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Message
From: pete.newsomef_ ~ “GRO
Sent: 31/01/2018 11:05:31 - _
To:
cc:
Subject: RE: Legally Privileged: Known Error Log [BD-4A.FID26896945]
OK will send over now.
Pete
Pete Newsome
Account Manager
Post Office Account, Fujitsu UK&I
Fujitsu named as
Responsible Business
of the Year
Fujitsu is proud to partner with Action for Children
CIO: Global Intelligence for the ClO. Fujitsu's online resource for ICT leaders
Sponsors of the 2015 Rugby World Cup
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From: Parker, Steve
Sent: Wednesday, January 31, 2018 11:05 AM
To: Newsome, Pete ¢
Cc: Defence Legal (Chris Jay,)
Subject: RE: Legally Privileged: Known Error Log [BD-4A.FID26896945]
Yes, like it
Steve
From: Newsome, Pete
Sent: Wednesday, January 31, 2018 10:51 AM
To: Parker, Steve < 4 _
Cc: Defence Legal (Chris Jay,) ¢ GRO i
Subject: RE: Legally Privileged: Known Error Log [BD-4A.FID26896945]
Steve
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I have updated the first answer in light of your reply.
Pete
Pete Newsome
Account Manager
Po:
GRO
Tel:
E-Ma
Web: mpzuxraprsureern-~
Web: uk.fulitsu.com
Fujitsu named as
Responsible Business
of the Year
Fujitsu is proud to partner with Action for Children
CIO: Global Intelligence for the ClO. Fujitsu's online resource for ICT leaders
Sponsors of the 2015 Rugby World Cup
= Please consider the environment - do you really need to print this email?
From: Parker, Steve
Sent: Wednesday, January 31, 2018 9:57 AM
To: Newsome, Pete
Cc: Defence Legal (Chris Jay,) <. 3
Subject: RE: Legally Privileged: Known Error Log [BD-4A.FID26896945]
Pete,
We can’t say it’s impossible to export. We make an exported version available to support techs should they be unable
to access a network to use the live version when supporting service out of hours. It is very rarely used, has some
inadequacies in its presentation layer and is clearly out of date as soon as it has been exported. Its use is discouraged
internally for these reasons.
OK with all other answers.
Steve
From: Newsome, Pete
Sent: Wednesday, J
To: Parker, Steve <_
Cc: Defence Legal (Chris Jay,) < GRO.
Subject: FW: Legally Privileged: Known Error Log [BD-4A.FID26896945]
Steve and Chris
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Could you check and if needed adjust my answers to Andy’s questions below.
Thanks
Pete
Pete Newsome
Account Manager
Post Office Account, Fujitsu UK&l
Web: http://uk.fujitsu.com
Web: uk. fujitsu.com
I £I¥inIe/c-
Fujitsu named as
Responsible Business
of the Year
Fujitsu is proud to partner with Action for Children
CIO: Global Intelligence for the ClO. Fujitsu's online resource for ICT leaders
Sponsors of the 2015 Rugby World Cup
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To: Newsome, Pete <¢
Cc: Lenton, Matthew Defence Legal (Chris Jay,) < GRO
Subject: RE: Legally Privileged: Known Error Log [BD-4A.FID26896945]
Pete
This makes sense and I can understand your concerns.
Just to clarify a few points:
1. Are you saying that there is no way to mass export data from the KEL (without having to write bespoke code to
add this functionality)? We currently have no way of exporting whilst keeping the data integrity and ensuring the
security of the system, we could never say there is no way as there are standard ways of extracting data etc.
2. Even if the data could be exported, would it be in a proprietary format that could not be meaningfully understood
without the KEL software? Probably too strong more like, some of the meaning and context could be lost in the
printed version leading to incorrect conclusions being drawn.
3. Is there any way to access the KEL from outside of FJ (eg. could we give Jason Coyne credentials so that he
could login through a web portal?). I appreciate that you may not want to offer this, but I'm looking to understand
whether it is technically possible. Technically possible but against Fujitsu's corporate security policy so not
possible in its current state.
4. You would however be willing for Jason Coyne to come back on site and look at / print more KELs? Yes no
problem, we offered this to him at the last visit.
5. Is there any other reasonable way to provide access to the KEL? I want to make sure that we have exhausted all
possibilities. None we can think of.
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Thanks
A
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP.
WOMBLE womblebonddickinson.com
BOND
DICKINSON v ©
From: pete.newsome@ GRO J
Sent: 30 January 2018 15:53
To: Amy Prime
Cc: Matthew.Lentoné Andrew Parsons; Legal.Defence,
Subject: RE: Legally Privileged: Known Error Log [BD-4A.FID26896945]
Amy, we have major concerns about the release of the KEL software. These are outlined below but the overriding one is
the release into the public domain by virtue of their becoming Court records of our confidential information which
comprises Fujitsu corporate trade secrets and highly sensitive IPR and know-how which could then get into the hands of
our competitors.
For these reasons we are not amenable to releasing the KEL software to Freeth’s.
We would prefer for a solution to be found and for this to addressed in another way than release of KEL software,
particularly as the request does not seem to bear any direct relationship to the Plaintiff's case. We therefore propose a
further visit for Freeth’s IT expert to view KELs and print any that have some relevance to the case. We suggest that
before these are released to the court Freeth’s show the link to any of the cases in consideration.
We use a custom developed solution utilising software developed and owned by Fujitsu that allows us to record
support knowledge into a structure known as a KEL (Known Error Log). KELs record support knowledge generated by the
analysis of incident tickets originating from live and test services, the symptoms seen, actions taken and outcomes.
expected. They can also be used pre-emptively to record general support knowledge not related to a specific
incident. The system recording and presenting the KEL information is developed in-house by Fujitsu for internal use only
and is hosted within a Fujitsu data centre and accessed by a Fujitsu internal network. KELS are created by Support
Executives working at all levels via a web interface using both fixed and free format fields and utilising a mark-up
language to provide information formatting.
After initial creation the content of the KEL evolves over time. KEL information is crowd sourced from any support
executive working on the Horizon system who encounters the symptoms described. As the understanding of the
underlying problem changes, the information on the KEL is revised and enhanced frequently. KEL content may also
change radically as a particular root case is eradicated and a new problem presents the same symptoms as seen during a
previous incarnation of the KEL.
Care must be taken when trying to use KEL information outside the Fujitsu support group environment. The content of
the KEL is proprietary to the Horizon system Proprietary in the sense that the language is often specific acronyms and
shorthand language easily understood by those in the Horizon technical and business community within Fujitsu but may
have different meanings when interpreted by outside readers, e.g. Network is used to mean both the physical
connectivity and as a proper noun to describe all the Post Office branches, the internal user would understand which is
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correct due to the context not immediately assume there was a problem in connectivity.) and uses nomenclature and
language which, while superficially familiar to the layman, is open to misinterpretation without the context of in-depth
knowledge of the Horizon system. KELs may also contain information which is Fujitsu confidential about how the service
is designed, operated and secured. By “confidential” is meant that If this knowledge is in the public domain it would:
1. Give our competitors insight in to how Fujitsu manage complex accounts which is potentially our IPR
2. Give information useful to our competitors on bidding against Fujitsu in any Post Office contracts
3. Expose information which could compromise either the Physical or IT Security of the system
The KEL system was designed for individual usage via its web based interface and not for the mass export of information,
however there is a print option within each KEL. A printed version may not necessarily stand alone. Some of the
additional context gained from following the linkages to associated information is lost once the KEL is printed.
I look forward to discussing this further with you.
Regards
Pete
Pete Newsome
Account Manager
Post Office Account. Fuiitsu UK&l
Tel! I
Web: http: fujitsu.com
Web: uk.fujitsu.com
I £I¥inIe\c-
Fujitsu named as
Responsible Business
of the Year
Fujitsu is proud to partner with Action for Children
I-CIO: Global Intelligence for the ClO. Fujitsu's online resource for ICT leaders
Sponsors of the 2015 Rugby World Cup
= Please consider the environment - do you really need to print this email?
From: Amy Prime [.
Sent: Wednesday, January 17, 2018
To: Newsome, Pete <¢
Cc: Lenton, Matthew;
Legal (Chris Jay,) <_
Subject: Legally Privileged: Known Error Log [BD-4A.FID26896945]
}>; Andrew Parsons Defence
Pete
Freeths have asked if it is possible to provide Jason Coyne with all of the KEL entries (current and historic). They have
not yet provided an explanation as to why all of them are required (and we will be querying this) but it would be of
assistance if you could clarify the technical limitations of extracting the KEL.
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My current understanding is that the KEL is hosted on proprietary software so the entries would only be in a readable
format if you have a copy of the software, otherwise it is necessary for screenshots / printouts of each entry to be provided
by FJ. Further, each entry comprises of multiple tabs (i.e. 1 KEL entry may require 4 or 5 screenshots to be provided) so
producing the screenshots is a labour intensive task.
Please could you confirm:
1. the above is correct and any other limitations you can foresee in providing the KEL to Jason Coyne;
2. an estimated time to produce screenshots of all KEL entries;
3. what software the KEL requires and who owns this software; and
4. whether it would be possible for either Freeths or Jason Coyne to obtain a copy of this software and the KEL to
be transferred to them.
If it would be easier to discuss the above, please feel free to call.
Kind regards
Amy
Amy Prime
Solicitor
Womble Bond Dickinson (UK) LLP
WOMBLE womblebonddickinson.com
BOND
DICKINSON id ©
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