FUJ00234975 - Post Office/ Fujitsu POA Operations Major Incident Procedure manual - V24.0 - Author: Matthew Hatch.

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FUJ00234975

FUJ00234975
POA Operations Major Incident Procedure
FUJITSU FUJITSU RESTRICTED (COMMERCIAL IN CONFIDENCE)
Document Title: POA Operations Major Incident Procedure
Document Ref: SVM/SDM/PRO/0001
Release: HNG-X
Abstract: This document details the POA Major incident processes which

supplements the major incident processes defined in the Fujitsu
EMEIA Business Management Systems Major Incident Procedure
with the Post Office Limited specific requirements or requests.

Document Status: APPROVED

Author & Dept: Matthew Hatch — POA Operations

Internal Distribution: As listed on pages 8 and 9 for
Mandatory Review
Optional Review
Issued for information
External Distribution: For information
Martin Godbold (POL),
Dionne Harvey (POL)
Information Classification: See section 0.10

Approval Authorities:

Name Signature
Steve Bansal Senior Service Delivery See Dimensions for record of approval.
Manager
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0 Document Control

0.1 Table of Contents

o DOCUMENT CONTROL
0.

0.1 Table of Contents
0.2 Document History
0.3 Review Details .
0.4 Acceptance by Document Review.
0.5 Associated Documents (Internal & External)
0.6 Abbreviations
0.7 Glossary.
0.8 Changes Expected .
09 Accuracy....
0.10 Information Classification

INTRODUCTION...

2 GUIDELINES AND INTERFACING TO POST OFFICE ............:sc0008
2.

1 Guidelines...
2.2 Interfacing to Post Office

3 POST OFFICE ACCOUNT DEFINING A MAJOR INCIDENT
3.

3.1 Incident Classifi
3.2 Influencing Factors in calling a Major Incident
3.3. Major Incident Triggers
3. Network Triggers...
Infrastructure Components Triggers
Data Centre Triggers ..
Online Service Triggers .
Security Triggers
GDPR Trigger:

3. Breach Notifical iO
3. Recognising a data breach and collecting evidence. . 20
3. Who decides if it is a data breach?....... 21
3. Supporting a GDPR audit resulting from a breach
3. POL Requested Data Modifications .
3.4 Major Business Continuity Incidents (I
4 CALLING THE MAJOR INCIDENT .........ceeseseeeee +23
5 PROCESS FLOW... +23
6 COMMUNICATIONS +23
6.1 Technical Bridge
6.2 Service Bridge.
6.3 Communication Process Flow
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6.4 Post Office Major Incident Report Requirements
6.5 Escalation Communication Protocol ..
6.6 Requests to Disable/Re-Enable Training Controls

6.6.1 Handling Requests to Disable Training Controls .
6.6.2 Handling Requests to Re-Enable Training Controls
6.6.3 Carrying out requests for Disabling and Re-Enabling Training Controls
6.6.4 Charging the Customer for Disabling and Re-enabling of Training Controls

7 EORMAL INCIDENT CLOSURE & POST INCIDENT REVIEW
7.

7.1 Post Incident Review ....
7.2 The Major incident Report

8 FUJITSU ROLES AND RESPONSIBILITIES DURING A MAJOR INCIDENT....35
8.

8.1 Role of the MAC Team..
8.2 Role of the Major Incident Manager
8.3 Role of the Technical Recovery Manager...
8.4 Role of the Problem Manager
8.5 Role of the Communications Manage
8. Role of the SDUs: (Technical Teams /SMC/MAC & Third Parties)
8.7 Role of the Service Delivery Manager owning the affected service
8.8 Role of the Service Lead/Senior SDM...

9 APPENDICES
9.

9.1 Daytime Duty Manager Contact Details .
9.2 Qut of Hours Duty Manager Contact Details
9.3 POA Service Delivery Contact Details

9.4 Special Situations
Personnel Absenc

QOH
Duty Manager Change Over

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0.2 Document History

Version No, Date Summary of Changes and Reason for Issue Associated Change -

Reference

0.4 03-Oct-06 First draft — to detail the Major Incident Escalation process
Draft taken from Horizon Document CS/PRD/122, V1.0.

1.0 11-Oct-06 Revision following comments from Reviewers

2.0 02-Sep-08 Changes for Acceptance by Document Review: insertion of

Section (0.4) containing table of cross references for
Acceptance by Document Review and addition of note to front
page. No other content changes.

24 24-Feb-2009 —_I Changes made for Acceptance by Document Review by Fiona
Wootfenden including the removal of references to
CS/PRD/074 which has been Withdrawn and replaced by
SVMISD/PRO/0018 and other tidying up changes.

Other changes to update Contact details.

22 44-Apr-2009 I Some Personnel Name changes and POA to POA +
Abbreviations, Security Updates to sections 5.1, 6.3, 8.2.1,
9.0,

23 3-June-2009 I Some Personnel Changes and minor changes following review
in May 2009

3.0 T-July-2009 Following security audit 2 minor changes. Alan Simpson now
on distribution and 6.3, an extra bullet entry added at end of
list

3.0 7-July-2009 Following security audit 2 minor changes. Alan Simpson now
on distribution and 6.3, an extra bullet entry added at end of
list.

34 14-Jan-2010 I Changes following director failing to sign off v3.0, plus minor
contact changes.

4.0 26-Mar-2010 I Approval version

44 18-May-2010 _I Following team restructure, the process has been significantly
reviewed

42 03-Jun-2010 I Updated following minor comments provided during review
cycle of version 4.1. This version will be presented for approval
at v5.0

5.0 07-Jun-2010 I Approval version

6.0 44-Sep-2010 __I Approved version following updates to personnel and table in
10.4 and section 10.8

64 15 July-2011 I Updates to personnel and changes from ‘Process’ to
Procedure’

62 05-Sept-2011 I Updates following changes requested by Bill Membery from
6.1, plus clarification of TRM role

63 14-Oct-2011 I Cosmetic changes mainly changing RMGA with POA and also
updating abbreviations

64 21-Dec-2011 I Updating of details for a Service Bridge

Also some POL requests

Despite this being an internal POA document, all external
comments that can improve the document are considered.

65 16-Jan-2012 Updated, following review and cosmetic changes in relation to
version 6.4
70 02-Jan-2013 Changes in relation to Personnel and also Tower Leads and
other cosmetic changes
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Version No. Summary of Changes and Reason for Issue Associated Change -

CP/PEAK/PPRR
Reference

7A 04-Feb-2013 Changes in relation to Personnel and revisions around
Communications

72 17-Sep-2013 I Major update to align with Business Assurance Management
procedures and for organisational changes.

(This version was originally identified as version 8.1)

8.0 18-Oct-2013 Updated for minor changes from Nana Parry.

8.1 10-Jun-2014 ‘Amended to replace the HSD function with the Atos Service
Desk and replaced IMT references with the MAC team.

Also updated to reflect the introduction of Atos as POL's
Service Integrator.

9.0 14-Aug-2014 __I Implemented minor changes following 8.1 review cycle.

9.1 22-Jan-2015, Optional Reviewers amended to include Chris Harrison &
‘Shaun Stewart.

Section 3.3.5 POLSAP Service Triggers added

Section 10.1 amended to refer to the Major Incident Report
and Post Incident Review Report templates which are now
held in Dimensions

10.0 12-Feb-2015 Minor update to section 9.1 and issued for approval.
10.4 10-Sep-2015 Note added to Section 1.1

General revision to reflect recent organisational changes, the
removal of the Engineering service.

Created table entry 6.13 and section 8.2 to cover the
production and management of multiple versions of the Major
Incident Report

10.2 22-Sep-2015 Minor changes for comments received from informal review
and issued for formal review.

11.0 12-Jan-2016 I Section 4.0 updated, table entry 6.12 amended, other minor
updates and issued for approval. — This Version was
REJECTED in Dimensions.

14 23-Jun-2016 I Section 4, Security Major Incidents deleted. Re-aligned cross
references to section numbering from 5 onwards

11.2 19-Jul-2016 Revised to include feedback from Steve Bansal replacing
Tower Lead with Senior SDM and/or Service Lead and
incorporated changes requested by Bill Membery.

12.0 49-Jul-2016 Approval version

42.4 44-Dec-2016 I Section 3.3.5 POLSAP Service Triggers modified to reflect 5"
October 2016 migration of POLSAP application support to
Accenture.

Section 7.1 modified to include recommendations to share
lessons learnt across Fujitsu, as per the Fujitsu EMEIA
Business Management System Major Incident Procedure
issued on 28" July 2016

12.2 09-Jan-2017 I Removed Sandie's name from optional review -appeared
twice

13.0 42-Jan-2017 I Approval version

13.4 20-Jul-2017 The procedure was checked and updated for CCN1602 CCN1602; CCN1609;
(section 3.3.5 amended to remove reference to Credence), CCNi614

CCN1609 (no change) and CCN1614 (section 3.3.1 amended
to remove reference to the VSAT service)

Revised section 0.5.

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Version No. Summary of Changes and Reason for Issue Associated Change -
CP/PEAK/PPRR
Reference
13.2 12-Sep-2017 Revised section 9.3, Out of Hours Duty Manager Contact
Details,
14.0 12-Sep-2017 I Approval version. Updated link to Dimensions web service,
section 9.1
44.41 31-May-2018 I Major re-write so that the Fujitsu EMEIA Major Incident

Procedure is used as the primary process and this document
contains customer specific process requirements in managing
a major incident. It also contains changes for HDCR changes
and amendment in the Acceptance by Document Review,
section 0.4. Requested internal Fujitsu Document Review

14.2 26-Oct-2108 —_I Section 3.3.6, Security Triggers, updated to include breaches
of Data Protection Legislation

15.0 24-Jan-2019 I Incorporated changes for comments raised by Steve Bansal
and Sandie Bothick.

15.1 09-May-2019 I Section 6.1 Technical Bridge enhanced for the actions
managed by the Major Incident Communications Manager.

15.2 03-August- Following the Major Incident Walkthrough, Section 6.1 Service

2019 Bridge has been reviewed and amended. 1) Timings for

IN/OOH. 2) The part of this section covering TRM (Technical
Recovery Manager.

Additionally, Section 6.2 Service Bridge has been amended in
line with comments from Steve Bansal during the Major

Incident Walkthrough
15.3 25-September- I Following a communication from Phil Boardman and review
2019 meeting added section 6.7 to cover Requests to Disable

Training Controls and to Re-Enable Training Controls. This
new section was required following Post Office Limited signing

CCN1641¢
15.4 28-January Following review meetings with Bill Membery, Sarah Selwyn,
2020 Andrew Hemingway, Steve Evans and Phil Boardman, added

sections 3.3.7 GDPR Triggers, 3.3.7.1 Breach Notification to
POL controller and EMEIA, 3.3.7.2 Recognising a data breach
and collecting evidence, 3.3.7.3 Who decides if it is a data
breach and 3.3.7.4 Supporting a GDPR audit resulting from a
breach. Additionally, following receipt of an update from Bill
Membery and Sarah Selwyn made further amendments

15.5 23-March 2020 I This review was purely for the GDPR section of the document
following the AMEX EPA SSK file incident.

Following being sent out for intemal review, made the low level
changes suggested by Matthew Lenton, Steven Browell and
Steve Bansal to section 3.3.7 and sub-sections. Additionally,
added comments made to me by Bill Membery if the DPO
does not come back or advises not to inform POL to section
3.3.7.1. Following the AMEX SSK EPA file issue added a
comments to sections 3.3.6 Security Triggers and 3.3.7 GDPR
Triggers and 8.4 role of Problem Manager

16.0 01-April 2020 I This review is purely for the section 6.7 Requests to Disable
Training Controls and to Re-Enable Training Controls, which
relates to CCN164%c.

Following a review of the list of authorised Fujitsu people by
Phil Boardman (Fujitsu) the list has been amended in order to
reflect the current people who can authorise this activity, from
a Fujitsu perspective.

Currently awaiting an update from Stuart Banfield (POL),
following a review of the list of POL people who can request
this activity to be performed. Once received, further
amendments will be made to the document.

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Version No. Summary of Changes and Reason for Issue Associated Change -
CP/PEAK/PPRR
Reference

16.0 02-Apr-2020 Approval version

16.1 07-Apr-2020 __I Following a review by Stuart Banfield (POL) in regards to the

POL requestors for section 6.7.1.1 Requests to Disable
Training Controls and to Re-Enable Training Controls, which
relates to CCN164‘c, the required changes have been made.

No other changes have been made to the document and the
changes made relate purely to what has been detailed above

17.0 07-Apr-2020 I For Approval

47.4 20-Apr-2020 I Following a Major Incident Management — Transition to Post
Office Meeting held on the 15th April 2020, conducting a
review of the document in order to replace any reference to
Atos with Post Office as of 1st May 2020.

This included the removal of Atos and the adding of Post
Office to sections 6.4 Major Incident Communication Flow
Diagram and 6.5 Post Office Major Incident Report
Requirements

Additionally, from section 0.5 Associated Documents (Internal
& External) removed ISSC 11 Information Secutity Incident
Management Procedure (ATOS) from the list.

17.2 02-June-2020 I Following a review by Steven Browell made the changes to
section 0.3 Review Details and section 6.7.1. Handling
Requests to Disable Training Controls in line with his
comments.

Following a review by Sarah Selwyn made changes to section
3.3.7.2 Recognising a Data Breach and Collecting Evidence, in
line with her comments

Additionally, with the decommissioning of POLSAP removed
any references and sections related to POLSAP. 3.3.5
POLSAP Service Triggers.

Updated reference to Fujitsu Major Incident Process at 7.1

No other changes have been made to the document and the
changes made relate purely to what has been detailed above.

18.0 03-Jun-2020 I Approval version

18.1 46-Jun-2020 _I Following completing a Pluralsight training course “The State
of GDPR: Common Questions and Misperceptions” made
some minor changes to the section 3.3.8 Recognising a data
breach and collecting evidence. Reviewed with Sarah Selwyn
and agreed changes.

No other changes have been made to the document and the
changes relate purely to what has been detailed above.

19.0 17-Jun-2020 I Approval version

19.1 44-July-2020 I Added a minor change to section 3.3.5 Security Triggers in
relation to using the configuration items to indicate if there are
GDPR, PCI or PCI and GDPR implications

Amended Steve Bansal's job title

No other changes have been made to this document other
than what has been highlighted above.

19.2 01-Sep-2020 I Following a discussion with the GDPR team with reference to
‘communicating to the account about the configuration items
related to PCI & GDPR, added a new configuration to TISNow.
This has resulted in section 3.3.5 Security Triggers in relation
to using the configuration items to indicate if there are GDPR,
PCI or PCI and GDPR implications being updated

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Version No. Summary of Changes and Reason for Issue Associated Change -

CP/PEAK/PPRR
Reference

No other changes have been made to this document other
than what has been highlighted above.

20.0 01-Sep-2020 I Approval version

20.1 08-Oct-2020 I Amended section 8.5 Role of Communications Manager to
include statements about SMS and updating Fujitsu senior
management obligations during technical bridges.

Amended section 3.3.5 Security Triggers with a comment
about password protecting emails with attachments

Amended section 3.3.6 GDPR Triggers with a comment
around updating POL within 48 hours.

No other changes have been made to this document other
than what has been highlighted above.

20.2 21-Oct-2020 I Amended section 8.5 Role of Communications Manager to
include statements about SMS and updating Fujitsu senior
management obligations during technical bridges, to remove
the NB’s as per feedback from Steve Bansal. Amended
section 3.3.5 Security Triggers comment about password
protecting emails with attachments, following feedback from
Steve Bansal

Amended section 3.3.6 GDPR Triggers with comments around
processor and sub-processors to cover what is required and
added contact details, following discussions with Sarah
Selwyn, Bill Membery, Vicki Williams and Phil Boardman

No other changes have been made to this document other
than what has been highlighted above.

21.0 09-Dec-2020 Approved Version

244 30-Dec-2020 Formatting amendments

Section 8.5 Role of the Communications Manager has been
amended to reflect that the MAC team will join the internal
technical bridges and perform this function.

Additionally added the contact numbers for the Fujitsu MIM
team to this section

Minor amendments made following review meetings with
Sandie Bothick and Steve Bansal

No other changes have been made to this document other
than what has been highlighted above.

21.2 19-Jan-2021 Updated following a review by Matthew Lenton
22.0 49-Jan-2021 I Approved Version
22.4 25-Mar-2021 I Amended sections 2.2 Interfacing with Post Office and 8.1

Role of the MAC Team with reference to the distribution list
used by the MAC and SMC teams for sending SMS updates.
This was following a review with Steve Bansal.

No other changes have been made to this document other
than what has been highlighted above.

23.0 07-Apr-2021 Approval version

23.1 09-Apr-2021 I Amended section 3.3.6 GDPR Triggers in line with updates
provided by Phil Boardman around Ingenico and the PBS
Project and rolling out to the Post Office Estate.

Removed Kelly Nash from Optional Review from section 0.3
Review Details and section 9.1 Daytime Duty Manager
Contact Details

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Version No. Date

Summary of Changes and Reason for Issue

Associated Change -
CP/PEAK/PPRR
Reference

No other changes have been made to this document other
than what has been highlighted above.

23.2 27-May-2021 I Amendments to section 3.3.6 GDPR Triggers following
feedback for Steve Bansal. This includes additional
information from Steven Evans around normal and

sensitive data.

Added a link to the Payment and Banking Pilot List to
section 3.3.6 GDPR Triggers.

Following a conversation with Steve Bansal, added
section 3.3.11 POL Requested Data Modifications.

No other changes have been made to this document
other than what has been highlighted above.

24.0 05-Jun-2021

Approved version

0.3 Review Details

Review Comments by :

Review Comments to Matthew Hatch + PostOfficeAccountDocumentManagement.__

Mandatory Review

Role

Name

POA Account Service Director

Steve Bansal

Service Architect

Phil Boardman

POA Acceptance Manager

Steve Evans

POA Information Security Manager

Geoff Baker

POA Senior Ops Manager HNS

Role

Optional Review

Alex Kemp

Name

POA Infrastructure Operations Manager

Andrew Hemingway

POA Business Continuity Manager

Sidharth Kumar

POA Problem Manager

Matthew Hatch

POA MAC & OBC Manager

Sandie Bothick

POA Operations Manager, Systems Management

Jerry Acton

POA Head of Online Services

Sonia Hussain

Solution Design Architect, Web Services

Sarah Selwyn

POA Network Infrastructure SDM.

Chris Harrison

POA Service Delivery Associate

Piotr Nagajek

POA Document Manager

Issued for Information — Please restrict this
distribution list to a minimum

Position/Role

Matthew Lenton

Name

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(*) = Reviewers that retuned comments

0.4 Acceptance by Document Review

The sections in this document that have been identified to POL as comprising evidence to support
Acceptance by Document review (DR) are listed below for the relevant Requirements:

POL NFR DR Document Section Docume!

Acceptance Ref Number

SER-2200 SER-2178 Whole Document

SER-2202 SER-2179 Whole Document

SEC-3095 SEC-3266 3.36 Security Triggers

SEC-3095 SEC-3266 SVM/SDM/PRO/0018 Security Major Incidents
section 8.5

0.5 Associated Documents (Internal & External)

Refereni Version Da Title Source
ARC/SEC/ARC/0001 Security Constraints Dimensions
CS/IFS/008 POA/POL Interface Agreement for the Dimensions

Problem Management Interface

CS/QMS/001 Customer Service Policy Manual Dimensions

EMEIA Incident EMEIA Incident Management Process. EBMS.

Management Process

EMEIA Major Incident EMEIA Major Incident Process EBMS.

Process

EMEIA Root Cause EMEIA Root Cause Analysis (RCA) Process. I EBMS

Analysis (RCA)

Process

PA/PRO/O01 Change Control Process Dimensions

PGM/DCM/TEM/0001 Fujitsu Services Post Office Account HNG-X I Dimensions

(DO NOT REMOVE) Document Template

SVM/SDM/INR/2693 Major Incident Report Template Dimensions

SVM/SDM/PLA/0001 HNG-X Support Services Business Dimensions
Continuity Plan

SVM/SDM/PLA0002 HNG-X Services Business Continuity Plan I Dimensions

SVMI/SDM/PLA/0031 HNG-x Security Business Continuity Plan Dimensions

SVM/SDM/PRO/0018 POA Operations Incident Management Dimensions
Procedure

SVM/SDM/PRO/0025 POA Problem Management Procedure Dimensions

SVM/SDM/SD/0011 Branch Network Services Service Dimensions
Description

SVM/SDM/SD/0023 POA Incident Enquiry Matrix Dimensions

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Reference Version Date Title Source
SVM/SDM/TEM/2531 Post Incident Report Template Dimensions
SVM/SEC/MAN/3807 Post Office Account HNG-X GDPR Directory I Dimensions
DES/GEN/SPE/2756 Horizon Business Data Flows and Interfaces I Dimensions

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

0.6 Abbreviations

Abbreviation Definition

BCP Business Continuity Plan

BMS Business Management System

EMEIA Europe, Middle East, India and Africa

ITIL Information Technology Infrastructure Library
MAC. Major Account Controllers

MBCI Major Business Continuity Incident

MICM Major Incident Communications Manager
MIM Major Incident Manager

MIR Major Incident Report

OOH Out Of Hours

PCI Payment Card Industry (as per Security Standards Council)
POA Fujitsu Post Office Account

POL Post Office Limited

POL ITSD Post Office IT Service Desk

SDM(s) Service Delivery Manager(s)

(NB: Throughout this document SDM refers to a person responsible for the Service,
and the SDM could work in, but not limited to, the Service Delivery, Service Support,
and Release Management or Security teams).

SDU Service Delivery Unit

SLT Service Level Targets

SMC System Management Centre

SMS Short Message Service (as known globally within Mobile Telephone Networks)
ssc Software Support Centre

TB Technical Bridge

TfSNow Hosts Incident, Problem and Change databases

TRM Technical Recovery Manager

0.7 Glossary

Term Definition

EMEIA Business The EMEIA Business Management System (EBMS) is the central library for all
Policy, Process and associated assets which provides Fujitsu with the responsible
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Term Definition

Management System ‘way of working that keeps the company, its employees and the services we deliver
efficient, effective and compliant

Fujitsu EMEIA Refers to Fujitsu Services Holdings PLC, Fujitsu Technology Solutions (Holding) BV
and their subsidiaries, whether they be incorporated within the EMEIA Region or not,
and any other company or organization that is managed by the EVP, Head of EMEIA
Region

T Time of incident occurring

TH3, Time Incident Occurred plus 3 minutes

0.8 Changes Expected

nn

0.9 Accuracy

Fujitsu Services endeavours to ensure that the information contained in this document is correct but, whilst every
effort is made to ensure the accuracy of such information, it accepts no liability for any loss (however caused)
sustained as a result of any error or omission in the same.

0.10 Information Classification

The author has assessed the information in this document for risk of disclosure and has assigned an information
classification of FUJITSU RESTRICTED (COMMERCIAL IN CONFIDENCE).

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1. Introduction

1.1. Purpose

The purpose of this Post Office Account major incident procedural document is solely to supplement the
major incident processes defined in the Fujitsu EMEIA Business Management Systems Major Incident
Procedure with any Post Office Limited specific requirements or requests.

This document outlines the management guidelines to be used for Major Incidents impacting the live
estate in communicating with Post Office Limited.

1.2 Owner

The owner of the Major Incident Management process at the local POA level is the Fujitsu POA Senior
SDM, Problem and Major Incident.

2 Guidelines and Interfacing to Post Office

2.1 Guidelines

It is important to maintain a balance between:
a) Allowing the technical teams the right amount of time to diagnose and impact an incident
b) Avoiding unnecessary alerting of the customer

c) Assessing which incidents are major

2.2. Interfacing to Post Office

« During the MAC Core Hours (Monday — Friday 08:00 — 20:00, Saturday 08:00 — 17:00) and Bank
Holidays 0800 — 1400 excluding Christmas Day. The MAC should be the first point of operational
contact between Fujitsu and the Post Office Service Desk. The SMC are responsible for
escalation of incidents to the POA OOH Duty Manager. The POA OOH Duty Manager may
initiate communications with the Post Office OOH Duty Manger. The SMC operate on a 24 x 7x
365 basis.

e Any activity detailed in this document which is assigned to the MAC team is handed over to the
SMC outside the MAC Core Hours, with the exception of the above.

e The relevant technical teams who are aware of and monitoring a potential major incident must
call the appropriate Major Incident Manager (Duty Manager out of hours) as soon as possible.
This is not limited to major incidents alone, but applies wherever a state other than Business as
Usual has been detected. The Major Incident Manager must in turn communicate the potential
incident, to the POL IT Service Desk for awareness and monitoring-This is usually done via the
MAC team in core hours.

e The Major Incident Manager (or Duty Manager out of hours) is responsible for communicating
both up the Fujitsu organisation and across (see appendix 9.3) to their counterpart in Post Office.
Where this is impractical (e.g. leave, out of hours, unavailable), the initiative should be taken to
jump up the organisation. Of prime importance is that the customer is informed in a timely
manner and at the correct touch point. This communication should be by voice or direct SMS.
The communication should include the date, time, name, nature of the incident, priority, if service
affecting, likely impact, and the Fujitsu owner to contact.

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e The Major Incident Manager (Duty Manager OOH, who covers Monday to Friday 17:30 to 09:00
and from 17:00 Friday though to 09:00 Monday) should also initiate communication using SMS
via the MAC team (see operational hours above.). Outside of these hours the SMS should be via
the SMC. The SMS distribution list used is titled ‘POASeniors' using the trigger **POA** in hours
by the MAC team and ‘POA Seniors out of hours by the SMC and amongst others includes the
appropriate members of the POA Operations Management Team.

3 Post Office Account defining a Major Incident

3.1 Incident Classification

As a general rule a Major Incident will be an incident rated as a Business Critical Incident as shown in the
following

- The ‘CONTRACT’
- Sections 3.2 and 3.3 below.
- POA Operations Incident Management Procedure document (SVM/SDM/PRO/0018).

- A series of connected lower priority incidents which combine to have a significant business
impact.

However not all incidents rated as priority 1 qualify as a Major Incident as the priority levels do not always
reflect the overall business impact to POL. For example a single counter post office which is unable to
trade, regardless of its business volumes, is rated as a priority 1 incident.

For incident classification on Post Office Account refer to the POA Incident Enquiry Matrix
SVM/SDM/SD/0023.

3.2. Influencing Factors in calling a Major Incident

It is important that a Major Incident is defined in accordance with section 3.3 Major Incident Triggers, as
such, because of its business impact on the day when it occurs, rather than simply being defined as a
Major Incident because it appears on a list. However the following parameters will also feed into the
consideration of whether a major incident should be called:

e Duration, i.e. how long has the vulnerability to service already existed?

e Impact across the estate, including consideration of whether a service is merely degraded or
actually stopped

e Time at which the event occurs in relation to the 24 hour business day

e Time of year — e.g. Peak Trading Period, Christmas / Easter / End of month / quarter
« Anticipated time before service can be resumed

e Impact to POL branches, customers, clients or brand image

e Business initiatives e.g. product launches

3.3 Major Incident Triggers

The following criteria could trigger a major incident, however as detailed in 3.2, the influencing factors
must also be considered. As such the list below is not exhaustive, whilst if an incident occurs which is
not detailed below, e.g., legislative, it should not necessarily be precluded from being declared a major
incident.

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It should be noted that any call trends in relation to the following, should be reported to the POA Duty
Manager as soon as the agreed threshold levels have been breached.

3.3.1 Network Triggers
Network Major Incident triggers are as follows:

e Complete or significant outage of the Central network, e.g. failure of both 3750 stack Catalyst
switches in totality for the Core layer in IRE11.

3.3.2 Infrastructure Components Triggers
Infrastructure component Major Incident Triggers are as follows:
e Total loss of environments providing individual online service capability
¢ Breach of access to data centres
« Breach of security
e Virus outbreak.

3.3.3. Data Centre Triggers
Data Centre Major Incident triggers are as follows:
e Network / LAN outage
e Loss of Data Centre, or significant loss of Data Centre Components

e Breach of security.

3.3.4. Online Service Triggers
Online services Major Incident Triggers are as follows:
e Online service unavailable within the Data Centre (not counter level)
e Third party provided service failure —- e.g. DVLA, Link, Moneygram, Santander etc.

N.B Once the third party service provider has been deemed to be the source of the Major
Incident; it will be managed by either POA or POL IT Service Desk in accordance with whichever
organisation manages that supplier relationship.

3.3.5 Security Triggers
Security major incident trigger examples are as follows:

e Actual or suspected attacks on the Fujitsu Services Buildings and its resources, POA Network or
Information Systems

e = Theft of IT equipment / property
° Theft of software

e Either Cardholder Data or Sensitive Authentication Data not being handled as described in the
CCD entitled “Security Constraints” (ARC/SEC/ARC/0001) or as required by PCI -DSS. For
example (AMEX) American Express sending EPA files such as the SSK file that does not
conform to the AIS (Application Interface Specification)

e Breach of Data Protection Legislation — inclusive of the GDPR, the Privacy and Electronic
Communications (EC Directive) Regulations 2003 and all other Applicable Law in respect of data

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protection and data privacy including any applicable guidance or codes of practice that are
issued by the Information Commissioner, Working Party 29 and/or the European Data Protection
Board (and each of their successors);

In the event of a Security Incident, minor or major (which also include GDPR and PCI Incidents), the POA
Operational Security Manager MUST be informed.

The POA Incident Management procedure SVM/SDM/PRO/0018 Appendix A provides further guidance
on security incidents and the contact details for the POA Operational Security Manager is contained in
Appendix B.

From a corporate perspective the Fujitsu EMEIA SECURITY INCIDENT REPORTING PROCEDURE is
to be followed.

If the Security Incident has been confirmed to be a GDPR Incident, minor or major please follow the
GDPR process. Also, please add the appropriate configuration item to the incident i.e. GDPR, PCI or
PCI and GDPR. This will allow us to report against any incident where GDPR and/or PCI breaches have
been identified.

In the event of a Security Incident, minor or major (which also include GDPR and PCI Incidents), the POA
Operational Security Manager MUST be informed. It is good practice for any attachments that are being
shared internally via email or sent onto the Post Office following investigation, are password protected, in
order to reduce the risk of a security incident including breaching GDPR or PCI legislation. This is
included in the POA Security Operations Guidance Page

3.3.6 GDPR Triggers

If anybody on the Post Office Account or sub-contractors suspect that a GDPR incident has occurred,
then the Fujitsu Security Operations (CSPOA) team need to be engaged immediately, even out of hours.

When the Fujitsu Security Operations (CSPOA) team have determined or suspect that a GDPR issue has
occurred and that the Major Incident Process needs to be followed:

GDPR major incident triggers\considerations are as follows:
e Is this personal data
e What type of personal data

» Normal Personal data (This is information that relates to an identified or identifiable
individual) Please use the link below:

What is personal data? I ICO.

>» Sensitive/Special Personal data (Special category data is personal data that needs more
protection because it is sensitive) .Please use link below:

Special category data I ICO
» What is the data shared on, processed on or transmitted through

e Has the data come from a 3 Party or the Customer. For example (AMEX) American Express.
sending EPA files such as the SSK file that does not conform to the AIS (Application Interface
Specification)

e Has data been lost in the Fujitsu domain that can't be explained

« Fujitsu are accountable for ensuring that Fujitsu sub-processors comply with GDPR/PCI
legislation and standards.

If the answer to the above questions has confirmed that there has been a GDPR incident, then the
process that should be adhered to is as follows:

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e POA Duty Manager has identified a GDPR incident (suspected GDPR breach), during the
management of an incident.

e In Hours there is a requirement to inform the Fujitsu Security Operations (CSPOA) team, and the
Fujitsu GDPR team that currently consists of (Steven Evans and Sarah Selwyn)

e Out of Hours there is a requirement to inform the OOH Contact for the Fujitsu Security
Operations (CSPOA) team

e In hours Fujitsu Security Operations (CSPOA) team, Fujitsu GDPR team that currently consists
of (Steve Evans or Sarah Selwyn) in conjunction with the relevant SME, are required to raise an
incident via the EMEIA Connect Security page

e Out of Hours the CSPOA team are required to raise an incident via the EMEIA Connect Security
page

IRRELEVANT

e In hours a call to the EMEIA Alerts and Crisis Management team using the telephone number
required. This is performed by a member of the GDPR team Steven

Evans and Sarah Selwyn)

e Fujitsu GDPR team that currently consists of (Steven Evans and Sarah Selwyn) in conjunction
with the EMEIA DPO team investigate the root cause analysis of a GDPR suspected breach
within 24 hours so Post Office Limited can be informed within the required 48 hours window This
is also covered in the POA Security Local Work Instructions (SVM/SEC/WK\I/3119)

e Ifthe GDPR\PCI trigger is as a result of a sub-processer such as TNS, FCIL or Ingenico etc. then
they are responsible for contacting the POA Duty Manager within 4 to 8 hours of noticing a
potential breach. Then the POA Duty Manager engage OOH the CSPOA OOH contact and In
Hours the Fujitsu GDPR team that currently consists of (Steven Evans and Sarah Selwyn). This
timescale is so that Fujitsu can notify POL within the agreed 48 hours.

e If Fujitsu consider a breach impacts a sub-processor then Fujitsu have a responsibility to notify
the sub-processer within 24 hours.

e In hours the Fujitsu MAC team will need to log an incident with the POA IT Service Desk and
OOH the POA OOH DM will need to engage the POL OOH MIM

¢ For useful information such as the Document Asset List, which is contained in the Purchase and
Asset Management area on Sharepoint, please refer to the link below:

Purchasing and Asset Management

e For Ingenico service desk and escalation details please refer to section 3.1 Ingenico Service
Desk and Escalation Contacts within the Post Office Operations Manual for Ingenico.

Please refer to the link: Post Office Operational Manual Ingenico and the table on the next page:

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The tables below details the Ingenico Service Desk contacts details including escalation contacts

everity

24x7x365

All Other Support:
08:00 — 20:00 Mon-Fri
Portal: https://my.services.ingenico.com 08:00 — 17:00 Sat

Ingenico Service Desk

(sPoc) Email: axissupport.ul

08:00 — 14:00 Bank Hols
Closed Sunday &

Christmas Day

2 Carolanne Calderhead Monday to Friday
Service Desk Manager 08:00 — 18:00

3 I Caroline Black Monday to Friday
Head of Customer 08:00 — 18:00

Success

4 David Allan Monday to Friday

Director of Customer I Mobiles GRO Hi 08:00 - 18:00

Operations .
Hl Ema

NB Level 3 Caroline Black might be subject to change. Awaiting update from Ingenico.

e If the incident has GDPR/PCI implications please ensure that the email to the Ingenico Service
Desk includes a statement that the issue is escalated appropriately.

o Fora list of PBS Banking pilot sites and Tranches please use the following link:
PBS Banking Pilot List

Support of Payment Banking Service will be from the deployment of the Model Office counter.

e If Ingenico have a Major Incident they will inform the Fujitsu MAC team, who will be responsible
for advising the Fujitsu Daytime Duty Manager and logging with the POL IT DSD team. Out of
Hours Ingenico will contact the Fujitsu OOH Duty Manager, who will be responsible advising POL
OOH Duty Manager and arrange for the SMC to e-bond an incident to the Post Office.

e For TNS please use the TNS NOC contact details below:

«Transaction Network Services

* Contact Number!) ‘Option 1)
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* Email Address: PSDNOCt_

e If the issue needs to be escalated then the above number can be used.

e For the FCIL please contact Moloykumar using the details below:

Telephone number

e For the FCIL if Moloykumar is unavailable, please contact Sreevardhan Reddy using the details
below:

e Telephone number

e Post Office Limited have 72 hours from being informed of a suspected GDPR breach to notify the
Ico.

Please see below sections for information on Breach Notification to POL controller and EMEIA

3.3.7. Breach Notification to POL controller and EMEIA

If the Fujitsu Problem and Major Incident team require to contact the Post Office data protection team,
particularly where root cause analysis of a suspected breach is being undertaken, the email address
can be used as a point of escalation as this mailbox is continually

monitored:

Data processors (POA and POA sub-processors) must understand what personal data is contained
within any data that has been lost, stolen, altered without permission, been subject to unauthorised
access or is unavailable to the data subject that requires access to it etc.

POL have confirmed that the current Horizon Incident Management Process is to be used in the case of a
suspected GDPR data breach and POL will determine if the incident is a GDPR breach.

In the event of a breach POA are to:
1. Follow the Major Incident Management process as below

2. Make sure if it is deemed a GDPR incident that the Fujitsu EMEIA Security Process is invoked via
this link: EMEIA Breach Notification Policy Link_and ensure that the EMEIA DPO has authorised
a decision to notify POL of a breach before notify POL

3. Ifinstruction to not notify POL by the EMEIA DPO, then do not proceed with notifying POL and
leave as an internal incident.

4. If EMEIA DPO does not provide feedback within the 24 hour window, then proceed with notifying
POL.

5. Immediately (within than 24 hours from discovery) inform POL in order that they can determine if
itis a GDPR breach. POL will notify the ICO and, if appropriate, the impacted data subjects
(under article 33 of GDPR legislation POL have 72 hours from becoming aware of the breach to
notify the ICO of the nature of the breach and the containment plan).

SVM/SDM/PRO/0018 Appendix A provides further guidance on security incidents and the contact details
for the POA Operational Security Manager are contained in Appendix B.

The POA Security Management team will follow:
SVM/SEC/WKI/3119 - POA Security Incident Management Work Instruction
e Suspected data breaches must be notified to POL within 24 hours (GDPR article 33(2) processor
to inform controller of breach without delay). During business hours please contact the Post

Office S:
who will triage the incident and forward onto the data protection team
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ii in Hours if required.

. _1as well

tin order for the Post Office data protection team

} _} to be informed if required after being triaged
. ‘OOH the Post Office Duty Manager's will add the data. protection},
address into any relevant communications.

NB: data. protection! "GRO iH can be used as a point of escalation as this mailbox is

continually monitored

3.3.8 Recognising a data breach and collecting evidence

How do you decide if it is a suspected data breach? There is a set of criteria defined by the Working
Party 29.

As per the Working Party 29 (Independent European working party that deals with issues related to
protection of privacy and personal data) Guidelines on personal data breach notification, a security
incident falling within one or more of the following categories should be considered a personal
data breach:

1. unauthorised or accidental disclosure of, or access to, personal data (a “Confidentiality
Breach”)

2. unauthorised or accidental alteration of personal data (an “Integrity Breach”);

3. accidental or unauthorised loss of access to, or destruction of, personal data (an “Availability
Breach”).

As above the Working Party 29 is now known as the European Data Protection Board.
NB: Please refer to the SVM/SEC/MAN/3807 GDPR Directory (Post Office HNG-X Account GDPR

Directory) held in Dimensions, for details of the Working Party 29 Guidelines. Please refer to sections
2.1.2 and 2.1.3 of the GDPR directory.

ind refer to the document

The following information sources identify personal data content:

See ‘GDPR Capability Statements’ for high level information on personal data content defined for
each Business Stream type in POA SharePoint: GDPR Capability Statements.

eSee ‘GDPR Account Data Mapping’ and filter on the personal data and special category data
columns in POA SharePoint. Use this spreadsheet in combination with DES/GEN/SPE/2756
‘Horizon Business Data flows and Interfaces’ in order to see the business flows in context and
understand the interface numbering used in the spreadsheet. This spreadsheet also contains the
names of the interface specifications that hold in detail the data elements within files (POL is yet
to highlight personal data in these POL documents)

See Section 5 of SVM/SEC/MAN/3807 ‘Personal Data Summary’.

Post Office are likely to ask POA for technical support in their report of the suspected breach to the ICO
in at least the following areas:

eThe nature of the suspected breach — what personal data has been impacted and how
oWho accessed what data (content and artefact e.g. log, data file, device etc.) and when

oWhat category is the suspected data breached

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oHow many data subjects are suspected to be impacted and what category are these data
subjects (since Horizon is transaction based it may be difficult to supply the number and
category of data subjects but by inspection of data, where available, a best guess should
be attempted. This may involve ATOS where the data has been collected via AP-ADC at
the counter)

oHow many records are suspected to be involved
oWho are the suspected impacted data subjects
o Whether the data has been replicated elsewhere e.g. Skype, e-mail, TFS Now, Peak

eWhat is the estimated impact of the suspected breach on data subjects (i.e. what is the risk to data
subjects whose data is breached)

Containment plan
«Remediation Plan
«What was done to prevent the suspected breach (security controls in place)
POA Operational Security will guide POA technical teams on gathering the above evidence.

Ensure suspected breaches and evidence collected is recorded (even if POL don't deem the incident as
a GDPR breach). This evidence must be securely stored (encrypted) under the control of POA
Operational Security and must reference the original TfSNow incident.

A useful webpage is the Information Commissioners Office, provides checklists that are useful. Please
use the following link: https://ico.org.uk/for-organisations/guide-to-data-protection/

For additional information and guidelines for areas such as breach notifications a useful link is:
https://ec.europa.eu/newsroom/article29/news.cfm?item_type=1390

3.3.9 Who decides if it is a data breach?

Post Office will ultimately determine using the evidence POA supply whether the incident is a GDPR data
breach. Prior to notifying POL and passing POL the evidence POA and EMEIA DPO will analyse the
evidence to determine if a breach has occurred.

See the EMEIA definition of data breach document link below. This document states that ‘only the
EMEIA DPO can authorise a decision to notify’ the controller of a breach

The EMEIA Definition of Personal Data Breach and Legal DPO Personal Data Breach Guidance
documents can be accessed via the link:

3.3.10 Supporting a GDPR audit resulting from a breach
Please see section 2.6 of the document GDPR Directory (SVM/SEC/MAN/3807).

3.3.11 POL Requested Data Modifications

This new section is required following a review by the team and discussions with Post Office with regards
to the 3 POL approval process.

As part of investigating an incident there may be a requirement to modify or delete data to resolve the
incident. In this scenario, whereby the need for data to be either modified or deleted has been identified
through internal investigation or in conjunction with Post Office representatives such Service
Management, POL Major Incident team or POL Supplier, there is a process in place to request three Post
Office Approvals. These are from Service, Security and the FSC.

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It is the Post Office's responsibility to collate the three Post Office approvals and clearly state the
requirements being requested of Fujitsu. This may be relevant to an incident or change, the requirements
can be updated on the tracking incident call and the relevant performed. This is usually the responsibility
of the Post Office IT Digital Service Desk, but on some occasions the Post Office MIM or Service
Manager on the technical bridge will arrange for these approvals to be given prior to Fujitsu proceeding
with any actions requested of them.

It is the responsibility of the POA Duty Manager or the Senior Service Delivery Manager to check what
data is being requested to be modified or deleted and that the three POL approvals detail the
requirements unambiguously to allow Fujitsu to perform and complete the request Following this review
authorisation to the relevant support teams needs to be given by the either the Senior Service Delivery
Manager or above in order to safeguard the POA Duty Manager. If approval can't be given and
clarification is required from Post Office then there may be a requirement for the three Post Office
approvals to be requested again.

On some occasions the modifying or deleting of data may come via the Ad-Hoc Report Request or OBC
process, which again requires the three Post Office Approvals. Additionally, this needs to be checked by
the Senior Service Delivery Manager or above to safeguard the POA Duty Manager and approval to
proceed needs to be provided before any works commence.

Also, whichever support team such as the SSC, UNIX or Security team who are performing the activity
will need to conduct an internal impact assessment and then provide confirmation that the actions to be
undertaken will not cause an adverse impact on the relevant environment i.e. LIVE. Additionally, there
might be a requirement for the relevant Development or Architectural resource to review the impact and
provide a statement prior to commencement of any works requested by Post Office.

Validation checks following the deletion or amending of data will need to be clearly defined by the
Support, Development or Architectural resources before the POA Duty Manager or Senior Service
Delivery Manager provides approval to proceed.

If the App Support permission is required then there is a process in place whereby the MAC team raise
an incident into the Security team, so it is clear audit that this permission is being requested, rejected,
approved and then removed once the works are completed.

The MAC team have local work instructions for the process that is required by them in regards to the
three Post Office Approval process. Please refer to SVM/SDM/WKI/3670 (MAC Team Work Instructions —
Section 14.0)

The POA Security Operations team have a local work instruction for the processing of App Supp access.
Please refer to SVM/SEC/PRO/0012 (Post Office Account User Access Work Instructions - section 4.2.3)

3.4 Major Business Continuity Incidents (MBCI)
For HNG-X the MBCI triggers are listed in:
e HNG-X Support Services Business Continuity Plan (SVM/SDM/PLA/0001)
* HNG-X Services Business Continuity Plan (SVM/SDM/PLA/0002)
« HNG-X Security Business Continuity Plan (SVM/SDM/PLA/0031)

These documents should be referred to as appropriate in the event of Major Incident to determine if
Business Continuity needs to be invoked.

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4 Calling the Major Incident

During business hours the Major Incident Manager declares and manages the Major Incident (with
handovers to the POA OOH Duty Manager where applicable.)

Where the impact of the incident is not immediately obvious, and it is not clear if a Major Incident should
be called, escalation and discussion with the POA Operations Management Team should occur, and a
collective decision made. If a Major Incident is not called, the incident should be monitored until closure,
to ensure that the impact does not increase to that of a Major Incident.

In the event that multiple services are impacted, multiple Major Incident Managers may be appointed by
any Service Lead or Senior SDM and will remain in their roles until incident closure.

Out of hours the POA OOH Duty Manager is responsible for declaring a Major Incident.

Section 8 of this document specifies the roles and responsibilities during a major incident. The Major
Incident Manager, see section 8.2, is referred to the Manage Major Incident Procedure and must
endeavour throughout the life of a major incident to adhere to the principles of that procedure.

5 Process Flow

As stated in section 1.2 Purpose, this Post Office Account Major Incident Procedural document is solely
to supplement the major incident processes defined in the Fujitsu EMEIA Business Management
Systems Major Incident Procedure so please refer to the EMEIA procedure and utilise the templates
provided within that procedure. These include the Major Incident Report and e-mail templates.

Section 6.3 of this Post Office Account process details the normal Major Incident Communication Flow
agreed with Post Office

When initiating the Major Incident Report, as required by the Fujitsu EMEIA Business Management
Systems Major Incident Procedure, take into consideration the Post Office specific reporting requirements
detailed in the Post Office Major Incident Report Requirements contained in section 6.4 below.

6 Communications

6.1 Technical Bridge

This is a Fujitsu technical conference for Technical experts and SDU's to discuss and analyse the
incident and to formulate an action plan to restore the service to POL without delay. It should enable the
Technical Recovery Manager to baseline the anticipated response, covering resolution, time and
resources required. This will also include the appropriate owning SDU of the service affected by the
Major Incident.

The Technical Bridge will be set up as required by the Major Incident Manager.

Invitations to the Technical Bridge will be via SMS, email or voice. The SMS will be sent to the distribution
list titled “SMS Technical Bridge’. The SMS text will be sent to technical experts on the POA and will
include outline details of the Major Incident. Also dial in details and the start time will be provided as part
of the meeting invitation.

The Technical Bridge will be started at T + 15 from the trigger, and reconvened at regular intervals during
the Major Incident; the exact scheduling will be discussed and agreed at each preceding Major Incident
Call. The timing of “T+15” for calling a Tech Bridge is for IN Hours only. For OOH the Duty Manager will
be contacted (1 hour reasonable endeavours for response).

The Technical Bridge is chaired by the Major Incident Manager with the recovery managed by the
Technical Recovery Manager.

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The Major Incident Communications Manager (MICM) is responsible for ensuring that updates, e.g.,
internal POA or SMS messages to a wider audience are provided at regular intervals, ideally every 30
minutes or longer if an appropriate ETA for the next update relevant to the recovery actions is given.

The MICNM is also responsible for ensuring that the Major Incident within TfSNOW is updated at regular
intervals throughout the major incident, including relevant Technical Bridge updates, for audit trail and
report writing purposes.

A request for a Technical Recovery Manager (TRM) will be made to the appropriate Service Delivery Unit
or Development Leads, who will appoint the appropriate resource to be the TRM. Ideally this nomination
is made at the start of the Technical Bridge and will be a SME and a person who is expected to drive to
the resolution. Throughout the Technical Bridge and resolution of the incident, the individual may change
during the bridge and evolvement. Also, there is a possibility that the role could be reassigned to different
individuals.

Following each Technical Bridge, it is the responsibility of the TRM to agree any actions as follows
-Recovery / restoration actions (which should normally include the TfSNow Change numbers),
-Service Improvement Plan recommendations
-Risk Register recommendations
-Recommendations for any improvements to KB/ Alerting / Configuration changes

The above will be documented in the Major Incident Report which is produced using the MIR Report
template contained within the Fujitsu EMEIA Business Management Systems Major Incident Procedure

6.2 Service Bridge

This is a service focussed call for Service Management (including the Technical Recovery Manager if
appropriate) and POL to discuss the service impact of the Major Incident and to receive updates on the
progress towards resolution. Post Office Major Incident Management may also be the initiators of a
Service Bridge.

The purpose of the Service Bridge is to provide a focussed area from which strategic decisions can be
made regarding a Major Incident.

As a guide the attendance could be made up of the following or their designated representative
depending upon if the incident occurs IN/OOH:

e Post Office (Personnel as instructed by Post Office Major Incident Management or Live Systems
Service Manager)

e The Senior SDM (Chair Person)
* POA Duty Manager IN/OOH
« POA other Service Leads or Senior SDMs
e POALead SDM, Problem and Major Incident
e POA Security Operations Manager (If required)
e POASDM owning the affected service
e Third Party Executives (if appropriate)
Service Bridge responsibilities include:
e Agreement of a containment plan
e Documentation of all agreed actions and timescales with owners

e Consistent management of the Major Incident across all the locations involved

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* Management of potential Major Business Continuity Incidents (MBCI’s) within Post Office and
the POA

e Co-ordinate meeting times and locations

In the event of a Major Incident requiring a Fujitsu Service Bridge, it is envisaged that this will be in place
at T+60 (or earlier if required by Post Office MIM). Participants required in the Service Bridge will be
contacted via SMS as appropriate.

The Senior SDM will send out a text via the MAC team or SMC in order to organise a Service Bridge.
Invitations to the Service Bridge will be via SMS, email, voice or Microsoft Teams.
The SMS text should state such details as;

oAn outline of the ongoing incident

oDial in details

oStart time.

The chairperson's code for voice only calls as a backup is available via the Duty Manager. The TRM will
attend meetings as required and provide appropriate root cause analysis and corrective action detail.

In the event that Post Office MIM initiate the Service Bridge, they should provide the contact details via
the POA Duty Manager for internal distribution.

6.3 Communication Process Flow

« On suspicion or confirmation of a Major Incident, the MIM will escalate to the Senior SDM for the
area, Problem and Major Incident Management SDM, and to the POA Service Leads.

e The MIM will inform the Post Office Service Desk, via the MAC team, of the start of the service
incident alerting of potential issues — including date, time, nature of the incident, priority and
impact if known and then directly inform the Post Office Live Service Manager

e All updates to the POL IT Service Desk are via the MAC team, within agreed timescales
controlled by the MICM

« The MICM will issue an SMS text to the POA via the MAC team, alerting of potential issues —
including date, time, nature of the incident, priority, impact and name

« APOA Service Lead or Senior SDM will inform the following within 10 minutes of start of the
service incident
o POA Delivery Executive
o POL Senior Service Delivery Managers
And will coordinate and ensure consistency of response to Post Office and POA Senior
Management via The Service Bridge

e Periodic (interval to be determined depending on the nature of the issue but not more than 30
minutes for Major Incidents) SMS updates to be sent to the original SMS Distribution list

e On final service restoration, an SMS text message must be sent to the original SMS Distribution
list

« The POA Senior SDM, will confirm understanding of Major Incident closure with Post Office
management and POA senior management, and agree next steps.

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Figure 1: Major Incident Communication Flow Diagram

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6.4 Post Office Major Incident Report Requirements

POL agreed template to base MI updates on.

Questions POL need to understand

What has happened?
Where in the system has a fault occurred?

\/s this in the Fujitsu domain or third party?

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6.5 Escalation Communication Protocol

The primary principle:

“Up and Across”

Example:

The Major Incident Manager would escalate up to POA Lead SDM, Problem and Major Incident
Management, and across to the Post Office Service Desk.

6.6 Requests to Disable/Re-Enable Training Controls

Training Controls have been added to the HNG-A/X Applications, which control the roles that Counter
Users are able to logon with and the products that they can trade when logged on. Training Controls
manage access in accordance with training curricula data provided by POL's identity management
system. POL have expressed concerns that the training curricula data that they provide could be mis-
entered or corrupted by the systems providing it (supplied by Accenture) so as to cause a
catastrophic/wide-spread loss of access to HNG-A/X Users.

One approach to resolving such a situation would be for POL to Request that POA disabled Training
Controls, completely, and then re-enable the Controls once the training curricula data had been
corrected. Should such a situation arise, it is likely that it would be recognised during a Major Incident
Service Bridge call. Similarly, it would be during a Major Incident Service Bridge call that POL would
decide on Training Controls disablement, over any other courses of action to resolve (e.g. correcting the
data in their identity management system or continuing with limited trading).

N.B. POL requesting us to disable Training Controls during a Major Incident Service Bridge call is NOT
sufficient authorisation to action that request (see below)

6.6.1 Handling Requests to Disable Training Controls

Whilst discussions for requesting disablement of Training Controls might have occurred during a Major
Incident Service Bridge, disablement should not be carried out until a formal authorised request has been
received.

During the Major Incident service bridge call, should the decision be made to disable Training Controls,
the Post Office signatory who will issue the request to disable Training Controls will be identified to
Fujitsu Services. To enable the Post Office signatory to make the request, after the Service Bridge call
POA Duty Manager will send an email to the identified Post Office signatory requiring Post Office to issue
Fujitsu Services with instructions to make a Request to Disable Training Controls and subsequently a
Request to Re-Enable Training Controls.

The email will contain the text below:

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On the recent Service Bridge Call, it was indicated that Post Office Ltd. would wish to request
disablement of Training Controls in HNG-X Systems and you were identified as the authorised Post
Office signatory who would raise the request. The instructions for requesting disablement and re-
enablement of Training Controls are shown below.

N.B. Please retain this email until after any Request to Re-Enable Training Controls has been issued.
To Request to Disable Training Controls
“Reply All” to this email, copying and pasting the text in the paragraph below into your reply;

Post Office hereby request that Fujitsu Services temporarily disable Training Controls
in HNG-X Systems with immediate effect until such time as Fujitsu Services receives
awritten Request to Re-Enable Training Controls from Post Office.

To Request to Re-Enable Training Controls

Whenever the decision is made to re-enable Training Controls, “Reply All” to this email, copying and
pasting the text in the paragraph below into your reply;

Post Office hereby request that Fujitsu Services re-enable with immediate effect
Training Controls in HNG-X Systems, previously disabled.

Regards, Fujitsu Post Office Account Duty Manager

6.6.1.1 Recognising Requests to Disable Training Controls
In order to be an acceptable Request to Disable Training Controls, all of the following must be true;

e The expectation that POL would issue a Request to Disable Training Controls must have been
expressed during a Major Incident Service Bridge Call. We should not accept “unexpected”
requests to disable Training Controls. Any such requests received should be returned to the Post
Office Limited IT Service Managers during normal working hours and not processed further. OOH
please refer to the OOH Rota supplied by Post Office Limited for the Post Office IT and Post
Office contact details and communicate with them and do not proceed any further.

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e The request should be communicated on email to:
o POA Duty Manager -

o Steve Bansal -

o Sonia Hussain -i

e The emailed request should be received from one of the Post Office Limited IT Service
Managers;

o Head of IT Service — Finance, Ops and Central - Paula Jenner

o Heads of Service — Retail — Martin Godbold

o Head of IT Service — Financial Services and Telecoms - Mark Nash
e The following deputies can also provide authorisation in a case where none of the

above 3 were available:

o Head of IT Service — FS & NS - Nick Baker

o IT Service Design and Assurance - Stuart Banfield

o IT Service Transformation Lead - Andy Jacques

o IT Security & Service Director - Ben Cooke

o IT Change Manager - Cherise Osei

o Senior Service Manager (Retail) - Lorna Owens

o Senior Service Manager - Matt Quincey
e The emailed request should include the following text:

“Post Office hereby request that Fujitsu Services temporarily disables Training Controls
in HNG-X Systems with immediate effect until such time as Fujitsu Services receives a
written Request to Re-Enable Training Controls from Post Office.”

On receipt of an acceptable Request to Disable Training Controls, the MIM/Duty Manager should;
e Reply to the Request email to confirm receipt

e Request to the POA Unix Duty Manager to Disable Training Controls reminding them that in
order to do this they would need to arrange for someone to;

1. Logon to the BRDB (assuming node 1) as Unix user ‘brdbblv1’
2. Invoke the command to disable the controls (where ‘SOMEREF’ is an Operational Change

Emergency Operational Change or P1/P2 Incident reference):
$BRDB_SH/BRDBXO11.sh -n BRDB_EUM_CONTROLS_ENABLED -t T -v N -r SOMEREF

« On confirmation that this action has been performed the MIM/Duty Manager should reply to the
Request email confirming fulfilment.

If there was sufficient time to have raised an Operational Change between the Major Incident Service
Bridge call and receipt of the acceptable Request to Disable Training Controls then the Operational
Change reference should be provided, if not an Emergency Operational Change code should be used,
but a follow up Operational Change should be raised.

6.6.2. Handling Requests to Re-Enable Training Controls

6.6.2.1 Recognising Requests to Re-Enable Training Controls

In order to be an acceptable Request to Re-Enable Training Controls, all of the following must be true;

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e POL should have previously requested that we Disable Training Controls. We should not accept
“unexpected” Requests to Re-Enable Training Controls. Any such requests received should be
returned to the Post Office Limited IT Service Managers during normal working hours and not
processed further. OOH please refer to the OOH Rota supplied by Post Office Limited for the
Post Office IT and Post Office contact details and return the request to the specified Post Office
Limited staff and do not proceed any further.

e The request must be communicated on email to;
o POA Duty Manager -'
o Steve Bansal -/ GRO }
GRO

o Sonia Hussain +,

« The emailed request should be received from one of the Post Office Limited IT Service Managers:
o Head of IT Service — Finance, Ops and Central - Paula Jenner
o Heads of Service — Retail — Martin Godbold
o Head of IT Service — Financial Services and Telecoms - Mark Nash
The following deputies can also provide authorisation in a case where none of the
above 3 were available;
o Head of IT Service — FS & NS - Nick Baker
o IT Service Design and Assurance - Stuart Banfield
o IT Service Transformation Lead - Andy Jacques
o IT Security & Service Director - Ben Cooke
o IT Change Manager - Cherise Osei
o Senior Service Manager (Retail) - Lorna Owens
o Senior Service Manager - Matt Quincey
o Service Design & Transition Lead - Financial Services & Telecoms - Darryl Inch
e The emailed request must contain the following text;

“Post Office Ltd. hereby request that Fujitsu Services Re-Enable the Training Controls
Support Facility in HNG-X Systems, previously Disabled”

On receipt of an acceptable Request to Re-Enable Training Controls, the MIM/Duty Manager should;
e Reply to the Request email to confirm receipt

« Request to the POA Unix Duty Manager to Re-enable Training Controls reminding them that in
order to do this they would need to arrange for someone to;

1. Logon to the BRDB (assuming node 1) as Unix user ‘brdbblv1’
2. Invoke the command to re-enable the controls (where ‘SOMEREF’ is an Operational Change,

Emergency Operational Change or P1/P2 Incident reference):
$BRDB_SH/BRDBXO11.sh -n BRDB_EUM_CONTROLS_ENABLED -t T -v Y -r SOMEREF

e On confirmation that this action has been performed the MIM/Duty Manager should reply to the
Request email confirming fulfilment.

If there was sufficient time to have raised an Operational Change between the Major Incident Service
Bridge call, fulfilment of a Request to Disable Training Controls and receipt of an acceptable Request to
Re-Enable Training Controls then the Operational Change reference should be provided; if not an
Emergency Operational Change code should be used, but a follow up Operational Change should be
raised.

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6.6.3 Carrying out requests for Disabling and Re-Enabling Training
Controls

There is no SLA to action these requests. Fujitsu will aim to action the request within 30 minutes of being

received from one of the Post Office authorised staff if received between Monday to Thursday between

09:00 and 17:30 and 09:00 to 17:00 on Friday. For any other times such as OOH, weekends and Bank
Holiday's Fujitsu will aim to action the request within 90 minutes.

The activity will be completed under a change raised in TfSNow by the Fujitsu UNIX Support team. Post
Office Limited have agreed that this can be raised as an Emergency Operational Change Request during
normal working hours and RETRO Operational Change Request for activity OOH.

6.6.4 Charging the Customer for Disabling and Re-enabling of
Training Controls

Within the contract (Schedule D1) paragraph 7.14 specifies if and when the Disabling and Re-enabling of
Training Controls is requested by Post Office Limited, it is a chargeable activity. Please engage finance
that this charge needs to be invoiced against the appropriate month.

7 Formal Incident Closure & Post Incident Review

7.1 Post Incident Review

The Post Incident Review is chaired by the Major Incident Manager and follows a set agenda which is
distributed with the Post Incident Review meeting invitation, along with the draft copy of the Major
Incident Report (if available).

The template for writing a Post Incident Review Report is stored in Dimension (hyperlink below) under
SVM/SDM/TEM/2531.

The purpose of a Post Incident Review is:

e Tounderstand the incident that prevented a Service or Services from being delivered.

e To confirm the impact to the business during and after the Incident and agree the number of
branches impacted and duration of Major Incident.

e To confirm the end-to-end recovery process and timeline, and identify that all documented
processes were followed.

e Toanalyse the management of the incident and the effectiveness of the governance process.
e To identify corrective actions, including agreed Third Party actions, to:
© prevent recurrence of the incident

o minimise future business impact
co improve the procedure for the management of incidents.

Output: To confirm details provided in the draft MIR provided to POL update with corrective actions and
redistribute. To also include any of the following as appropriate

* any activities for a Service Improvement Plan

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e any Changes and associated TfSNow Change reference.
e any follow up that requires to be progressed via Problem Management
e any improvements to KBsalerting and /or event management

The agreed impact of the Major Incident must be provided for inclusion in the Counter Availability SLT
Figures.

If this review highlights areas where improvements can be made, an agreed Service Improvement Plan
will be produced, using the EMEIA SIP template, with appropriate actions, owners and timescales. It will
also identify any ongoing risks to the service, together with any changes. Service Management will track
all actions to resolution. Third party actions will be reviewed at Service Review meetings.

Consideration should be given as to whether the improvements can be shared across Fujitsu as lessons
learnt, in accordance with Fujitsu EMEIA Business Management System document: Major Incident
Management Process. Please see use the hyperlink below to access this document:

Major_Incident_Management_Process

These are to be documented on the Lessons Learnt portal to help other Accounts to learn from the
failures or success of the major incident activities. As stipulated in the document, there may be situations
when the lessons cannot be shared due to confidentiality reasons.

Itis important that the number of branches impacted and the duration of the Major Incident is agreed at
the Major Incident Review. This information is required to calculate the impact on Branch and Counter
Availability and any associated Liquidated Damages (LD) liabilities

7.2 The Major Incident Report

A first draft of the Major Incident Report is to be produced within 24 hours and on the approval of the
POA Senior Service Delivery Manager sent to Post Office Service Management.

The first formal version of the Major Incident Report is to be produced within five working days and on the
approval of the POA Senior Service Delivery Manager is sent to Post Office Service Management.
Generally this report will be produced after a Post Incident Review is held and the actions for the Major
Incident Report identified.

If applicable a Problem Record is to be opened for tracking the corrective actions and managed through
the POA Problem Management Process. The formal Major Incident Report version 1.0 is to be attached
to the TfSNow problem record and sent formally for storing in Dimension.

One or more formal versions of the Major Incident Report is to be produced which will also be sent to
either Post Office Service or Problem Management, after the approval of the POA Senior Service
Delivery Manager, providing feedback on the corrective actions. These major incident reports are also to
be attached to the TfSNow problem record and sent formally for storing within Dimensions.

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7.3 Calculating potential LD liability for Major Incidents

Major Incidents which qualify as Failure Events are detailed in the Branch Network Service Description
(SVM/SDM/SD/0011). A Failure Event is defined in this document as an event or series of connected
events which causes one or more Counter Positions to be deemed to be Unavailable due to a Network
Wide Failure or a Local Failure. Ongoing failures will be deemed to be part of such a Failure Event until
the Failure Event is closed in accordance with the Incident closure and Major Incident Review process as

detailed in section 7.0.

For a Failure Event the Incident Closure & Major Incident Review Process will require Post Office and
Fujitsu to agree the number of branches and counter positions affected and the duration of the outage
(rounded to the nearest 30 minutes as detailed in the Network Wide Rounding Table).

Network Wide Rounding Table

less than N hours 30
minutes

“30 minutes or less 30 minutes
More than 30 minutes 1 hour
but less than 1 hour

1 hour or more but less 1 hour
than 1 hour 30 minutes

1 hour 30 minutes or 2 hours
more but less than 2

hours

N hours or more but N hours

N hours 30 minutes or
more but less than
(N+1) hours

(N+1) hours

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8 Fujitsu Roles and Responsibilities during a Major
Incident

This section defines the roles and responsibilities individuals and teams have as part of the Major
Incident Escalation Procedure. The following roles will be laminated and available for the MIM to assign
during a Major Incident.

8.1 Role of the MAC Team

The role of the Major Account Controllers team in the event of a Major Incident is as follows:

« Receive phone calls and log incidents from Post Office IT Service Desk, and communicate the
progress of investigations to the Post Office IT Service Desk.

Notes:

1, There is also a HDI interface between Post Office Service Now and Fujitsu TfSNow systems
so incidents and updates may be automatically transferred as well

2, These incidents are generally considered ‘software’ incidents as hardware and branch network
incidents are no longer managed by Fujitsu.

e Escalation of any Call Threshold Breaches to the POA Duty Manager
« Confirming times and details to Major Incident Manager (MIM)

e Send/update service impact details to the Major Incident Manager. These details will be fed into
the Technical Bridge in real time as requested, whilst details for the overall Major Incident will be
provided to the Major Incident Manager post the incident.

* Be responsible for sending communications as provided by the Major Incident Communications
Manager for the following:-

To send out SMS text messages and attend all Technical Bridges

-SMS to SMS Technical Bridge

To inform of new Major Incidents and provide MI updates of progress to the following
- E Mail Post Office IT Service Desk
- Voice Post Office IT Service Desk
-- SMS to POASeniors (**POA**) — POA Senior Management

NB

The above communications will be as per instructed by the Major Incident
Communications Manager

ALL should be identical, in order to avoid any misunderstandings.

This also of course includes notification to Post Office IT Service Desk and POA
Management of the restoration of service.

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8.2 Role of the Major Incident Manager

Major Incident Manager (MIM). This will by default be either the Day Time Duty Manager or OOH Duty
Manager (hours shown in 9.3). However a separate member of the Service Management team may be
appointed as the MIM depending on the situation. The primary role of the MIM in a Major Incident is to
facilitate the management of the Incident through investigation and diagnosis to resolution, with the aim
of making the process as efficient and effective as possible. Upon determining that a Major Incident has
been called, a request for a Technical Recovery Manager (TRM) will be made to the appropriate POA
Service Lead or Senior SDM who will appoint one of his team to be the TRM. The Major Incident
Manager acts as the central point for communication and non-technical information flow, allowing the
TRM to focus on the technical situation and the resolution of the Incident. The Major Incident Manager is
also responsible for creating and maintaining all the associated documentation. For the process to be
effective, all updates and information regarding the incident must be fed to the MIM to update the
timelines and report.

The Major Incident Manager:
*e Calls and chairs the Technical Bridge

e Has responsibility for creating the Major Incident Report, using the template defined in section9.1
and ensuring that the applicable information is captured.

« Records the Technical Bridge attendees names so they can be documented in the Major Incident
Report.

e Identifies Business and Service impact though discussions with the users, the Post Office IT
Service Desk and the MAC team — providing this input into the Tech Bridge.

e Distributes the Technical Bridge actions provided by the TRM (if appropriate).
e Assists with communication internally within the POA
e Track time lines

e Along with the POA Problem Manager, ensures that the TRM provides regular updates on any
longer term corrective actions

« Following the resolution of the Incident, schedules and chairs the PIR.

8.3 Role of the Technical Recovery Manager

The primary functions of the Technical Recovery Manager are to co-ordinate and manage the restoration
of service, manage the technical teams, and act as the communication point for the technical teams and
third parties. The function will also include managing all longer term technical corrective actions, e.g.
recommendations for improvements to KBs, eventing and configuration.

The Technical Recovery Manager:
« Manages the technical recovery of the Incident — liaising with SDUs and third parties.

e Provides updates on the recovery, when technicians / representatives of technical teams are
unable to attend the Technical Bridge

e Is the only person to liaise directly with the technical teams, including technical third parties.

« Provides summarised actions from Technical Bridge to the Major Incident Manager, including:
o Current status including impact and risk
o Advising on potential workarounds.

o Planned recovery activities including timelines

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o Root Cause Analysis*, corrective actions, and their corresponding action owners and
timelines (where known)

The TRM will be responsible for attending any meetings and providing appropriate root cause analysis
and corrective action detail. This will also include managing any longer term technical corrective actions
that are documented in the Major Incident Report and will include where appropriate:

e Any activities for a Service Improvement Plan

e Any Changes / TfSNow Change references

e Any Risks

e Any Configuration changes

e Anyimprovements to KB's, alerting and /or events

e Any associated Peak or TfSNow calls

* For Root Cause Analysis refer to the Fujitsu EMEIA Conduct Root Cause Analysis Procedure.

8.4 Role of the Problem Manager

The Problem Manager ensures that corrective actions / investigations are tracked and completed
following the major incident.

Any corrective actions arising from the Major Incident Review will be added to the Major Incident Report
and also a Problem Record if appropriate, and tracked with POL through to completion. The updates will
be distributed to Post Office as required, and in the case of a Security Major Incident associated with PCI
failures, the POL Security team will also receive a copy of the report.

As Fujitsu have interfaces with 3° parties such as American Express, then liaising with Post Office
representatives from Service and support teams such as the Payments team as well as 3% party
representatives will be required, in order to contain, remove data etc, so the potential PCI\GDPR data
breaches are resolved in a timely manner and with the required authorisations.

8.5 Role of the Communications Manager

The Major Incident Communications Manager (MICM) will attend the Technical Bridge and produce each
update as agreed during the bridge, where possible trying to ensure that updates are provided on time
and following the agreed Major Incident Progress Template. This will reduce any miscommunication and
ensure all parties follow process.

e Above all ensuring only one update is circulated
e Will ensure that updates are provided within the agreed times
e Updates will adhere to the agreed Major Incident Progress Template
e Update the master TfSNow incident with all updates
e Ensure update is provided to MAC to circulate through to Post Office IT Service Desk
Supply update to Service Bridge, so the Service Manager can provide updates to the Post Office.
« Manages all communication internally within the POA

e Communicate to Fujitsu Core Major Incident Management team using the telephone numbers
below, when instructed on the Technical Bridge:

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Manages via MAC, the communication with the Post Office Service Desk on the progression of
the incident

8.6 Role of the SDUs: (Technical Teams /SMC/MAC & Third
Parties)

The role is to investigate the Incident, monitor the progress and feed into the Technical Bridge. Also in
the event of no pre-determined recovery options, suggest and evaluate potential recovery options to
resolve the Incident.

The technical teams should not be contacted by any party other than the Technical Recovery Manager.

The Technical Teams / SMC/ MAC team & Third Parties should send an attendee to the Tech Bridge and
the associated Major Incident Review meeting. Where attendance on the Tech Bridge is not possible, a
suitable alternative resource should attend. If neither is possible then a full update MUST be provided to
the TRM to ensure that the Bridge can be updated.

8.7 Role of the Service Delivery Manager owning the
affected service

8.8

Attends Technical Bridge
Attends PIR

Responsible for any further action proposed by the Problem Manager that falls outside the
Major Incident closure criteria.

Responsible for any Service Improvement Plan actions

Role of the Service Lead/Senior SDM

Appoint a Technical Recovery Manager

POA Service Lead or Senior SDM will inform within 10 minutes of the start of the service
incident the following-

o POA Delivery Executive

o POL Senior Service Delivery Managers

Will coordinate and ensure consistency of response to Post Office and POA Senior
Management via the Service Bridge.

Appendices

9.1 Daytime Duty Manager Contact Details

¢ Steve Bansal =

¢ — Matthew Hatch

« — Sonia Hussain

« — Piotr Nagajek =
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9.2 Out of Hours Duty Manager Contact Details

The OOH Duty Manager provides cover between 17.30 - 09.00 Monday PM to Thursday AM and 17.00 -
09.00 Friday PM to Monday AM. The OOH Duty Manager can be contacted on the phone number
detailed in the Post Office Account Service Delivery Contact Details on Share Point (see 9.4 below) or on
the date relevant POA OOH Duty Manager rota.

Outside these times, please contact the POA Duty Manager

Note: Names and phone numbers are correct at the time of document issue and subject to change. In
the event of difficulties refer to the Fujitsu Services Global Address List for the latest details.

9.3 POA Service Delivery Contact Details

The Post Office Account service delivery contact details can be found on the Post Office Account Share
Point under Operations > BCP in a folder named Post Office Account Service Delivery Contact Details.

This document can be accessed via the following link: Post Office Account Service Delivery Contact
Details

9.4 Special Situations

9.4.1. Personnel Absence

e In the absence of a POA Service Lead or Senior SDM, an alternative Lead will be appointed.
e Role cards have been produced and will be available to expedite the process, as
documented in section 8 of this document.

9.4.2 OOH

e The OOH Duty Manager will act as the Major Incident Manager.

9.4.3 Duty Manager Change Over

« The Duty Manager at the beginning of the incident will be by default responsible for all MIM
communications responsibilities unless a different arrangement is made between the
outgoing and incoming Duty Managers.

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