andrew Paul Dunks

Age if under 18 over 18 (If over 18 insert 'over 18')

This statement (consisting of 13 pages each signed by me) is true to the best of my
knowledge and belief and I make it knowing that, if it is tendered in evidence, I shall be liable
to prosecution if I have wilfully stated in it anything which I know to be false or do not believe
true.

Dated the 24th dayof July 2007

Signature

I have been employed by Fujitsu Services (Fujitsu), Post Office Account, since 11 March 2002
as an IT Security Analyst where I am involved in IT Security for the Post Office Account. I have
a working knowledge of the computer system known as Horizon, which is a computerised
accounting system used by Post Office Ltd. I am authorised by Fujitsu to undertake
extractions of audit data held on the Horizon system 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.
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
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 aspects
of these calls. This area is not my particular area of expertise and I make this witness

statement simply to help clarify the call logs for the benefit of the Court.

An important element of the support provided to sub-postmasters and Counter Clerks is the

Signature Signature witnessed by

CS011A (Side A) Version 4.0 07/06
FUJ00083683
FUJ00083683

Witness Statement
(CJ Act 1967, s9; MC Act 1980, ss 5A(3)(a) and 5B, MC Rules 1981, r 70)

Continuation of statement of

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 (i.e. the sub-postmaster or
counter clerk) would raise a call to the HSH seeking clarification or advice. HSH is a service
run by Fujitsu Services for 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
01/09/05 to 29/11/06 for the address Post Office - Branch Code 0107026 (the Porters Ave
branch)

I have reviewed the HSH calls pertaining to the Porters Ave branch during the period
01/09/05 to 29/11/06 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.

A breakdown of the reason for the calls is given below:
1. Past to NBSC (Network Business Support Centre) = 3
2. Power Cut = 1

3. PinPad=1

4. Error Events Monitored = 2

5. _ PIN (Personal Identification Number) = 2

6. System Freeze = 3

7. Duplicate Call = 1

8. Keyboard (KB) = 1

9. Flood Damage = 1

11. Information Request = 1

12. Loss of Network Connectivity = 5

13. Encryption Key Renewal = 3

Signature Signature witnessed by

csottA Version 4.0 07/06
FUJ00083683
FUJ00083683

Witness Statement
(CJ Act 1967, s9; MC Act 1980, ss 5A(3)(a) and 5B, MC Rules 1981, r 70)

Continuation of statement of

14. Credit Card = 1

15. Bar Code Reader (BCR) = 1
16. One Shot Password (OSP) = 1
17. Office Closure = 1

Call reference details and an overview of each call are given in date order below:

1. Thu 08 September 2005 13:40 call Reference E- 0509080545

New call taken by Anthony Vasse: pm (post master) wants to check foreign currency
rates.

Resolution:

Call Closed by Anthony Vasse - Thu 08 September 2005 13:41: referred pm to nbsc
(Network Business Support Centre) for currency rate issue.

Outcome

PM enquiry past to the NBSC for resolution.

2. Thu 10 November 2005 08:42 call Reference E- 0511100151

New call taken by Denise Miller: BRANCH TRADING > FAILING TO ROLLOVER 09/11
@ 03:15

Resolution:

Call Closed by Denise Miller - Fri 05 May 2006 12:26: @@BIM - matter resolved last
year.

Outcome

This call was logged at the same time as E-0511100152 about the same problem of

failing to rollover, which was passed to the NBSC(Network Business Support Centre)
for resolution.

3. Thu 10 November 2005 08:42 call Reference E- 0511100152

New call taken by Anthony Vasse: pm (post master) is not in the right ca (Cash
Account) period and has not rolled over this morning.

Resolution:

Call Close by Anthony Vasse - Thu 10 November 2005 08:44: referred pm to the nbsc
for trading balance issue.

Outcome

PM enquiry past to the NBSC for resolution.

Signature Signature witnessed by

cSottA Version 4.0 07/06
FUJ00083683
FUJ00083683

Witness Statement
(CJ Act 1967, s9; MC Act 1980, ss 5A(3)(a) and 5B, MC Rules 1981, r 70)

Continuation of statement of

4. Sat 10 December 2005 09:53 call Reference E- 0512100110

New call taken by Erica Tidman: caller has a power failure, contacting horizon to inform
helpdesk

Resolution:

Call Close by Erica Tidman - Sat 10 December 2005 09:55: power failure, power failure
recorded, ref given

Outcome

The PM was logging this call to inform the helpdesk that the PO (Post Office)had just
had a power cut.

5. Wed 04 January 2006 16:34 call Reference E- 0601040801

New call taken by Simon Hopperton: pm states that the pinpad is not working as it
keeps coming up with the error message that the customer has made an unsuccessful
attempt.

Resolution:

Call Close by Simon Hopperton - Wed 04 January 2006 16:41: pm states that the
pinpad is not working as it keeps coming up with the error message that the customer
has made an unsuccessful attempt. pm hung up. pm is happy to close call

Outcome

PM advised to check cables and also walked through reinstallation of the Pinpad.

6. Wed 04 January 2006 17:26 call Reference E- 0601040831

New call taken by Ricky Law - Wed 04 January 2006 17:33: PM need walkthrough
pinpad installation

Resolution:

Call Closed by Ricky Law: PM needed pinpad install walkthrough . PM given
instructions on how to do a pinpad installation. Said to call back if any problems occur.
Outcome

PM given help on how to re-install a pinpad to see if it fixes the fault.

Signature Signature witnessed by

cSottA Version 4.0 07/06
FUJ00083683
FUJ00083683

Witness Statement
(CJ Act 1967, s9; MC Act 1980, ss 5A(3)(a) and 5B, MC Rules 1981, r 70)

Continuation of statement of

7. Wed 04 January 2006 17:35 Call Reference E- 0601040835

New call taken by Nicola Whitehead: pm states that she is having problems after
speaking to Ricki Law regarding the pinpad

Resolution:

Call Close by Sam Roullier - Thu 05 January 2006 15:09: ** [No Remark entered.] Call
closure code of FAILURE and repair code 827

Outcome

An engineer was dispatched to replace faulty pinpad as previous attempts to fix fault
did not work.

8. Thu 05 January 2006 02:23 call Reference E- 0601050008

New call taken by David Hunter: Critical Event received @ 01:15:43; 'An unexpected
error occurred while attempting to insert a message. Timeout occurred waiting for lock
(0xC 1090003

Resolution:Call Close by David Hunter - Thu 05 January 2006 03:57: closing call
Outcome

An automatic error event was picked up by the SMC (System Management Centre) [2nd
line support] and a call was logged. The SMC referred to KEL (Known Error Log)
database ref: JSimpkins338Q. The KEL recommends a remote counter reboot which
fixed the problem and no further events were seen.

9. Fri 13 January 2006 15:58 Call Reference E- 0601130555

New call taken by Keely Fitzgerald: pm states that her pinpad won't accept cards.
Resolution:

Call Close by Akram Ali - Mon 16 January 2006 15:31: ** [No Remark entered.] Call
closure code of FAILURE and repair code 821

Outcome

After pm checked the pinpad an engineer was dispatched to replace it.

10. Wed 18 January 2006 09:15 call Reference E- 0601180136
New call taken by Darryl Johnson: PM states that he has had to reboot and got new

Signature Signature witnessed by

cSottA Version 4.0 07/06
FUJ00083683
FUJ00083683

Witness Statement
(CJ Act 1967, s9; MC Act 1980, ss 5A(3)(a) and 5B, MC Rules 1981, r 70)

Continuation of statement of

PIN (Personal Identification Number) printed but PIN is not going through on the
system.

Resolution:

Call Closed by Darryl Johnson - Wed 18 January 2006 09:20: PM states that PIN
(Personal Identification Number) is not going through on the system - reboot -ref
offered

Outcome
A new PIN was allocated to the PM.

11. Wed 18 January 2006 17:45 call Reference E- 0601180817

New call taken by Hamid Abdul: pm states screen froze during transaction
Resolution:

Call Close by Hamid Abdul - Wed 18 January 2006 17:47 m states screen froze during
transaction. reboot required.

Outcome

PM contacted the helpdesk as the screen had frozen on counter 2. The pm was
advised to re-boot the counter which then continued to operate as normal.

12. Mon 23 January 2006 08:58 call Reference E- 0601230120

New call taken by Sam Roullier: PM states that they cleaned the other day and they
have disconnected cable now he has gone to enter his PMMC card (Postmaster
Memory Card) but doesn’t know where his pin is.

Resolution:

Call Close by Katrina Brooks - Mon 23 January 2006 13:49: have been able to contact
site and speak to pm, pm reports that he has found his pin and has been able to
complete the reboot of counter

Outcome

The pm contacted the helpdesk to say that they had lost their PIN which is input when
using the PMMC card, which is used by sub-postmasters to log onto their terminal. PM
stated that they had found their PIN and logged in ok.

13. Mon 23 January 2006 13:10 call Reference E- 0601230734
New call taken by Stephen Ashby: pm states bcr (Bar Code Reader) is not working
Resolution:

Signature Signature witnessed by

cSottA Version 4.0 07/06
FUJ00083683
FUJ00083683

Witness Statement
(CJ Act 1967, s9; MC Act 1980, ss 5A(3)(a) and 5B, MC Rules 1981, r 70)

Continuation of statement of

Call Close by Joseph Mould - Mon 23 January 2006 15:06: engineer adjusted cable
tested ok Call closure code of and repair code 824

Outcome

Engineer went to site and adjusted BCR cable on counter 2 and tested OK.

14. Mon 23 January 2006 13:15 call Reference E- 0601230737

New call taken by Stephen Ashby: pm states ber not working

Resolution:

Call Close by Stephen Ashby - Mon 23 January 2006 13:17: pm states ber not working.
reboot required. ref no offered.

Outcome

This appears to be a duplicate call for the BCR on counter 2 which was resolved as per
previous call E- 0601230734.

15. Thu 16 February 2006 15:30 call Reference E- 0602160746

New call taken by Louise Peplow: Pm states that the KB (Keyboard) is not accepting
swipe cards.

Resolution:

Call Close by Catherine Jeanes - Fri 17 February 2006 16:23: ** [No Remark entered.]
Call closure code of FAILURE and repair code 821

Outcome

An engineer was dispatched and the KB (Keyboard) was replaced and tested.

16. Mon 13 March 2006 16:25 call Reference E- 0603131056
New call taken by James Butterworth: Pm states that the pinpad is not working.
Resolution:

Call Close by Stephen Ashby - Tue 14 March 2006 16:01: engineer swapped pinpad.
tested ok. Call closure code of and repair code 821

Outcome
An engineer was dispatched and the KB was replaced and tested.

17. Fri 05 May 2006 08:45 call Reference E- 0605050099
New call taken by Jennifer Dear: Cath from NBSC states that site will be closed until

Signature Signature witnessed by

cSottA Version 4.0 07/06
FUJ00083683
FUJ00083683

Witness Statement
(CJ Act 1967, s9; MC Act 1980, ss 5A(3)(a) and 5B, MC Rules 1981, r 70)

Continuation of statement of

further notice due to flooding and site needing to be re-wired

Resolution:

Call Close by Denise Miller - Wed 10 May 2006 15:20: @@BIM as per progress branch
reopened.

Outcome

The NBSC logged this call to highlight that this PO was closed due to flood damage, it
was re-opened 3 days later on the 8" May.

18. Fri 05 May 2006 12:50 call Reference E- 0605050676

New call taken by Denise Miller: Branch has closed today owing to flood /no power.
Can SSC (System Support Centre) advise date last branch trading harvested etc.,
branch may require rewire so need latest date PO should reopen by to avoid archiving.
thanks.

Resolution:

Call Close by Denise Miller - Wed 10 May 2006 15:21: @@BIM - above comments duly
noted. Branch reopened successfully.,

Outcome

This call was logged to find out how long the PO could be closed before it affected its
data retrieval. The PO was re-opened 3 days latter so no action necessary.

19. Tue 09 May 2006 14:28 call Reference E- 0605090919

New call taken by Sukhdeep Thind: Pm reports that she has online services
unavailable - 0111.
Resolution:

Call Close by Sukhdeep Thind - Tue 09 May 2006 14:30: online services unavailable.
NFF (no fault found).

Outcome

It appears that the PO may have briefly lost network connectivity, the helpdesk could
not find any fault and the call was closed.

20. Fri 12 May 2006 23:31 call Reference E- 0605120970

New call taken by Richard Postance: Critical NT_Error occurred at 23:17:25, 12/05/06
on H10702600101. KMRxX: Riposte Error 1726. The remote procedure call failed.
(Ox6BE) RiposteReadMessagePort.

Resolution:

Signature Signature witnessed by

cSottA Version 4.0 07/06
FUJ00083683
FUJ00083683

Witness Statement
(CJ Act 1967, s9; MC Act 1980, ss 5A(3)(a) and 5B, MC Rules 1981, r 70)

Continuation of statement of

Call Close by Richard Postance - Sat 13 May 2006 07:15: Counter successfully
rebooted, no further errors. closing call.
Outcome

(‘NT’ referring to the Microsoft operating software used on the counters)

An automatic error event was picked up by the SMC (System Management Centre) [2nd
line support] and a call was logged. The SMC referred to KEL (Known Error Log)
database ref: MWright1245K. The KEL recommends a remote counter reboot which
fixed the problem and no further events were seen. This error was due to the KMRX
service (which is the Key Management Distribution Receiver Service that runs on
counters) failing to respond.

21. Fri 19 May 2006 12:43 call Reference E- 0605190435

New call taken by Anthony Vasse: pm needs to update the security on the system.
Resolution:

Call Close by Anthony Vasse - Fri 19 May 2006 12:45: pm needed help with a kma
(Key Management Application) refresh. Issue resolved.

Outcome

The data encryption keys on all counters are renewed/refreshed every 2 years via
rebooting the counters and by following some on screen instructions. The PM needed
assistance in doing this.

22. Sat 20 May 2006 09:20 call Reference E- 0605200118

New call taken by Darryl Johnson: PM states that he is trying to update PMMC
(Postmaster Memory Card) but now has communication with the centre has failed.
Resolution:

Call Close by Darryl Johnson - Sat 20 May 2006 09:25: pm states that he has
communication with the centre failed- kma door opened - re offered

Outcome

The network communication failed when trying to update the data encryption keys on
the PMMC, as the comms have to be set/open (“door”) for specific updates, this was
then set by the helpdesk and the update re-tried successfully.

23. Thu 25 May 2006 16:04 call Reference E- 0605250980
New call taken by Matthew Fry: FAD requires Security keys updated - Contact the PM

Signature Signature witnessed by

cSottA Version 4.0 07/06
FUJ00083683
FUJ00083683

Witness Statement
(CJ Act 1967, s9; MC Act 1980, ss 5A(3)(a) and 5B, MC Rules 1981, r 70)

Continuation of statement of

to request controlled restarts and acceptance of new security data on all slave
counters.

Resolution:
Call Close by Lee Shambrook - Mon 19 June 2006 15:46: KMA complete
Outcome

The helpdesk contacted the pm to advise him to re-boot counter 2 so that the
encryption key update can complete.

24. Fri 01 September 2006 10:19 call Reference E- 0609010268

New call taken by Elspeth Neilson: PM (post master) states all London Borough and
Dagenham swipe cards are being declined on both counters. All other swipe cards are
being accepted.

Resolution:

Call Close by Elspeth Neilson - 01/09/2006 10:22: PM reported London Borough cards
not going through. Advised that the problem is with the cards. Referred to NBSC
(Network Business Support Centre).

Outcome

This was a problem with a customer credit card and passed to the NBSC.

25. Mon 04 September 2006 10:01 Call Reference E- 609040287
New call taken by Stephen Ashby: pm states online services unavailable.
Resolution:

Call Close by Stephen Ashby - 04/09/2006 10:05: online services unavailable, The
network connection was successfully pinged (tested) and now fine.

Outcome

Network communication was lost briefly.

26. Mon 04 September 2006 14:52 call Reference E-0609040840

New call taken by Akram Ali: pm states that he has message on screen telling him to
contact Horizon and quote error code 00000111.

Signature Signature witnessed by

cSottA Version 4.0 07/06
FUJ00083683
FUJ00083683

Witness Statement
(CJ Act 1967, s9; MC Act 1980, ss 5A(3)(a) and 5B, MC Rules 1981, r 70)

Continuation of statement of

Resolution:

Call Close by Akram Ali - 04/09/2006 14:56: pm advised to carry out a network test,
advised test was fine pm will call back if still not working.

Outcome

The error code quoted was informing that there had been a brief loss in network
communication.

27. Tue 05 September 2006 15:14 call Reference E- 0609050731
New call taken by Stephen Ashby: pm states online services unavailable.
Resolution:

Call Close by Stephen Ashby - 05/09/2006 15:16: online services unavailable, The
network connection was successfully pinged (tested) and now fine.

Outcome

Network communication was lost briefly

28. Tue 05 September 2006 15:35 call Reference E- 0609050766
New call taken by Elspeth Neilson: PM states online services are unavailable. Online
services have been intermittent since yesterday morning.

Resolution:

Call Close by Jordan Edgar - 12/09/2006 10:03: Pm was advised to perform a counter
re-boot and it was also arranged for BT to check the phone lines for any problems (no
fault was found). It was then decided to replace the Base Unit (counter) to see if this
cured the intermittent fault. The base unit was swapped and the site was monitored for
any recurrence of the problem. The PM was contacted and was happy for call to be
closed.

Outcome

This was a problem with network communication with the counter, An engineer was
dispatched and the counter was swapped out.

29. Wed 13 September 200614:36 call Reference E-0609130558
New call taken by Ricki Law: Please wait while receipt is printed message has frozen
on screen.

Resolution:

Call Close by Ricki Law - 13/09/2006 14:39: Please wait while receipt is printed
message has frozen on screen. PM advised to carry out a reboot of the counter.

Signature Signature witnessed by

cSottA Version 4.0 07/06
FUJ00083683
FUJ00083683

Witness Statement
(CJ Act 1967, s9; MC Act 1980, ss 5A(3)(a) and 5B, MC Rules 1981, r 70)

Continuation of statement of

Outcome
This was a counter freeze which was resolved with a reboot.

30. Thu 21 September 200617:12 call Reference E- 0609210861
New call taken by Ricki Law: PM states system has frozen on riposte screen,
Resolution:

Call Close by Ricki Law - 21/09/2006 17:16: PM states system has frozen on riposte
screen.(screen had frozen during reboot) advised reboot.

Outcome
This was a counter freeze which was resolved with a reboot.

31. Wed 29 November 2006 14:25 call Reference E- 0611290626
New call taken by Joanne Rowland: nbsc requests osp (One Shot Password) for
auditor.

Resolution:

Advised Call Close by Joanne Rowland - 29/11/2006 14:34: osp provided for auditor.
Outcome

A OSP was required by the auditor to enable him to log in to the counter, this was
authorised by the NBSC.

32. Wed 29 November 2006 15:39 Call Reference E- 0611290757

New call taken by Daley Bilton: requests OSP contact on:
Resolution:

Call Close by Daley Bilton 29/11/2006 16:05: osp given
Outcome

A OSP was required by the auditor to enable him to log in to the counter, this was
authorised by the NBSC.

GRO

33. Wed 29 November 2006 16:26 Call Reference E- 0611290794

New call taken by Stephanie Byrne: Closure @ 1600 today due to an Audit. Closed
until further notice

Resolution:
This call is still open.

Signature Signature witnessed by

cSottA Version 4.0 07/06
FUJ00083683
FUJ00083683

Witness Statement
(CJ Act 1967, s9; MC Act 1980, ss 5A(3)(a) and 5B, MC Rules 1981, r 70)

Continuation of statement of

Outcome

This call was raised to highlight the fact that the Office will be closed until further
notice.

The calls E- 0605120970, E- 0601050008, referrer to a “critical event” “Critical NT_Error”.
The term critical is the comparative level of attention required to generate remedial action. It
refers to the level of attention required on a grading system for example critical high level of
attention or warning would be medium level of attention. These critical events occurred outside
the Post Office opening times and a standard action of a reboot of the systems, which would
also highlight any further issues, was undertaken and repaired the problem and confirmed
stability of the system. I should add that this area is not my particular area of expertise. I have
a general knowledge of these procedures and have made the comments above to aid the
court.

Signature Signature witnessed by

cSottA Version 4.0 07/06