FUJ00152189 - ICL Pathway Ltd NETWORK BANKING MANAGEMENT OF PROSECUTION SUPPORT (Draft). Abstract: This document outlines the end to end procedures required to manage and deliver the Network Banking prosecution support service.

Evidence on official site

FUJ00152189
FUJ00152189

ICL Pathway Ltd Network Banking Management of Prosecution —_—Ref: NB/PRO/003

Support
Version: 0.1
COMMERCIAL IN CONFIDENCE Date: 11-Feb-2002

Document Title:

Document Type:

Release:

Abstract:

Document Status:

Originator & Dept:

Contributors:

Reviewed By:

Comments By:

Comments To:

Distribution:

NETWORK BANKING MANAGEMENT OF
PROSECUTION SUPPORT

Procedure

N/A

This document outlines the end to end procedures required to
manage and deliver the Network Banking prosecution support
service.

DRAFT

Jane Bailey CS Security

Graham Hooper, Jan Holmes, Richard Laking

Jan Holmes, Graham Hooper, Richard Laking, Brian Muir,
Tony Hayward, Hilary Forrest, Richard Brunskill

PO - Graham Ward
22/02/02

Originator & Pathway Document Controller

ICL Pathway Document Management and Review list

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Contract Controlled
ICL Pathway Ltd

Support

Network Banking Management of Prosecution

FUJ00152189
FUJ00152189

Ref: NB/PRO/003

Version: 0.1

COMMERCIAL IN CONFIDENCE Date: 11-Feb-2002
0.0 Document Control
0.1 Document History
Version No. I Date Reason for Issue Associated
CP/PinICL
0.1 11/02/02 Initial Draft N/A
0.2 Approval Authorities
Name Position Signature Date
Martin Riddell Director, Customer
Service
Graham Hooper CS Security Manager
Graham Ward Post Office Ltd. Internal
Crime Policy and
Standards Manager
0.3 Associated Documents
Reference Version I Date Title Source
PA/TEM/001 ICL Pathway Document PVCS
Template
CR/FSP/006 Audit Trail Functional PVCS
Specification
NB/SDS/004 System Design PVCS
Specification for Network
Banking Reconciliation
IA/PRO/004 Audit Data Extractions PVCS
Process

Unless a specific version is referred to above, reference should be made to the current
approved versions of the documents.

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FUJ00152189

FUJ00152189
ICL Pathway Ltd Network Banking Management of Prosecution Ref: NB/PRO/003
Support
Version: 0.1
COMMERCIAL IN CONFIDENCE Date: 11-Feb-2002

0.4 Abbreviations/Definitions

Abbreviation Definition

cs Customer Services

Disputed Banking Means any Banking Transaction the result or records of which are

Transaction disputed by POCL or a third party

FAD A Post Office outlet unique identifier.

HSH Horizon System Helpdesk

Litigation Means civil or criminal court or statutory tribunal proceedings
related to Banking Transactions

PO Ltd Post Office Limited

PSS ICL Pathway Prosecution Support Section

PSS Day Between 09:00 and 17:30 Monday to Friday excluding English
Bank Holidays.

Record Query Means the extraction by the NB System of records relating to

Banking Transactions meeting specified Search Criteria such
extraction being limited to specific types of information/data fields

Record Query Form

Record Query Form (RQ). A single Record Query Form must
relate to a single outlet.

RFI

Request for Information for the Existing service

Search Criteria

Means either of:
(a) date range, time-range, Outlet and PAN; or
(b) date range, time-range and Outlet,

which may be specified for a Record Query.

NB this is different from the criteria used for Disputed Banking
Transactions

0.5 Changes in this Version

Version

Changes

0.1

Initial Draft

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Contract Controlled

FUJ00152189

FUJ00152189
ICL Pathway Ltd Network Banking Management of Prosecution Ref: NB/PRO/003
Support
Version: 0.1
COMMERCIAL IN CONFIDENCE Date: 11-Feb-2002

0.6 Changes Expected

Changes

Comments from internal review

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Contract Controlled
FUJ00152189

FUJ00152189

ICL Pathway Ltd Network Banking Management of Prosecution Ref: NB/PRO/003
Support

Version: 0.1
COMMERCIAL IN CONFIDENCE Date: 11-Feb-2002

0.7 Table of Contents

1.0 INTRODUCTION...
1.1 EXISTING SERVICES..........000000
2.0 SCOPE...

3.0 RECORD QUERIES

3.1 SCOPE...
3.2 SEARCH CRITERIA
3.3. FORMAT FOR RECORD QUERY REQUESTS .
3.4 EXCLUSIONS...

4.0 LITIGATION SUPPORT.

4.1 SCOPE
4.2. EXCLUSIONS.........

5.0 NOTIFICATION PROCESS...

5.1 CONTACT POINTS .
5.1.1 Post Office.
5.1.2 ICL Pathway

5.2 REQUEST PROCESS

6.0 MANAGEMENT PROCESS...

6.1 ALLOCATION OF RECORD QUERIE!
6.2. RECORD QUERY DATABASE
6.3 PROCESS FOR CANCELLATIONS

7.0 PROSECUTION SUPPORT PROCESS...

7.1 RECORD QUERY...
7.1.1 Identify Search Criteri:
7.1.2 Create Audit trail of request
7.1.3 Search for files required to complete reques
7.1.4 Select and retrieve file:
7.1.5 Generate message stort
7.1.6 Rquery to spreadsheet
7.1.7 Burn closed CD
7.1.8 Anti Virus check .
7.1.9 Despatch

7.2. LITIGATION SUPPORT
7.2.1. Check Horizon System Helpdesk Logs
7.2.2. Analysis Non-polling reports ....
7.23 Analysis of event and fault logs
7.24 Complete witness statement

7.2.4.1 Witness Statement of Fact ... . .

7.2.4.2 Court attendance in support of Witness Statement of Fact
7.2.5 Exhibit Labels .
7.2.6 Despatch..

7.3. RECORD QUERY AND LITIGATION SUPPORT RESOLUTION TIME SCALES

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ICL Pathway Ltd Network Banking Management of Prosecution Ref: NB/PRO/003
Support
Version: 0.1
COMMERCIAL IN CONFIDENCE Date: 11-Feb-2002

7.4 WIDE SPREAD ERRORS ...........cccccsceeseeseseeeeseeeeeeeeesseeeteteasenseeetestesesneeeeteseneseeseseeeneneee 20
8.0 ADDITIONAL LITIGATION SUPPORT........ccscsssssessessessesnesesnessesneenssnenecaneneeneeneeses 22

8.1 EXPERT WITNES: i]

8.2 COURT ATTENDANCE IN SUPPORT OF EXPERT WITNESS STATEMENT
9.0 ACCESS TO AUDIT TRAILS 23
10.0 APPENDICES ....sssssssssssssscsessesssssnssncsnsoscsncescsnssscsnssssuscsnsensscsenoscsesonssssencesssnssosensoosences 24

10.1. APPENDIX I
10.2 APPENDIX 2
10.3. APPENDIX 3
10.4 APPENDIX 4

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ICL Pathway Ltd Network Banking Management of Prosecution Ref: NB/PRO/003
Support
Version: 0.1
COMMERCIAL IN CONFIDENCE Date: 11-Feb-2002

1.0 Introduction

The Network Banking Prosecution Support Service has been introduced in response to NBS
Requirements 260 and 315. The scope of the Service is outlined in Schedule NO1 of the
Codified Agreement in the Section entitled “/nformation Retrieval and Audit”.

This document defines the management and delivery of the service necessary to support
Consignia in respect of criminal prosecution or civil litigation for the NBS.

It is intended that the management of prosecution support process is generic for all services.
Record Query requests are received, documented, extracted from the Audit Archive and
progressed to resolution in the same manner. The production of evidence and witness
statements in support of litigation also utilises the same processes.

1.1 Existing Services

At the operational level, it is considered unhelpful and impractical to introduce an arbitrary
distinction between litigation support for NBS and the existing service. Nevertheless this
document and the limits on Record Queries and Search Criteria it contains relate to
information retrieval and audit for the Network Banking System and not the Existing
Services. Should existing provisions in respect of information or transaction record retrieval
obligations for the Existing Services be in conflict or inconsistent with the obligations for
Network Banking Litigation Record Queries, such obligations shall continue to apply to the
Existing Services and not to the Network Banking System.

Provision of prosecution support for the existing service has not been agreed under contract,
nor has a CR been received to request such a facility. Provision of the current data retrieval
support service is based upon an informal agreement between the Director of Horizon
Commercial and the Director of Pathway Quality. CCN 759, submitted to formalise this
agreement was not subsequently ratified. The agreement provided for the provision of up to
50 audit data extractions per annum for audit and security purposes, with a maximum of 7 in
any calendar month. The annual target measured over a rolling 12 month period. Additional
extractions were catered for on the basis of Time and Material costs equivalent to 1.5 days at
Senior consultant rate.

The provision of litigation support (specifically the provision of witness statements) is
similarly not formalised and is currently provided on a “without prejudice subject to contract”
basis pending the receipt of an appropriate Change Request.

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Contract Controlled
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ICL Pathway Ltd Network Banking Management of Prosecution Ref: NB/PRO/003
Support
Version: 0.1
COMMERCIAL IN CONFIDENCE Date: 11-Feb-2002

2.0 Scope

This document sets out the procedures to be adopted by ICL Pathway / Prosecution Support
Section (PSS) for managing and dealing with NWB Record Queries for Investigation and
Litigation support purposes and any other NWB Litigation issues which may arise, including
the:

* undertaking of Record Queries;

* presentation of banking Transaction records extracted by Record Queries;

* analysis of appropriate Help Desk records, Non-Polling and fault and event logs;
* preparation of Witness Statements of Fact in relation to Record Queries;

* attendance at Court by relevant employees to give evidence in respect of Witness
Statements;

+ undertaking of additional litigation support activities as may be requested on a case-by-
case basis on the instruction of Legal Counsel.

It is recognised that it is not possible to deliver a standardised response to all litigation related
NB Record Queries. The type of information requested for a Record Query is heavily
dependent upon the requirements of the particular case in question and the demands of the
Legal System.

These procedures therefore provide a flexible approach to the provision of litigation support.

Evidence in support of potential litigation will be obtained solely from the Horizon System
Audit Archive / Server. The integrity of this data is described in the Audit Trail Functional
Specification. All access to audit data is restricted to named individuals who access via
dedicated workstations located in a secure environment. This is consistent with the security
controls employed for the existing service.

Requests for Information will fall into two general categories:
Record Query only.

This involves the extraction for the audit archive of records relating to data for a
particular outlet.

Record Query plus associated Witness Statement.

This involves the extraction for the audit archive of records relating to data for a
particular outlet plus the provision of a Witness Statement of Fact in support of the data
extracted.

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ICL Pathway Ltd Network Banking Management of Prosecution Ref: NB/PRO/003
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Version: 0.1
COMMERCIAL IN CONFIDENCE Date: 11-Feb-2002

3.0 Record Queries
3.1 Scope

A Record Query is an extraction from the Network Banking System of records relating to
Banking Transactions, which meet specific search criteria. Record Queries may be
undertaken to provide transaction and other details required to facilitate an investigation or in
support of litigation.

The number of Record Queries requested by PO Ltd in connection with investigation or
litigation shall be no more than 500 per year on a rolling year basis with no more than 70 in
any calendar month. Any Record Queries over and above the 500 maximum will be rolled-
over to the next 12-month period and count towards the total for the next year.

3.2 Search Criteria

The search criteria for Record Queries in support of litigation are either:
(a) Date range, time-range, Outlet and PAN; or
(b) Date range, time-range and Outlet.

which may be specified for a Record Query.

These criteria differ from those for Record Queries in respect of Disputed Banking
Transactions in that litigation support generally requires a range of dates as opposed to
individual dates. It is therefore impractical to restrict the search criteria to individual dates.

Each Record Query shall cover a maximum date range of 14 calendar days.

Individual dates or multiple date ranges can be accommodated provided that the maximum
number of days requested does not exceed 14 calendar days for each Record Query.

If a request is received for a date range greater than 14 calendar days then an additional
Record Query or Record Queries will be required to facilitate the request. Additional Record
Queries will be required for each subsequent period of 14 calendar days or part thereof.

Each Record Query shall relate only to an individual Outlet.

3.3. Format for Record Query Requests
Record Queries in connection with litigation shall be made via the Record Query Form.
Post Office Ltd will specify the following details for each Record Query:

Date of request;

Outlet FAD and address to which the Record Query relates. Each Record Query shall
relate to a single FAD;

Date range/times. The maximum date range for each Record Query shall normally be 14
calendar days.

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ICL Pathway Ltd Network Banking Management of Prosecution Ref: NB/PRO/003
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COMMERCIAL IN CONFIDENCE Date: 11-Feb-2002

General requirements. This includes the required attributes associated with the Record
Query. NB: Precise attributes available under the Network Banking Service are yet to be
confirmed. ICL Pathway shall agree with Post Office Ltd the attributes necessary to
support their requirements.

Output Format required. This is normally a standard Excel 95 version with separate
columns for each attribute requested.

Alternatively ICL Pathway will provide information in native format if requested. ICL
Pathway will provide details in other formats on receipt of an appropriate Change Request.

Each Record Query shall be allocated a unique identifier to facilitate the logging and
monitoring of work carried out. The identifier shall be “RQ” followed by a sequential
number starting from 1 (1 to nnn). This will provide the audit trail information necessary to
ensure continuity of evidence if required later at a court or tribunal.

The agreed Record Query (RQ) Form is at Appendix 1.

3.4 Exclusions

Record Queries in connection with Disputed Banking Transactions are not covered in this
document.

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ICL Pathway Ltd Network Banking Management of Prosecution Ref: NB/PRO/003
Support
Version: 0.1
COMMERCIAL IN CONFIDENCE Date: 11-Feb-2002

4.0 Litigation Support

In addition to the details at 3.3 above, Post Office Ltd shall wherever possible, advise on the
Record Query Form whether an associated Witness Statement is required.

4.1 Scope

PSS on request and in conjunction with the requested Record Query in support of Litigation,
shall supply the following:

Appropriate Horizon Help Desk and Non-polling reports for the specific search criteria on
the Record Query shall be analysed to ensure the integrity of Banking Transactions
records extracted for the Record Query;

Fault and event logs shall be analysed also to ensure the integrity of Banking Transactions
records extracted for the Record Query;

Witness Statements of the facts in relation to a Litigation Record Query and based on the
above analysis shall be prepared by the relevant member of ICL Pathway Customer
Service Prosecution Support Section. A maximum of 250 Analysis and Witness
Statements will be undertaken per year;

Attendance at Court by the person who has provided the Witness Statement in order to
give evidence in support of that Witness Statement. ICL Pathway shall provide a
maximum of 200 days attendance in court per year.

The precise work undertaken for litigation support is detailed in section 7.2 Litigation
Support.
4.2 Exclusions

The provision of additional litigation support is excluded from the service detailed above.
Additional litigation support is covered in Section 8 (Additional Litigation Support).

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FUJ00152189
ICL Pathway Ltd Network Banking Management of Prosecution Ref: NB/PRO/003
Support
Version: 0.1
COMMERCIAL IN CONFIDENCE Date: 11-Feb-2002

5.0 Notification Process

5.1 Contact Points
5.1.1 Post Office

All Record Queries in conjunction with investigation and or litigation must be authorised by
the Post Office Ltd Security and Network Audit Team.

Requests will be accepted from the following named individual:
Graham Ward: Internal Crime Policy and Standards Manager

Post Office Ltd.

Security and Network Audit,

4" Floor Impact House,

Edridge Road,

Croydon CR91PJ

Tel

Post Office Ltd. Internal Crime Policy and Standards Manager shall also advise the ICL
Pathway Prosecution Support Manager of one named deputy who is authorised to request
record queries in his absence.

Other parts of the Post Office (e.g. Security and Network Audit Team) requiring Record
Queries must channel these requests through this single point of contact. All Record Queries
from these sources shall count toward the 500 maximum for the year.

5.1.2 ICL Pathway

Post Office Ltd. Internal Crime Policy and Standards Manager shall submit all requests for
Record Queries in connection with investigation and Litigation to:

Customer Service Prosecution Support Section,
ICL Pathway,

Forest Road,

Feltham

Middlesex TW13 7EJ

The Record Query will be sent via email to both ICL Pathway’s Prosecution Support
Manager and also to one named deputy who shall be advised to the Post Office Ltd. Internal
Crime Policy and Standards Manager.

ICL Pathway and Post Office Ltd will agree the e-mail address of the operational single point
of contact within both organisations.

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ICL Pathway Ltd Network Banking Management of Prosecution Ref: NB/PRO/003
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COMMERCIAL IN CONFIDENCE Date: 11-Feb-2002

5.2 Request Process

Post Office Ltd Internal Crime Policy and Standards Manager shall receive a Record Query
from an employee of the Post Office. The Internal Crime Policy and Standards Manager or
deputy shall complete a Record Query form and email it to both the ICL Pathway Prosecution
Support Manager and to one nominated and agreed individual from PSS. This will provide
the contingency arrangements. The nominated individual shall record the details of the
request and the date and time of the request in the Record Query Database. The manager
shall determine which member of the PSS shall carry out the request from analysis of current
workloads per team member.

Post Office Ltd Internal Crime Policy and Standards Manager shall also keep a log of all
requests made to the PSS.

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Contract Controlled
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ICL Pathway Ltd Network Banking Management of Prosecution Ref: NB/PRO/003
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Version: 0.1
COMMERCIAL IN CONFIDENCE Date: 11-Feb-2002

6.0 Management Process

6.1 Allocation of Record Queries

ICL Pathway Prosecution Support Manager shall allocate and monitor all requests within
PSS. Allocation will be determined on current workloads of each member of PSS. Each
individual in the section has the responsibility for updating their log daily. This will ensure an
even spread of workload across PSS, making sure all requests are completed in accordance
with agreed time scales. Status of Record Queries shall be maintained in the Record Query
Database.

6.2 Record Query Database

The Database shall track all work carried out, by date and time, on every Record Query. The
database shall be used for allocating requests and tracking the request through the audit
extraction process.

6.3 Process for Cancellations

The process of cancellation shall take into account the dates of each request and not the
requests unique identifier. As the unique identifier shall be used for audit purpose once an
identifier has been attached to a request it shall not be reused even if the request is later
withdrawn. This ensures the integrity of the request log for requests that require litigation
support at the time of request or at a future date. The log shall also ensure that Post Office Ltd
and ICL Pathway meet contractual requirements on the number of requests and the turn
around of requests.

Investigate requests
evidence from PO Ltd.
Intemal Crime Policy &

Cancellation Request Standards Manager

PSS Manager receives Record Confirmation receipt 3] PO Lid Receive Request and fill in
Query Record Query Form

I Form emailed

Record Qu Logged on Record Query Database

will not be
removed from the
Record Query

database, Th Record Query Database
will be marked as
Cancelled
aennennee enna a

. Work carried out and recorded in
Ifa Record Query has Recond Quer Daubae
started, it can be
cancelled but will still
count toward the
annual total. CD Processed and posted to PO

Ld
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Contract Controlled
ICL Pathway Ltd

Network Banking Management of Prosecution

Support

COMMERCIAL IN CONFIDENCE

Ref: NB/PRO/003

Version: 0.1
Date: 11-Feb-2002

FUJ00152189
FUJ00152189

7.0 Prosecution Support Process

Identify Search Criteria

Create Audit Trail of Request.

Search for files required to
complete request

i

Select and retrieve files

Request For

‘Network Banking’

Information Form

Check Horizon system Helpdesk
Logs

Analysis Non-polling reports

Analysis all event and fault logs.

I

Generate Message Store

Rauery to spreadsheet

System automatically
logs data and time of
each process to the
Reauest Audit Trail

Complete Witness Statement

Burn ‘closed’ CD

Anti Virus cheek CD.

i

Despatch of CD

7.1 Record Query

7.1.1 Identify Search Criteria

The team member allocated to the request shall identify the search criteria from the Record

Query

7.1.2 Create Audit trail of request

The Audit Solution provides an audit extractor register. A registry shall be created on the
Audit Workstation at the beginning of the work for each Record Query. The register records
the time spent on the Audit Workstation in completing the Record Query. The search criteria

Complete Exhibit Labels

Despatch to PO Lid

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ICL Pathway Ltd Network Banking Management of Prosecution Ref: NB/PRO/003
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Version: 0.1
COMMERCIAL IN CONFIDENCE Date: 11-Feb-2002

and Record Query identifier shall be used to initiate each audit extractor registry. (NB: the
Audit Extractor Register is not the Record Query Database). The Record Query Database
holds information on when the Record Query is received, the search criteria and whether any
Record Queries are cancelled.

7.1.3 Search for files required to complete request

A search for files required to complete the request shall then be initiated using the audit
extractor register.

7.1.4 Select and retrieve files

Once the search has completed and returned the results each required file shall be marked for
selection and then selection will be initiated. Files extracted from the tape silo to the server
shall be seal checked as they are extracted. This check ensures that the integrity of the data
has not been altered from the time the transaction first originated to the time it was stored to
tape. After the files have been extracted the operator shall check the seal status and ensure all
seals match.

7.1.5 Generate message store

A message store of the selected files shall be initiated on the operator’s local machine using
the files extracted to the audit server.

7.1.6 Rquery to spreadsheet

Once the message store has been successfully generated, the Rquery tool shall be used to
select the files as per the search criteria set out in the Record Query. (NB: Banking
Transaction details are still in refinement and until documentation is prepared on Network
Banking Transaction data, data attributes available cannot be identified. When documentation
is available Post Office Ltd. Internal Crime Policy and Standard Manager and ICL Pathway
PSS Manager shall agree requirements).

The Banking Transaction records extracted for the Record Query shall be export by the
Rquery tool to an Excel 95 Format or native format if requested.

Sensitive Data included in records of Banking transactions are held in encrypted form by the
Network Banking System. Therefore, sensitive data included in a Record Query will be
provided to Post Office Ltd. Internal Crime Policy and Standards Manager in its encrypted
form.

7.1.7 Burn closed CD

Once the data is complete and formatted it shall be burnt to ‘closed’ CD-W along with a word
document that shall provide an explanation of the format in which the data is provided. The
CD-W will be labelled with the Record Query reference number, using a special pen for
writing on CDs. The audit extractor register will complete date and times of access and
events.

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COMMERCIAL IN CONFIDENCE Date: 11-Feb-2002

7.1.8 Anti Virus check

The word document that is attached to the CD shall also contain reference to the anti virus
software used to check the CD. It shall state the engine and virus definition files used. The
CD-W shall be checked for viruses after the data has been written to it and before sending it
to the Post Office.

7.1.9 Despatch

The CD shall be sent to Internal Crime Policy and Standards Manager by first class post.
Packaging of the CD will provide sufficient protection against damage in transit.

Files extracted to the audit server shall then be deleted in order for the next Record Query to
be undertaken. The message store on the operators local workstation shall be cleared of
messages and the audit extractor register shall complete dates and times of all access and
events before marking that particular registry as completed.

7.2. Litigation Support

7.2.1 Check Horizon System Helpdesk Logs

Any problems or faults at a Post Office outlet are logged with the Horizon System Helpdesk.
These logs will be examined using the search criteria specified in a Record Query to ensure
the outlet was functioning effectively.

The logs are accessed through the web-based program, Powerhelp. All PSS members shall
have access to Powerhelp. They shall use the specified outlet and date range as requested in
the Record Query search criteria to search Powerhelp for any calls logged for the outlet in the
data range required. The log of calls to the Horizon System Helpdesk detail incidents of
error, inaccuracy or malfunction pertaining to the sites, equipment, services and individuals
concerned.

7.2.2 Analysis Non-polling reports

Non polling reports shall be reviewed for the outlet in question, for all days within the date
range specified, to identify if the outlet in question had any problems receiving polls. Non-
polled reports are stored by date. The file consists of all non-polls for a particular day. For
the date range in question, the reports with the corresponding date shall be retrieved and
searched through, by outlet. This will ensure whether during the date range in question the
outlet received all polls.

7.2.3 Analysis of event and fault logs

Any relevant PinICLs identified in Powerhelp logs will be reviewed through PinICL Client to
ensure that any recorded faults, would not hinder the outlets performance or otherwise affect
the integrity of audit archive from which the Record Queries are extracted.

The PinICL log will detail the error relating to the site, equipment and or service in question.

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Contract Controlled
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Version: 0.1
COMMERCIAL IN CONFIDENCE Date: 11-Feb-2002

7.2.4 Complete witness statement

PSS will provide a witness statement of fact in respect of 250 Record Queries per annum.
This will as far as possible be undertaken by the person responsible for the actioning of the
work at 7.1 so as to retain continuity of evidence and obviate the need for additional
statements.

7.241 Witness Statement of Fact

Any material or otherwise pertinent information shall be recorded and included in the
relevant witness statement.

Requirements for witness statements explaining the extraction of Audit Data from Horizon in
response to a Record Query shall be completed by the individual from PSS who completed
the request.

The statement shall follow the standard format for witness statements provided in evidence
including the following:

Identification information about the author of the Witness Statement.

A summary of the previous manual system used by the Post Office before Horizon.
A summary of Horizon and what information is recorded.

How consistent time is recorded within the Horizon system.

The types of reports that can be generated on a counter by a clerk.

The transfer of accounts information to Post Offices main accounts department.

A brief overview of all applications, OBCS, EPOSS, APS, LFS, NBS.

How data is passed from the counter to Tape.

The process for extracting information for Record Queries and the controls in place to
protect and ensure the integrity of that data.

An analysis of the Record Query, when the Record Query form was received and the
dates when the audit data extraction took place. This shall be taken from the Record
Query Database and Audit Extractor Registry.

A summary of the evidence provided for the request

Any NB specific Witness Statement requirements shall be incorporated as agreed by Post
Office Ltd. Internal Crime Policy and Standards Manager and ICL Pathway CS Security
Manager.

An agreed draft Witness Statement of Fact is at Appendix 2.

7.2.4.2 Court attendance in support of Witness Statement of Fact

The author of a witness statement of fact may be required to attend Court in order to bear
testimony to the facts. A maximum of 100 days has been anticipated for Court attendance.
Any days over this maximum shall be subject to a Change Request.

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Contract Controlled
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ICL Pathway Ltd Network Banking Management of Prosecution Ref: NB/PRO/003
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Version: 0.1
COMMERCIAL IN CONFIDENCE Date: 11-Feb-2002

7.2.5. Exhibit Labels

All evidence referred to in the Witness Statement will require an Exhibit Label. This allows
for the evidence to be clearly identified. Exhibit labels will be required for any of the
following that are referred to in the Witness Statement of Fact:

CD of transaction data,
HSH logs,
Non-polling reports,
fault and event logs.

The agreed Exhibit Labels are in appendix 3.

7.2.6 Despatch

Evidence from HSH logs, Non-polling reports, fault and event logs shall be given an exhibit
number and along with the Witness Statements of fact, shall be posted to Post Office Ltd.
Internal Crime Policy and Standards Manager by first class post. Packaging of the
statements, reports etc. will provide sufficient protection against damage in transit.

7.3 Record Query and Litigation Support Resolution Time
Scales

The time-scale for completion of each Litigation Support Record Query is seven working
days. This is measured from the time and date that the Record Query is received by PSS from
Post Office Ltd. Internal Crime Policy and Standards Manager as outlined at 5.2.
Completion is defined as the work identified at 7.1.1 to 7.1.9 or at 7.1.1 to 7.1.9 and 7.2.1 to
7.26.

For the avoidance of doubt, where multiple Record Queries are required in support of the
same Outlet / case, the time-scales for completion shall be based upon the actual number of
Record Queries that are undertaken (i.e. 2 Record Queries shall be completed in 14 calendar
days).

7.4 Wide Spread Errors

ICL Pathway will monitor ‘trigger points’, for example HSH calls and the NWB Report set,
which can alert of any likely potential or actual ‘widespread’ errors which may occur. This is
generally agreed to be the case where at least 100 exceptions of the same System State are
reported. In such a case, a problem will be raised and passed from ICL Pathway into the POL
business community.

Should this scenario occur, ICL Pathway Business Continuity Manager will
immediately notify POL Business Continuity M anager of the widespread error. Upon
giving such notice the provisions of this document (other than this section) shall cease

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to apply to that particular widespread error. Instead, a recovery plan applicable to the
specific nature of the error will be agreed by both parties.

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COMMERCIAL IN CONFIDENCE Date: 11-Feb-2002

8.0 Additional Litigation Support
8.1 Expert Witness Statement

To offer all the available evidence without it being requested would only serve to flood the
courtroom with documentation. For this reason expert in depth analysis and detailed “expert”
witness statements (as opposed to witness statements of fact) are rarely required.

It is however conceivable that, given the size and complexity of the Horizon system, the
integrity of the Witness Statements of fact may be challenged by Defence Counsel in order to
discredit a prosecution. In these cases additional, granular detail about the technical working
and integrity of various systems that constitute the Horizon system may be required if only
for “unused material”.

Expert witnesses could comprise anyone within ICL Pathway or its approved contractors who
could be called upon to provide and testify to this additional evidence.

Expert witnesses could be called upon to provide for example:

Operational logs and shift hand over documentation to demonstrate consistent operation
and availability of the service;

Secure NT, Dynix and SecurID definitions;
Details of information flows throughout the system;

Details of cryptographic key controls and other confidentiality, integrity and availability
issues;

Provision of specific Tivoli and other system security event files;
Subsequent analysis of this data.

Whilst this type of detail is specifically excluded from the standard evidential requirements
included at paragraphs 7.2.1 to 7.2.4, ICL Pathway will provide up to 15 man-days effort per
year in support of this granular level of evidence. The production of this evidence shall not be
subject to the time-scales at 7.3 but ICL Pathway shall use best endeavours to meet dates
notified by Post Office for the production of this material.

Support in excess of 15 days shall be considered on production of an appropriate Change
Request. ICL Pathway’s charges for assistance in this respect shall be calculated on the basis
of the rates set out in Schedule A12.

8.2. Court Attendance in support of Expert Witness Statement

A maximum of 15 man-days effort per year shall be provided for attendance at Court in
support of expert witness testimony. Support in excess of 15 days shall be considered on
production of an appropriate Change Request. ICL Pathway’s charges for assistance in this
respect shall be calculated on the basis of the rates set out in Schedule A12.

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COMMERCIAL IN CONFIDENCE Date: 11-Feb-2002

9.0 Access to Audit Trails

Reasonable access to the audit trail of Banking Transactions shall be provided for Post Office
Ltd. Internal Audit for audit purposes. This shall be by request (and reasonable notice) to ICL
Pathway Audit Manager and shall be within the limits agreed in respect of the Existing
Services.

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COMMERCIAL IN CONFIDENCE Date: 11-Feb-2002
10.0 Appendices

10.1 Record Query
10.2 Witness Statement of Fact
10.3 Exhibit Labels

10.3 Prosecution Support Service Levels

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Contract Controlled
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Network Banking Management of Prosecution
Support

COMMERCIAL IN CONFIDENCE

Ref: NB/PRO/003

Version: 0.1
Date: 11-Feb-2002

FUJ00152189
FUJ00152189

10.1 Appendix 1

RECORD QUERY

Originator:

Post Office Ltd Date:

Internal Crime Policy and Standards
Manager

The 4" Floor,
Impact House,
Edridge Road,
Croydon
CR9 IPJ

dd/mm/ccyy

Telephone:

_GRO I Ref No. NB #400

Information Requested

Date range:

(2 week maximum)

Post Office I Name and FAD

Type

Record Query / Record Query &
Witness Statement

PAN

General Description /

Format
requirements:

Specific Details:

Signed

Date dd/mm/ccyy

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10.2 Appendix 2

Witness Statement
CJ Act 1967, s.9: MC Act 1980, ss.SA(3)(a) and SB: MC Rules 1981,r.70)
Statement of:
Age if under 18:____s(if over 18 insert ‘Over 18’)

Occupation:

This statement (consisting of 6 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 I know to be false or do not believe to be true.
Dated the — day of CCYY

Signature:

I have been employed by ICL Pathway for x months. I have been employed as IT Security
Analyst responsible for Audit Data Extraction and IT Security. I have working knowledge of the
computer system known as Horizon, which is the computer system used by Post Office Counters
Ltd. I am authorised by ICL Pathway Ltd to undertake extractions of audit data held on the

Horizon system.

Prior to the system being introduced, Post Offices ran a weekly manual or electronic cash
balance on a counter register system. This was the system in which all transactions performed by
counter clerks would be entered on a daily basis onto their weekly balance sheets or input into
their computer systems. At the end of the accounting period they would amalgamate the daily

transactions, include their stock and cash on hand and arrive at a balance.

Sigmature.........ccsscceseccesseeeesenees Signature witnessed Dy...........cssccesecesecees

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FUJ00152189
FUJ00152189

NOTE: This side B to be completed only when the original statement is overleaf.
When this form is used to make a copy of a statement, side B is to be left blank

Address

Home telephone No: Business Telephone No:

Occupation: Date and place of birth:

Maiden Name: Identity code:
Dates to be avoided. Delete dates of non availability of witness

Month of: Month of: Month of:

1 2 13 I4 15 6 17 1 2 3. /4 I5 I6 7 1 2 13 14 5 I6 I7

8 19 10} 11 I 12] 13} 14]8 I9 10} 11} 12] 13 I 14]}8 [9 10 I 11 I 12 I 13 I 14

15 I 16 I 17 I 18 I 19 I 20 I 21 I 15 I 16 I 17 I 18 I 19 I 20 I 21 I 15 I 16 I 17 I 18 I] 19 I 20 I} 21

22 [23 I 24 [25 I 26 [27 I 28 I 22 I 23 I 24 [25 I 26 I 27 I 28 I 22 [23 I 24 [25 I 26 I 27 I 28

29 I 30 I 31 29 I 30 I 31 29 I 30 I 31

Month of: Month of: Month of:

1 2 13 I4 I5 6 17 1 2 3 /4 I5 I6 I7 1 2 13 14 5 I6 I7

s Jo fiofir fi2fisfiafs [9 fiofir fi2}i3 fia ][s fo fio far fi2 [13] 14

15 I 16 I 17 I 18 I 19 I 20 I 21 I 1S I 16 I 17 I 18 I 19 I 20 I 21 I 1S I 16 I 17: I 18 I 19 I 20 I 21

22 I 23 I 24 I 25 I 26 I 27 I 28 I 22 I 23 I 24 I 25 I 26 I 27 I 28 I 22 I 23 I 24 I 25 I 26 I 27 I 28

29 I 30 I 31 29 I 30 I 31 29 I 30 I 31

Contact point, if different from above:

Address:

Telephone No:

STATEMENT TAKEN BY (print name)

Office:

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Continuation sheet No. 1

Continuation of Statement of:

A new system has been introduced within the Post Office Counters Offices and this is known as
Horizon. Each counter position has a computer terminal, a visual display unit and a keyboard and
printer. This individual system records all transactions input by the counter clerk working at that
counter position. Each clerk logs on to the system by using a series of passwords. The
transactions performed by each clerk, and the associated cash and stock level information are
recorded by the computer system in a stock unit. Once logged on, any transactions performed by
the clerk must be recorded and entered on the computer and are accounted for within the user's

allocated stock unit.

The Horizon system consistently records time in GMT and therefore takes no account of Civil
Time Displacements. The clock incorporated into the desktop application on the counter visual
display units is however configured to indicate local time. This has been the situation at Post
Office Name (FAD ### ###) since dd/mm/ccyy when the Horizon system was introduced at that

particular Post Office.

The Horizon system provides a number of daily and weekly records of all transactions input into
it. It enables Post Office users to obtain computer summaries for individual clients of Post
Office Counters Limited e.g. National Savings Bank, Giro, Driving Licence Agency and Pension
and Allowances. The Horizon system also enables the clerk to produce a weekly balance of cash

and stock on hand combined with the other transactions performed in that accounting period.

The system also allows for information to be transferred to the main accounting department at

Chesterfield in order for the Office accounts to be balanced

Sigmature.........cscccssesseeeeeeeeeeeees Signature witnessed Dy..........scccseeseeeeeeeeee

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Continuation sheet No. 2

Continuation of Statement of:

The Post Office counter processing functions are provided through a series of counter
applications: the Order Book Control Service (OBCS) that ascertains the validity of Benefit
Agency order books before payment is made; the Electronic Point of Sale Service (EPOSS) that
enables postmasters to conduct general retail trade at the counter and sell products on behalf of
their clients; the Automated Payments Service (APS) provides support for utility companies and
others who provide incremental in-payment mechanisms based on the use of cards and other
tokens; the Logistics Feeder Service (LFS) which supports the management of cash and value
stock movements to and from the outlet, principally to minimise cash held overnight in outlets
and the Network Banking Service (NBS). The NBS constitutes the elements of Post Office Ltd's
end-to-end on-line Network Banking Service (supporting banking transactions) for which ICL
Pathway has a responsibility under contract. The counter desktop service and the office platform
service on which it runs provides various common functions for transaction recording and

settlement as well as user access control and session management.

Information from counter transactions is written into a local database and then replicated
automatically to databases on all other counters within a Post Office outlet. The information is

then forwarded over ISDN (or other communication service) to databases on a set of central

Correspondence Servers at the ICL Pathway Datacentres. This is undertaken by a messaging
transport system within the Transaction Management Service (TMS). Various systems then
transfer information to Central Servers that control the flow of information to various support

services including the Pathway Data Warchouse where an historic record of all data is stored.

Signature Signature witnessed Dy...........ecceseeeeeeceeeee

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Continuation sheet No. 3

Continuation of Statement of:

Details of outlet transactions are normally sent at least daily via the system. Details relating to
the outlet's stock holding and cash account are sent weekly. Details are then forwarded daily via
a file transfer service to the Post Office accounting Department at Chesterfield and also, where

appropriate, to other Post Office Clients.

An audit of all information handled by the TMS (the TMS journal) is taken daily by copying all
new messages to archive media. This creates a record of all original outlet transaction details
including its origin - outlet and counter, when it happened, who caused it to happen and the
outcome. The TMS journal is maintained at each of the ICL Pathway Datacentre sites and is
created by securely replicating all transaction records that occurred in every Outlet. They
therefore provide the ability to compare the audit track record of the same transaction recorded in
two places to verify that systems were operating correctly. All exceptions are investigated and
reconciled. Records of all transactions are written to Tape audit archive media. When
information relating to individual transactions is requested, the tapes are loaded onto Audit
Servers and the data extracted via Audit Workstations. Information is presented in exactly the
same way as the data held in the archive although it can be filtered depending upon the type of

information requested.

Where data is stored on a computer, there are no reasonable grounds for believing that the
information is inaccurate because of improper use of the computer, and at all material times the
computer was operating properly or if not, any respect in which it was not operating properly or
was out of operation was not such as to affect the production of audit records or accuracy of their

contents.

The integrity of audit data is guaranteed at all times from its origination, storage and retrieval to
subsequent despatch to the requester. Controls have been established that provide assurances to

Post Office Ltd Security and Network Audit Team that this integrity is maintained.

Sigmature..........ccseccesecceeeceeeeeees Signature witnessed Dy...........ssecseeeceeeeeees

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ICL Pathway Ltd Network Banking Management of Prosecution Ref: NB/PRO/003
Support
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COMMERCIAL IN CONFIDENCE Date: 11-Feb-2002

Continuation sheet No. 4

Continuation of Statement of:

During audit data extractions the following controls apply:

1. Extractions can only be made through the three Audit Workstations (AWs), which exist at
ICL Pathway, Forest Road, Feltham Middlesex and the two ICL Data Centres. These are all
subject to rigorous physical security controls appropriate to that location. Specifically, the
Feltham AW — where most extractions take place — is located in a secure room subject to
proximity pass access within a secured ICL site.

2. Logical access to the AW and its functionality is controlled by dedicated Logins, password
control and utilises the Microsoft Windows NT and Pathway security features defined in the
overall Horizon security policy.

3. All extractions are logged on the AW and supported by documented Record Query Forms,
authorised by nominated persons within Post Office Ltd Security and Network Audit Team.
This log can be scrutinised on the AW.

4. Extractions are only made by authorised individuals.

5. Upon receipt of a Record Query from Post Office Ltd Security and Network Audit Team they
are interpreted by ICL Pathway Prosecution Support Section. The details are checked and the
printed request filed.

6. The required files are identified and marked using the dedicated audit tools.

7. Using the above information the relevant archive tapes are identified.

8. A request to load the tapes at the Data Centre is made.

9. Checksum seals are calculated for audit data files when they are written to Tape and re-
calculated when the files are retrieved.

Signature. .. Signature witnessed by.

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Support

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Continuation sheet No. 5

Continuation of Statement of:

10. To assure the integrity of the audit data while on the DLT the checksum seal for the file is re-
calculated by the Audit Track Sealer and compared to the original value calculated when the

file was originally written to the DLT. The result is maintained in a Check Seal Table.
11. The specific Record Query details are used to obtain the specific data.

12. The files are copied to the AW where they are checked and converted into the file type
required by POIA.

13. The requested information is copied onto removal CD media, sealed to prevent modification
and virus checked using the latest software. It is then despatched to Post Office Limited Internal

Crime Policy and Standard Manager using first class post.

Record Query ## was received on dd/mm/ccyy and asked for information in connection with the
Post Office at Post Office Name - FAD ##i# ### I produce a copy of Record Query ## as
Exhibit XXX

On various dates and at various times between dd/mm/ccyy and dd/mm/ccyy, I undertook
extractions of data held on the Horizon system in accordance with the requirements of Record

Query ## and followed the procedure outlined above.
I produce the resultant CD as Exhibit XXX.

The report is formatted with the following headings:
[To be agreed by Post Office Ltd and ICL Pathway]

The CD (Exhibit XX2) was sent to the Post Office Ltd Security and Network Audit Team section

by first class post on dd/mm/ccyy.

Sigmature........cccscccesecesseeseeseeees Signature witnessed Dy...........ssccceeeceeeseees

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Support
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COMMERCIAL IN CONFIDENCE Date: 11-Feb-2002

10.3 Appendix 3

ICL Pathway Ltd

Signature of Witness: ............00 cece eee eee eeeeeeee ee eeee

Description of Item:
. Exhibit No .

Version 1.0 03/01
ICL Pathway Limited. Registered in England no. 3011561

Registered Office: 26 Finsbury Square, London, EC2A IDS

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Support
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COMMERCIAL IN CONFIDENCE Date: 11-Feb-2002
10.4 Appendix 4
Prosecution Support Service Levels NBPROOO3 I Requests I Service Levels
Reference
500 Tr] RY]

Data Extraction Undertake Record Queries from archived audit data assuming on-line Section 7.1 300

immediate access to data. This involves obtaining the data, sorting as per
(R260/R315) Customer requirement, producing output on media, virus checking and

labelling.
Litigation Support I Production of “Statement of Fact” Witness Statements for 50% of the Section 7.2 250

data retrieval requests at TL

Collation of evidence from Pathway problem management systems

(HSH, PinICL, Non-polling reports ete) to prove the integrity of data

provided in support of Customer prosecutions requires.

‘Attendance at Court by the individual who produced statements to give Section 72 I 100 days)

evidence. (It is assumed that 2/5 of these prosecutions will require a

minimum of one day’s attendance)

Providing additional investigative support to the Customer in analysing Section 8 I” 15 (days)

extracted data.

Additional “expert witness” testimony and analysis where statements of Section 8 I 15 (days)

fact are insufficient. Estimated requirement for provision from within

Pathway and its sub-contractors

Additional Case Based Requirements Section 8 cR
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Contract Controlled