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Message
From: Andrew Parsons ij
Sent: 17/07/2017 14:
To: Rob Houghton } i _ —— ose
ce: Rodric Williams, GRO _1]; Mark Underwood GRO _JsJane
Subject: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
Rob
Understand your view from a technical perspective. However, the reason it is phrased this way is to give us some wriggle
room. Saying “admin access is absolutely not functionality" creates a higher risk that that staternent could later be proved
to be incorrect. This section of the Defence is all about historic statements that were not correct, and so we need to be
very careful about saying this things that could be challenged. My language is, admittedly, much less clear than yours but
that is intentionally so.
A
Andrew Parsons
Partner
Bond Dickinson LLP
Bend Dickiagen.
From: Rob Houghton
Sent: 17 July 2017 14:52
To: Andrew Parsons
Cc: Rodric Williams; Mark Underwoo jane MacLeod; Amy Prime
Subject: RE: PLSG meeting on WednéSday 24 May 2017 @12 in Tonbridge (1.11)
lve looked at it a few times during the last meeting and the problem is (and I know I’m being pedantic) but the sentence
doesn’t really make sense to me! The phrase “it is admitted that, although this would not usually be classified as
“functionality” —is odd. If it makes sense to a lawyer then that’s fine. For the record though — it would never be
classified as functionality. {f that functionality was wanted (the ability for administrators to change data) then it would
be coded entirely different. It's actually a known unfortunate consequence of systems and therefore you have extensive
controls around it (which we do have). In fact — it’s encouraging that the controls are so extensive that the risk has been
really reduced down to a very small level. In most organisations then the controls are nowhere near as extensive as this.
I can’t think of a form of words to make this work! (other than the ones I proposed}
R
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From: Andrew Parson:
Sent: 17 July 2017 12:18
To: Rob Houghton
Cc: Rodric Williams; Mark Underwoode4 Jane MacLeod; Amy Prime
Subject: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
Rob
On the first para: As this is Post Office's defence It is Post Office that has to make all the submissions, even where we are
relying on FU. Hence why it says “Post Office would characterise..." However, I'll speak to Tony about removing this
sentence.
On the second para: You're amendments below create risks. First, if we say admin access is a common feature, the
Claimants will say how did you miss it before? This is a hostage to fortune. The second element below sounds like the
admin access was a mistake and should not have been part of the designed system. I understand the points you are
making, but they could be mis-read by a judge.
Was my original amendment incorrect? Set out below for ease of reference.
As to paragraph 27, it is admitted that, although Hee as-not-designed-to-have this functionality this
would not usually be classified as "functionality" within an IT system, there was a highly theoretical possibility that
certain Fujitsu personnel could abuse their privileged user rights to circumvent the protections in the system as
designed so as to edit or delete branch transaction data as described in paragraph [57(4)XX] above
Kind regards
Andy
Andrew Parsons
Partner
Bond Dickins
From: Rob Houghton _
Sent: 17 July 2017 12:03
To: Andrew Parsons
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Cc: Rodric Williams; Mark Underwood: Jane MacLeod
Subject: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
Response in >>>>
Read through it all. Two comments - on this statement...
(1) ANLTT systems experience software coding errors or bugs which require fixes to be developed and
implemented. For a system of Horizon’s scale, Post Office would characterise the number of errors or
bugs in Horizon requiring fixes as relatively low. In any event, as is noted in paragraph [53 and 54XXI
below, there are robust measures in place for their detection, correction and remediation.
Can we say they are relatively low? Where did this come from? Not sure I could say this without further data. THIS IS
FJ's LANGUAGE AND THEY WERE HAPPY WITH IT.
>>> Can they defend it? If so ~ do we need to assign to FJ; the bit I am concerned about is “Post Office would
characterise the number of errors or bugs in Horizon requiring fixes as relatively low...” I wouldn’t/ couldn’t
!
a
i.
2. As to paragraph 27, it is admitted that, although Heri: as not-desi etionality this
would not usually be classified as "functionality", there was a highly theoretical possibility that certain Fujitsu
personnel could abuse their privileged user rights to circumvent the protections in the system as designed so
as to edit or delete branch transaction data as described in paragraph [57(4)XX] above.
{don’t think it needs the phrase “ although Horizon was not designed to have this functionality” ~ its not functionality —
admin access is available in every system globally. I would state — In common with all systems that have administration
access .... {which is all}. Rob — I can see the force of this argument. We've discussed this before with Tony. Although
from a technical point of view admin access is not functionality, we decided that this argument would be overly
technical and semantic in the eyes of the judge. Is the amended language above better?
>>> Suggest this.....
>>> As to Paragraph 27, it is admitted that, Hdretied tt - Josittied to tive this tunchenabtechecwoule
5 in common with other computer systems and not designed as part of
Horizon functionality. there was IS a highly theoretical possibility that certain Fujitsu personnel could abuse their
privileged user rights to circumvent the protections in the system as designed so as to edit or delete branch
transaction data as described in paragraph [57(4)XX] above
R
From: Andrew Parsons C
Sent: 14 July 2017 14:39
To: Mark Underwoodix!Jane MacLeod; Angela Van-Den-Bogerd; Mark R Davies; Stuart Nesbit; Patrick Bourke; Rob
Houghton; Rodric Williams; Thomas P Moran; Tom Wechsler; Mark Ellis; Melanie Corfield
Ce: Kevin Morgan; Amy Prime
Subject: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
All
Thanks to all those who have commented so far. We're locking down the Defence at 9am on Monday so that we can
complete all the cross referencing and proof reading before the Tuesday deadline. If you have any final comments,
please let us know before then.
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Thanks
Andy
Andrew Parsons
Partner
Bond Bickinsas
Fotlow Bond Dickinsen
40)
ww.bonddickinson.com
Goud Didcinten-
From: Andrew Parsons
Sent: 12 July 2017 14:49
To: ‘Mark Underwor Jane MacLeod; Angela Van-Den-Bogerd; Mark R Davies; Stuart Nesbit; Patrick Bourke; Rob
Houghton; Rodric Williams; Thomas P Moran; Tom Wechsler; Mark Ellis; Melanie Corfield
Cc: Kevin Morgan; Amy Prime
Subject: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
All
Please find attached the draft Defence for your review and comment. As discussed earlier, if possible please provide
comments rather than amendments to the actual text. f've also attached the Claimants’ Generic Particulars of Claim for
reference.
You'll see a few points where input from Deloitte and Fujitsu is needed ~ we expect to get this today.
Please send any comments to me and Amy Prime (copied).
Thanks
Andy
From: Mark Underwood
Sent: 12 July 2017 14:40
To: Jane MacLeod; Angela Van-Den-Bogerd; Mark R Davies; Stuart Nesbit; Patrick Bourke; Rob Houghton; Rodric
Williams; Thomas P Moran; Tom Wechsler; Andrew Parsons; Mark Ellis; Melanie Corfield
Cc: Kevin Morgan
Subject: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
Dear all, please find attached the open action list, which includes those taken today.
Ihave highlighted in yellow those that require people’s imminent attention.
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Many thanks
Mark
N Mark Underwood
Head of Portfolio: Legal, Risk & Governance
Ground Floor
, 20 Finsbury Street
2017 Winner of the Global Postal Award [) Pn 38Q
for Customer Experience
Mobile number
From: Mark Underwo:
Sent: 11 July 2017 13:46
To: Jane MacLeod; Angela Van-Den-Bogerd; Mark R Davies; Stuart Nesbit; Patrick Bourke; Rob Houghton; Rodric
Williams; Thomas P Moran; Tom Wechsler; ‘Parsons, Andrew'; Mark Ellis; Melanie Corfield
Ce: Kevin Morgan
Subject: RE: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
Dear all, further to my note earlier today, please find attached the final Decision Paper.
Mark
“ Mark Underwood
Head of Portfolio: Legal, Risk & Governance
Ground Floor
2017 Winner of the Global Postal Award °° Finsbury Strest
London EC2¥ 9AQ
for Customer Experience
Mobile number:
From: Mark Underwood:
Sent: 11 July 2017 09:30
To: Jane MacLeod; Angela Van-Den-Bogerd; Mark R Davies; Stuart Nesbit; Patrick Bourke; Rob Houghton; Rodric
Williams; Thomas P Moran; Tom Wechsler; 'Parsons, Andrew'; Mark Ellis; Melanie Corfield
Ce: Kevin Morgan
Subject: PLSG meeting on Wednesday 24 May 2017 @12 in Tonbridge (1.11)
Dear all,
We have a PLSG meeting on Wednesday 12 July @12 in Tonbridge (1.11). Ahead of that meeting please find attached:
1. The Agenda
2. Decision Paper: Access to Second Sight
3. Decision Paper: Standstill Agreement with Fujitsu
4. Decision Paper: Communications Strategy
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5. Decision Paper: Wider Risks to POL [To follow later today]
6. Open actions list as at 11 July 2017
Please let me know if you are intending to dial in.
Many thanks, and apologies for the delay in circulating these papers.
Mark
“ Mark Underwood
Head of Portfolio: Legal, Risk & Governance
Ground Floor
2017 Winner of the Global Postal Award °° Finsbury Street
London EC2¥ 9AQ
for Customer Experience
Mobile number!
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