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Steering Group Meeting: 8 August 2017
DECISION: SHOULD POST OFFICE PRESERVE MORE DOCUMENTS?
41. BACKGROUND
1.1 Post Office has a Court duty to take reasonable steps to preserve any documents that may need
to be later disclosed in the litigation. At the Steering Group meeting on 22 August 2016, Post
Office decided to take a proportionate approach to this duty. The decision paper from this
meeting is at Schedule 1.
1.2 It was decided that a list of key individuals across the business who might hold relevant
documents would be produced, and then establish what documents they held and how. Forensic
copies would be taken of relevant electronic documents and scanned copies taken of hard copy
files. Although not all relevant documents would be preserved because of the targeted nature of
the exercise, it would demonstrate a genuine attempt to preserve documents.
1.3 It was recognised that that the preservation exercise would need to be refreshed if/when further
Claimants issued a claim against Post Office (we now have 324 new Claimants) and as the
litigation progressed.
2. DOCUMENTS ALREADY PRESERVED
24 The preservation exercise had a dual purpose: it was to preserve documents and also to provide
information to support the Case Review exercise. Within the original 198 Claimants, 88 were part
of the mediation scheme and so the Case Review was limited to the other 110 cases.
2.2 This has led to a tiered capture of documents:
2.2.1 Litigation hold notices have been sent to key parts of the business. This covers a wide
range of documents but only provides a low level of assurance that documents will not
be destroyed.
2.2.2 For some categories of documents, we have extracted all Post Office data in relation to
all subpostmasters (not just Claimants).
2.2.3 For some categories of documents, we have only captured information relating to the
198 original cases.
2.2.4 For some categories of documents, we have only captured information relating to the
110 cases subject to the Case Review.
2.3 In general, we have narrowed the capture of documents when dealing with paper records as
these require significantly more time and cost to locate and scan into a data room.
2.4 The preserved documents are being hosted in a data room that currently holds 599,004
documents. Further information on the documents that have been preserved already can be
found in Schedules 2 and 3.
25 The focus of work so far has been around preserving documents relevant to individual Claimants.
We have not yet preserved documents relevant to generic issues. For example, we have
captured the debt team files on individual Claimants, but we have not scoped and preserved
general documents and policies about debt collection practices. This is because "generic"
documents are much more difficult to identify, locate and retrieve in a cost effective way.
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3.1
3.2
41
4.2
4.3
4.4
FURTHER PRESERVATION NEEDED
In light of the new 324 Claimants and now having served Post Office's Defence, the document
preservation exercise could be extended to new areas, namely:
3.1.1 Documents relating to the new 324 Claimants.
3.1.2 Some areas of generic documentation.
The enclosed Schedule 4 lists areas for further preservation work.
RECOMMENDATION
We recommend preserving Tranches 1 and 2 in Schedule 4.
4.44 As a minimum, Post Office should extend the document preservation exercise that has
already been carried out to the 324 new Claimants.
4.1.2 We would strongly recommend preserving the entirety of POL SAP when it is taken
Offline later this year. Currently, only certain reports have been run from it and it
contains a vast amount of potentially key financial information on the Claimants and
their branches.
4.1.3 We would also recommend beginning to capture key generic documents that are likely
to be sought in disclosure by the Claimants, to the extent that this could be done cost-
effectively.
BD's work in delivering the above will be covered by its fixed fee until 19 October 2017, however
we anticipate this work will continue after that date. The majority of the costs of this exercise will
however fall on Post Office:
4.21 Capturing paper records for 324 new Claimants will require considering resourcing
from Post Office to locate, organise and send the files to Millnet for scanning. Millnet
will also charge for scanning and coding documents into the data room. We anticipate
this will cost around £100 - £300 per Claimant based on historic figures.
4.2.2 Capturing further electronic files will incur forensic costs from CA and Millnet. These
costs very much depend on the number of documents captured. We therefore
recommend that Post Office sets a budget for this exercise and we will then look to
capture a corresponding amount of data to fit within this budget.
4.2.3 Uploading and hosting more documents in the data room will increase the hosting
costs (which currently stand at £5,525 per month). It is difficult to assess the likely
forward cost as it depends on the number of documents but this could be between
£8,000 - £10,000 per month.
In the Decision Paper of 22 August 2016, we set out the advantages of preserving documents.
We continue to believe that these advantages justify the above costs.
We also note that since then Mr Justice Fraser has been appointed as the managing judge for
the Group Litigation. He has recently given a judgment in another case criticising a party for not
preserving evidence. He is therefore a judge who clearly takes an interest in these types of
issues.
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SCHEDULE 1: PLSG PAPER FROM 22 AUGUST 2016
SUMMARY:
Background
Post Office has a Court duty to take reasonable steps to preserve any documents that may need to be
later disclosed in the litigation. "Document" means practically anything holding information, including
electronic documents like emails.
What will satisfy the duty to preserve documents will depend upon the likelihood of documents being lost,
how they may be lost and the consequence on the litigation of losing a document. For example, for
documents tangentially related to one minor sub issue in the litigation, only minimal action will be
required. However, where the documents are required to determine a key liability issue, it will likely be
necessary to have the documents forensically imaged to avoid them being lost.
Failing to adequately preserve documents could result in sanctions against Post Office — including cost
penalties, striking out of parts of Post Office's case and / or the drawing of adverse inferences by a
Judge (ie. by making assumptions against Post Office in the absence of documentary evidence to
disprove those assumptions).
Steps to date
At the outset of the Group Action, Post Office Legal sent "litigation hold notices" to key parts of the
business asking them not to destroy relevant documents.
Since then BD has liaised with various teams at Post Office regarding potentially relevant documents and
document sources. Through these investigations, we have developed an understanding of document
storage, retention and deletion across the business, as well as better understanding the current IT
projects that may impact on document preservation. Please see the Document Locations Table attached
to this paper for details of the locations in which documents are held.
These investigations have led to the development of the "Preservation Options" attached to this paper.
Options
Given the complexity of Post Office's IT systems and the different practices operated in different
business units, we do not believe that simply sending general litigation hold notices (Option 1) or even
more stringent, targeted litigation hold notices (Option 2) will be sufficient.
Conversely, the work to date has revealed that the indicative costs for forensically imaging all Post
Office's systems (Option 5) to be in the hundreds of thousands of pounds (if not more) and this option is
not viable.
Our view is that some form of limited forensic imaging of information is required — either of documents
held by key custodians (Option 3) or by undertaking a deeper review to identify more relevant locations
of documents (Option 4).
ADVANTAGES:
e The nature of the claims in this matter, particularly the fraud and concealment issues, means that
preservation is a relatively high risk issue in this case. Losing key documents where there are
allegations of concealment would weigh against Post Office in Court and would be presented by
Freeths as yet another form of concealment. This militates towards Post Office taking a more
stringent approach to document preservation.
e Doing nothing risks falling foul of the Court duty to preserve relevant documents. Aside from the
legal consequences, this would present very badly through a public / media lens.
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e By taking steps now, we can then put Freeths on notice of what Post Office is doing and seek
their early engagement on this issue. This will make it harder for them to complain later about
missing documents.
DISADVANTAGES:
e Preserving and disclosing documents is one of the most expensive parts of the litigation process.
All the defensible preservation options come at a material cost to Post Office.
« No matter what steps are taken, many documents will have been lost already due to the passage
of time. Some amount of criticism about missing documents is inevitable and further work now
cannot offer complete protection for Post Office.
RECOMMENDATION:
Post Office should commission the further scoping work described in Option 4 below. This would allow a
more accurate cost estimate to be drawn up. A more informed decision can then be taken to proceed
with either Option 3 or Option 4 (or otherwise).
In parallel, BD should write to Freeths to draw out their view on what would be a proportionate way to
proceed.
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PRESERVATION OPTIONS
[ANNEXED TO PLSG PAPER ON 22 AUGUST 2016]
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Option Summary Pros/Cons Defensibility Cost range (ex
VAT)
4 Take no more action High risk that documents will not be Not defensible Nil Cost
Rely on the hold notices already sent to the business and retained.
undertake a further review once Post Ofice has received High risk of criticism as there are additional
the Particulars of Claim. steps that POL could reasonably take at
this stage.
Zero cost.
2 Send improved litigation hold notices It is unlikely that all relevant Likely not Less than £2,500
Based on investigations to date, draw up a list of key alvidualsiteams would pe fully identified defensible
individuals within Post Office and then send specific hold ased on current information.
notices to those specific individuals. In light of the ongoing IT projects /
With respect to external documents within POL's control, migrations this is still relatively high risk.
identify the key external business partners and Unlikely the preservation would be
stakeholders (eg. Fujitsu) and send bespoke hold notices effectively implemented by all individuals.
to them.
Low cost/impact.
3 Forensically copy documents from key individuals Would likely require the assistance (and Likely £15,000 to £75,000
i : therefore cost) of a third party e-Disclosure I defensible in the
Based on investigations to date, draw up a list of key ; i
individuals within Post Office and then take forensic mirror provide ne to fakerforensically sound shor erm but
images of any electronic documents stored in their email imag . updating in the
accounts and personal files. Would not secure documents held in near future
With respect to external documents within Post Office's shared workspaces (eg Sharepoint, etc.)
control, locate key external business partners and Would likely require updating upon receipt
stakeholders (eg. Fujitsu) and send bespoke hold notices of the Particulars of Claim.
to them.
Limited POL time/interaction required.
With respect to hard copy documents, obtain and store
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Engage an external e-Disclosure service provider to take
a forensic mirror image of all Post Office servers and
document storage locations.
With respect to external documents within Post Office's
Most expensive option (due to IT costs of
mirroring very large amounts of data).
Provides full protection with respect to
historic electronic documentation only (still
Option Summary Pros/Cons Defensibility Cost range (ex
VAT)
any original hard copy case files relevant to particular Shows a genuine attempt to preserve
Claimants. documents based on the current state of
the claim.
4 Undertake further scoping work and then forensically Would require time from business units in Defensible but Cost of scoping
copy documents from key individuals and in key order to scope locations of documents. not perfect. work:
leeations Would require the assistance of a third £10,000 - £20,000
Undertake a detailed further review of document party e-Disclosure provider.
locations/custodians and attend meetings with potential . .
custodians and/or teams to obtain information on storage Provides a good level of protection but Cost of imaging
processes. protection is limited by the value of the documents:
information extracted from Post Office
Also scope out documents held in relation to each teams and is not future proof (eg. more £25,000 - £150,000
individual Claimant. documents could be created after copies
This scoping work would allow a list to be drawn up of key are taken).
individuals and key shared document locations (eg. Likely to preserve major locations of key
relevant parts of Sharepoint, etc). documents.
Forensic images can then be taken of any electronic Shows a genuine attempt to preserve
documents stored on key individual email accounts and documents.
personal files and in any other key shared workspaces.
Reduces the burden when Post Office
With respect to external documents within Post Office's reaches the disclosure stage in this action.
control, locate key external business partners and
stakeholders (eg. Fujitsu) and send bespoke hold notices
to them.
With respect to hard copy documents, obtain and store
any original hard copy case files relevant to particular
Claimants.
5 Forensically image all key IT systems Time consuming (but less so than above). Gold standard, £700,000 -
minimal risk of £1,500,000
preservation
failure.
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Option
Summary
Pros/Cons
Defensibility
Cost range (ex
VAT)
control, we would propose locating the key external
business partners and stakeholders and send bespoke
hold notices and/or document requests to them (with the
option to obtain forensically sound copies where
appropriate).
With respect to hard copy documents, obtain and store
any original hard copy case files relevant to particular
Claimants.
need to rely on the hold notices to prevent
future deletions.
Less invasive/time consuming than option
4 above.
Provides full protection with respect to
historic documentation and avoids the
need to revisit retention (certainly in the
short term).
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SCHEDULE 2: CATEGORIES OF DOCUMENTS ALREADY PRESERVED
Team Paper files Electronic files
These have been scanned These have been forensically
and loaded into the data imaged from PO's servers
room. and loaded into the data
room.
Contract Advisers. Files for all 198 Claimants — Key parts of the Contract
where still available Adviser SharePoint site
All of the Electronic Filing
Cabinets (used prior to
SharePoint)
Security Files for all 198 Claimants — Data was collected for the
where still available CCRC project from Security and
Royal Mail's drives in July 2015
and specific files from Jarnail
Singh's folder. This data is
continuing to be preserved. We
have however not updated this
data (ie. data after July 2015
has not been preserved yet).
Field teams No paper files Data was collected from key
parts of the Field team
SharePoint site (including
Branch Contact and audit files)
Former Agent Debt
Files for all 198 Claimants —
where still available
No material paper files
Current Agent Debt
No paper files
Reports generated from Core
Finance and POL SAP on
transaction corrections issued
to branches and debt history
A copy has also been taken of
the FSC Relationship
Manager's (Andy Winn)
SharePoint
NBSC
No paper files
Call logs for the 110 Case
Review Claimants
HSD call logs
ATOS have not reported any
paper files
Following review of the NBSC
call logs, a selection of logs
were requested from ATOS for
the 110 review Claimants
NT
No material paper files
Specific spreadsheets were
extracted from the NT
SharePoint covering financial
data and an overview tracker of
branches moving through the
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Team
Paper files
These have been scanned
and loaded into the data
room.
Electronic files
These have been forensically
imaged from PO's servers
and loaded into the data
room.
NT program
Fraud Analysis
No paper files
Reports generated from
SharePoint to show which of the
110 Case Review Claimants
had been investigated for
potential fraud and which of
those cases either resulted in
non-suspension or were
escalated for further
investigation, e.g. by Security
HR Assistant Checks
No material paper files
Reports were generated from
the HR Assistant Checks team
for the 110 case review
Claimants showing the names
of registered Assistants at each
branch
Training
No material paper files
Contents of Sandra McBride's
laptop, who was responsible for
maintaining training materials
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SCHEDULE 3: DOCUMENTS ALREADY PRESERVED — BY CLAIMANT
Note: excludes mediation scheme cases where information was already captured as part of the mediation scheme.
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No I Claimant/ branch NBSC call HSD call Security Security Former Agent I Contract HR Assistant
logs logs hard copy electronic debt hard Adviser hard info
file files copy file copy file
(From CCRC)
2 Yes Yes Yes Yes
3 Yes Yes Yes
4 Yes Yes Yes 2015 Yes
5 Yes Yes Yes
6 Yes Yes Yes
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No I Claimant/ branch NBSC call HSD call Security Security Former Agent I Contract HR Assistant
logs logs hard copy electronic debt hard Adviser hard info
file files copy file copy file
(From CCRC)
6 Yes Yes Yes Yes
6 Yes Yes Yes Yes
8
10 Yes Yes
13 Yes Yes Yes
13 I G R Oo Yes Yes Yes
15 Yes Yes Yes 2017 Yes Yes Yes
17 G RO I Yes Yes Yes 2015 I Yes 2015 Yes Yes
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No I Claimant/ branch NBSC call HSD call Security Security Former Agent I Contract HR Assistant
logs logs hard copy electronic debt hard Adviser hard info
file files copy file copy file
(From CCRC)
Yes Yes Yes Yes
Yes Yes
Yes Yes Yes
Yes Yes Yes
Yes Yes Yes Yes
Yes Yes Yes
Yes Yes Yes Yes
Yes Yes Yes
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No I Claimant/ branch NBSC call HSD call Security Security Former Agent I Contract HR Assistant
logs logs hard copy electronic debt hard Adviser hard info
file files copy file copy file
(From CCRC)
38 Yes Yes Yes
39 Yes Yes Yes Yes
42 Yes
43 Yes Yes Yes
44 Yes Yes Yes 2017 Yes Yes Yes
49 Yes Yes Yes
50 Yes Yes Yes
52 Yes Yes 2017 Yes
54 Yes Yes Yes Yes
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No I Claimant/ branch NBSC call HSD call Security Security Former Agent I Contract HR Assistant
logs logs hard copy electronic debt hard Adviser hard info
file files copy file copy file
(From CCRC)
56 Yes Yes Yes
61 Yes Yes Yes
22 Yes Yes Yes Yes
62 Yes Yes Yes
63 Yes Yes
63 Yes Yes Yes
63
63
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No I Claimant/ branch NBSC call HSD call Security Security Former Agent I Contract HR Assistant
logs logs hard copy electronic debt hard Adviser hard info
file files copy file copy file
(From CCRC)
63
63 Yes
63 Yes
64 Yes Yes Yes
66 Yes Yes Yes 2017 Yes Yes Yes
67 . a Yes Yes Yes
70 G R O I I Yes Yes Yes Yes
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No I Claimant/ branch NBSC call HSD call Security Security Former Agent I Contract HR Assistant
logs logs hard copy electronic debt hard Adviser hard info
file files copy file copy file
(From CCRC)
76 GRO Yes Yes Yes Yes
77 Yes 2017 Yes Yes Yes
Yes Yes Yes
Yes Yes Yes
Yes Yes Yes Yes
Yes Yes Yes Yes
Yes Yes
Yes Yes Yes Yes
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No I Claimant/ branch NBSC call HSD call Security Security Former Agent I Contract HR Assistant
logs logs hard copy electronic debt hard Adviser hard info
file files copy file copy file
(From CCRC)
Yes Yes Yes
Yes Yes Yes
Yes Yes Yes Yes
Yes Yes Yes Yes
Yes Ongoing by Yes 2015 Yes
Paul Lorraine
Yes Yes Yes
Yes Yes Yes
Yes Yes
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No I Claimant/ branch NBSC call HSD call Security Security Former Agent I Contract HR Assistant
logs logs hard copy electronic debt hard Adviser hard info
file files copy file copy file
(From CCRC)
94 Yes
95 Yes Yes Yes
96
98 GRO Yes Yes Yes
“l Yes Yes Yes
Yes Yes
Yes
104 Yes Yes Yes
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No I Claimant/ branch NBSC call HSD call Security Security Former Agent I Contract HR Assistant
logs logs hard copy electronic debt hard Adviser hard info
file files copy file copy file
(From CCRC)
Yes Yes Yes Yes
Yes Yes Yes Yes
Yes Yes Yes Yes
Yes Yes Yes Yes
Yes Yes Yes
Yes Yes Yes
Yes
Yes Yes
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No I Claimant/ branch NBSC call HSD call Security Security Former Agent I Contract HR Assistant
logs logs hard copy electronic debt hard Adviser hard info
file files copy file copy file
(From CCRC)
118 ‘I Yes Yes Yes Yes
121 Yes Yes Yes
122 Yes Yes Yes
122 Yes
123 Yes Yes Yes
125 Yes Yes Yes
126 'I Yes Yes
130 Yes Yes Ongoing by Yes 2015 Yes Yes
Paul Lorraine
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No I Claimant/ branch NBSC call HSD call Security Security Former Agent I Contract HR Assistant
logs logs hard copy electronic debt hard Adviser hard info
file files copy file copy file
(From CCRC)
Yes Yes Ongoing by Yes 2015 Yes Yes
Paul Lorraine
Yes Yes Yes
‘I Yes Yes Yes Yes Yes
Yes Yes Yes Yes Yes
Yes
Yes
Yes Yes Yes
Yes Yes
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No I Claimant/ branch NBSC call HSD call Security Security Former Agent I Contract HR Assistant
logs logs hard copy electronic debt hard Adviser hard info
file files copy file copy file
(From CCRC)
140 f G RO Yes Yes Yes Yes
144 Yes Yes
= ~GRO_ -
I Yes Yes Yes Yes
Yes Yes Yes Yes
Yes Yes 2017 Yes Yes Yes
Yes Yes Yes Yes
Yes Yes Yes
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No I Claimant/ branch NBSC call HSD call Security Security Former Agent I Contract HR Assistant
logs logs hard copy electronic debt hard Adviser hard info
file files copy file copy file
(From CCRC)
Yes Yes Yes Yes
Yes Yes
Yes Yes
Yes Yes Yes Yes
Yes Yes Yes Yes
Yes Yes
Yes Yes 2017 Yes Yes
160 ADH I Yes Yes Yes
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No I Claimant/ branch NBSC call HSD call Security Security Former Agent I Contract HR Assistant
logs logs hard copy electronic debt hard Adviser hard info
file files copy file copy file
(From CCRC)
1] Yes Yes Yes
Yes Yes Yes
Yes Yes Yes
‘I Yes Yes Yes
Yes Yes Yes Yes
Yes
Yes Yes
170 + Yes Yes Yes
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No I Claimant/ branch NBSC call HSD call Security Security Former Agent I Contract HR Assistant
logs logs hard copy electronic debt hard Adviser hard info
file files copy file copy file
(From CCRC)
Yes
Yes Yes Yes Yes
Yes Yes Yes Yes
Yes Yes Yes Yes
Yes Yes Yes
Yes Yes Yes
Yes Yes Yes
189 Yes Yes
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No I Claimant/ branch NBSC call HSD call Security Security Former Agent I Contract HR Assistant
logs logs hard copy electronic debt hard Adviser hard info
file files copy file copy file
(From CCRC)
‘I Yes Yes Yes
Yes Yes
Yes Yes Yes
Yes Yes
Yes Yes Yes Yes
Yes Yes
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SCHEDULE 4: AREAS FOR FURTHER PRESERVATION WORK
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transaction corrections
and debt history for
additional Claimants
documents on debt
recovery
Team Tranche 1 Tranche 2 Tranche 3
Documents that Documents that are Documents where
should definitely be preferable to POL could arguably
preserved. preserve say that preservation
was unreasonable at
this stage
Business wide Current manuals and Email accounts and
policy documents OneDrives of all key
relevant to the Group individuals with contact
Action with Claimants
Contract Advisers. Hard copy files for
additional Claimants
where available
Current Agent Debt Further reports on Manuals and policy
Former Agent Debt
Hard copy files for
additional Claimants
where available
POL SAP database.
This is due to be taken
Offline later this year. It
would be preferable to
preserve the database
in case historic reports
of any other type are
needed
Manuals and policy
documents on debt
recovery
Fraud Analysis
Further reports on
Claimants investigated
Full lift of Fraud
Analysis team's.
SharePoint
Collection of archived
data held on CDs
FSC Enquiries teams
Manuals and policy
documents on
transaction enquiries
and investigations
Paper files containing
supporting evidence
and any investigation
into transaction
corrections issued to
Claimant branches
HSD
Further call logs for
additional Claimants
and original Claimants
that didn't enter the
Case Review
Knowledge Base
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additional Claimants
where available
SharePoint
It has been some time
now since the original
lift for the CCRC
project was done in
July 2015. It would be
preferable to refresh
this
Manuals and policy
documents on
investigations and
prosecutions
Team Tranche 1 Tranche 2 Tranche 3
Documents that Documents that are Documents where
should definitely be preferable to POL could arguably
preserved. preserve say that preservation
was unreasonable at
this stage
NBSC Further call logs for Knowledge Base
additional Claimants
and original Claimants
that didn't enter the
Case Review
Security Hard copy files for Security network drive /
Agent Remuneration
Reports from HR SAP.
on remuneration paid
to agents
Preservation of entire
HR SAP database
(unless this can be
done in a cost effective
way)
Branch Standards
Reports from web-
based platform on
contact with agents for
intervention or sales
support
Reports from Combat
database on standards
failings and training
delivered to Claimant
branches
Hard copy completed
forms from agents
signing confirmation of
training delivered
Files from Google drive
‘on responses from
Claimants to surveys
about the network
Cash Management
Reports from SAP on
Claimant branch cash
holdings
Reports from Remedy
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Team
Tranche 1
Documents that
should definitely be
preserved.
Tranche 2
Documents that are
preferable to
preserve
Tranche 3
Documents where
POL could arguably
say that preservation
was unreasonable at
this stage
and Dynamics (call
logging database) of
calls made by
branches to request an
increase in cash
holdings
Reports from OneDrive
into concerns over
cash holdings at
Claimant branches
(where available)
Contracts & Policy
Manuals and policy
documents on
contracts, contractual
investigations and
licence fees
Crown Network
Reports from HR SAP.
and performance
records from Branch
Managers on Crown
employees
Field
Manuals and policy
documents on
interventions and
audits
IT (including Fujitsu)
Technical documents
and manuals on
Horizon
Legal
Files from Legal team
drive on Claimants
Files from Cartwright
King on Claimants
NT
NT's SharePoint and
team drive
Manuals and policy
documents on NT
Post Office External
helpline
Call records from
customers relating to
Claimant branches
Knowledge Base
Scheduling
Records from Access
and Dynamics on on-
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Team
Tranche 1
Documents that
should definitely be
preserved.
Tranche 2
Documents that are
preferable to
preserve
Tranche 3
Documents where
POL could arguably
say that preservation
was unreasonable at
this stage
boarding Claimants
Sparrow / SSRT
SharePoint and Huddle
for reports and
supporting information
prepared in relation to
Claimants
Training
Knowledge Centre &
Sandra McBride's
OneDrive (previously
responsible for
maintaining training
materials)
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