POL00042966
POL00042966
Claim No: HQ16X01238, HQ17X02637, HQ17X04248
THE POST OFFICE GROUP LITIGATION
IN THE HIGH COURT OF JUSTICE
QUEEN'S BENCH DIVISION
BETWEEN:
ALAN BATES & OTHERS
Claimants
AND
POST OFFICE LIMITED
Defendant
POST OFFICE'S RESPONSE TO CLAIMANTS'
INFORMATION REQUESTS MADE ON 4 MARCH 2019
Overarching Response
On 4 March 2019, the Claimants' Requests for Extended Disclosure were served, which included seventeen
questions about the types of documents used by Post Office and where they might be held (Information
Requests). Post Office's objections to the Requests for Extended Disclosure were provided on 15 March 2019,
pursuant to paragraph 3.3 of the Seventh CMC Order. As explained in WBD's letter of 15 March 2019, Post Office
does not consider that the Requests for Extended Disclosure pursuant to PD 51U was the appropriate method for
the Claimants to make information requests, however it was recognised that the Claimants were seeking clarity on
how best to target their Stage 5 Disclosure requests. Post Office therefore confirmed that it would be willing to offer
responses to the information requests, despite there being no Court order requiring Post Office to do so.
Post Office has sought to clarify with the Claimants a number of the information requests. Post Office has not
received any substantive response to the clarifications sought as set out in WBD's letters dated 1 April 2019, 19
August 2019 and 29 August 2019. Following these letters, the Claimants responded on 30 August 2019 stating that
due to the change of scope of the Further Issues Trial, it was not proportionate for the Claimants to focus resource
on answering Post Office's queries. Therefore, responses to the information requests on which Post Office has
sought clarification, including in relation to the expanded date range request from the Claimants, are being treated
as closed at this stage of the litigation.
Some of the information requested dates back over 19 years and seeks precise details of custodians and document
involved in certain activities. It has been difficult for Post Office to identify exactly who held specific roles within the
business and the documents they may have produced due to the passage of time. Post Office has made
reasonable and proportionate enquiries to find the information requested but it cannot warrant that this information
is completely accurate given the passage of time. Nevertheless, it should be practically useful to the Claimants
when they are formulating future disclosure requests.
POL00042966
POL00042966
Claim No: HQ16X01238, HQ17X02637, HQ17X04248
Information Request —- NBSC
helpline and representations
alleged:
A1: Provide copies of all indexes,
schedules and lists comprising
categories or folders/document titles
enabling all NBSC call scripts and
reference articles to be identified,
searched and inspected.
As explained in WBD's letter of 15 March 2019, this Information Request
duplicates the Stage 4 Disclosure Requests A4, F8/F9, H20/H21 and
K29.
Post Office objected to providing further information in response to this
request since the Claimants were seeking information on documents that
Post Office had agreed to disclose (and which have now been disclosed
as part of Stage 4 Disclosure).
WBD's letter of 19 August 2019 maintained this objection and requested
clarification from the Claimants as to why information was sought to
identify documents which Post Office had already agreed to disclose. No
response has been received to this request for clarification and therefore
this request is considered closed.
A2: Information on the types of
documents generated by Post Office
which contain high level statistics
and reports supplied to Senior
Management relating to:
(a) the nature and extent of issues
raised with NBSC by branches;
(b) the nature and categorisation of
NBSC responses to enquiries by
branches; and
(c) issues raised by branches
regarding alleged shortfalls,
discrepancies or losses.
The information to be provided is.
limited to the timeframes identified in
Mrs Stubbs and Mr Abdulla’s IPOCS,
giving a date range of January 2007
to August 2010.
Between 2000 and 2014, Post Office stored information concerning the
calls made by postmasters to the NBSC in a system called Remedy.
Reports could be run on the information stored within Remedy to, for
example, group together the calls made that month on particular topics.
Remedy had multiple users across Post Office who were able to run such
reports.
The reporting function of Remedy is the most likely tool to have been
used by Post Office to report to Senior Management on (a) the nature and
extent of issues raised with NBSC by branches and (b) the nature and
categorisation of NBSC responses to enquiries by branches. Our current
understanding is that there was no protocol for saving the reports which
were run from Remedy into a centralised document repository.
Post Office has not been able to recall or locate details of a formal
process between January 2007 and August 2010 for regular reporting to
Senior Management on the matters (a) to (c) nor any specific categories
of documents within which high level statistics and reports on matters (a)
to (c) were recorded. We understand that reporting was more likely to
have been ad hoc or on the basis of volumes of calls, length of calls and
time periods between initial calls to the resolution of the issue raised by
the Live Service Incident Management Team.
We have not been able to identify a specific category of document used
by the Live Service Incident Management Team to report to Senior
Management. Communications from this team depended on the incident
they were reporting on under the Major Incident Management Process
(set out in Response F12).
We have identified the individuals who may have undertaken such
reporting in Response A3.
AC_157555783_8
POL00042966
POL00042966
Claim No: HQ16X01238, HQ17X02637, HQ17X04248
A3: Identify the teams (from the list We understand the following teams may have been involved with the
at Appendix B to the Defendant's creation of high level statistics and reports for Senior Management in
EDQ) and the individuals within relation to the subject matters identified in Request A2:
those teams with responsibility for
creating the high level statistics and 1. Branch Support Services Team;
reports identified in the Defendant's
response to Request A2 above, 2. NBSC; and
between the date range of January
2007 to August 2010. 3. Live Service Incident Management Team (also known as the
Duty Management Team or IT Systems Management Team) may
have liaised with Senior Management between 2007 and 2010.
The team of approximately 8 —- 10 members reported to the
Systems and Direct Channels Operations Team and Service Desk
and Continuity Team. We understand the Live Service Incident
Management team had a general reporting function, although not
NBSC specific, and carried out analysis of call data to determine
trends which may have been reported to Senior Management on
an ad hoc basis.
The individuals from the Branch Support Services Team who may have
had responsibility for creating high level statistics and reports between
January 2007 to August 2010 for Senior Management were:
1. Andrew Kenny
2. Anne Allaker (Change and Improvement Manager, Branch and
Customer Support)
The individuals from NBSC who may have had responsibility for creating
high level statistics and reports for Senior Management between
January 2007 to August 2010 were:
Jill Kennedy (NBSC Manager)
Susan Stewart (Contact Centre Transition Manager)
Mark Haynes (Head of Business Support)
Howard Street (Helpline Migration & SSL Acct. Management)
Adele Henderson (Head of Network Business Support Centre
Programme)
Louise Bentley (Tier 2/ PSA Manager)
Michael Denison (Tier 2/ PSA Manager)
ARONS
No
The individuals from the Live Service Incident Team who may have had
responsibility for creating high level statistics and reports for Senior
Management between January 2007 to August 2010 were:
1. Dave Hulbert (Senior Service Delivery Manager; Systems and
Direct Channels Manager)
Gary Blackburn (Live Service and Business Continuity Manager)
Richard Ashcroft (Live Service and Business Continuity Manager)
Andy McLean (Head of Service Delivery and Head of Operations
Control / Operations Controller)
RON
AC_157555783_8 3
POL00042966
POL00042966
Claim No: HQ16X01238, HQ17X02637, HQ17X04248
A4: Please provide a description of As explained in WBD's second letter of 18 May 2018, which concerned
the types of documents stored on Stage 2 Disclosure for the Common Issues Trial, Post Office undertook
the ‘N:Drive’ relevant to the NBSC investigations during this stage of disclosure to map the Post Office
employees who used the "N Drive" and to understand the documents
which were stored in this location. Our fifth letter of 23 July 2018
confirmed that "During our investigations to locate the identity of the N
Drive, it has come to our attention that Post Office's NBSC team practice
is to store documents in the P Drive." We are therefore proceeding on
the basis that information sought by the Claimants is in relation to the
documents stored on the P Drive.
The P Drive is a team document repository used by the NBSC with the
file path:
Our understanding is that the P Drive is used as a central storage
location for documents by the NBSC.
Please find below a screenshot of the contents of the P Drive.
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AC_157555783_8 4
Claim No: HQ16X01238, HQ17X02637, HQ17X04248
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AC_157555783_8
Claim No: HQ16X01238, HQ17X02637, HQ17X04248
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AC_157555783_8
Claim No: HQ16X01238, HQ17X02637, HQ17X04248
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AC_157555783_8
POL00042966
POL00042966
Claim No: HQ16X01238, HQ17X02637, HQ17X04248
Information Request —
Information held by Post Office
B7: Identify the teams from those
listed in Appendix B to the
Defendant's EDQ and the
custodians within those teams, who
were responsible for deciding what
information should be
communicated to the branch
network:
7.1 by the NBSC helpline
regarding alleged shortfalls,
discrepancies or losses;
7.2 by the Defendant to the branch
network by means of the document
categories referred to in Request
AG (a), (b), (c) and (d);
7.3 by the Defendant to external
(non-postmaster) third parties,
including but not limited to press
releases, announcements, media
communications and
communications with MPs.
The information to be provided is
limited to January 2007 to August
2010.
In response to B7.1
e POL Core Information Management Team was established
around 2005 and was in place throughout the relevant period. The
team had approximately 6 members. The POL Core Information
Management Team liaised with the NBSC and product managers,
both of whom would advise the POL Core Information Management
Team on the contents of the KBAs used by the call handlers (where
such input was required), for example on the introduction of a new
product or service.
Wendy Schofield and James Unsworth were key contacts within
the POL Core Information Management Team who may have been
responsible for deciding what information should be communicated
to the branch network by the NBSC via KBAs, along with the product
manager (which would change depending on the contents of the
communication).
In response to B7.2
e Werefer you to paragraphs 5.1 — 5.22 of WBD's letter of 30 August
2019. Each Counter News, Operational Focus, Branch Focus and
Memoview identifies an author. The Memoview request forms also
list whom that particular Memoview has been reviewed by before it
is submitted to Fujitsu to be communicated to the branch network. It
should be noted that the authors of those publications may not
necessarily be the individuals responsible for deciding what was
communicated to the branch network, but merely the authors of
these documents.
Each of these types of operational updates were used to
communicate matters to the branch network. The teams and
individuals involved in deciding what information should be
communicated to the branch network, save for the overarching
Communications Team, will vary depending on the individual topic
being communicated. Over 5,600 operational updates were
disclosed in Stage 4 Disclosure. As you will see from the volume of
operational updates, it is not reasonable nor proportionate to
ascertain for each article in each publication which team / individual
decided what should be communicated. However, if following
inspection there is any particular article(s) that you would like further
information about, we can look into that article further.
In response to B7.3
e Post Office are waiting clarification from the Claimants on the
meaning of RFI 7.3.
In the meantime we understand that between 2007 to 2010, David
Simpson of Royal Mail was the Press Office lead and Mich Fisher of
Royal Mail was the Public Affairs lead. We understand these
contacts both left Royal Mail several years ago.
AC_157555783_8
POL00042966
POL00042966
Claim No: HQ16X01238, HQ17X02637, HQ17X04248
Information Request — Decisions
to communicate known bugs,
errors or defects
F12: A list of all teams, and named
custodians within such teams, with
responsibility for deciding whether
any matters of the nature referred
to in GPOC §23, §24 or §25 would
or should be communicated to the
branch network.
The matters are:
A: software coding errors, bugs or
defects and data or data packet
errors which required fixes, which
had the potential to produce
shortfalls (paras 23 and 24 GPOC);
B: knowledge that Fujitsu:
was able to alter branch data
directly (para 25 GPOC)
was able to carry out changes to
Horizon and/ or transaction data
which could affect branch accounts
(para 25 GPOC)
C: knowledge that Horizon:
had "insufficient error repellency"
(para 24 GPOC)
was “imperfect and had the
potential for creating errors" (para
24 GPOC)
The information to be provided is
limited to the date ranges of July
2000 to August 2010.
General response
We refer you to Post Office's response to Request B7 and paragraphs 5.1
to 5.22 of WBD's letter of 30 August 2019 regarding the processes for
communications being sent out to the branch network between 2000 to
2010.
The following teams may have had responsibility for deciding whether the
matters referred to in §23, §24 and §25 of the GPOC would or should be
communicated to the branch network.
1) Live Service Incident Management Team, Major Incident
Escalation Group; Business Protection Team and selective Service
Outage Groups . We refer you to POL-0081287 and POL-0217803.
2) Branch and IT Systems Team — from 2011 onwards, we understand
that this team would have been responsible for the production and
circulation of weekly technical incidents reports which were emailed to
four senior custodians, being:
(a) I Alan Simpson: Security Operations, Security Manager
(2011/2012) & ISAG Compliance Support Manager (2013)
(b) Dave King: Business Support Manager (2011/2012) & Security
Architect (2013)
(c) Graham Ward: Security Programme Manager (2011/2012) &
Mails Conformance Deployment Manager (2013)
(d) Duncan Godfrey Information Security, Security Architect
(2012/2013)
We understand that the individuals within the Branch and IT System
Team who may have generated these reports were:
(a) Terry Whitehead, IT & Change, IT Services Support (2011)
(b) Alison Dockerty, IT & Change, Service Management Support
(2012)
(c) I Claire Hudson, IT & Change, Service Management Support
(2012)
‘d) Jayne Sanjari, IT & Change, IT Services Support (2012)
e) Steven Birch, IT & Change, Live Service MI Advisor (2012)
f Laura Darby, IT & Change, Service Management Support (2012)
‘g) Emma Langfield, IT & Change, Post Office Service Desk (2013)
h) Julie Edgley, IT & Change, Post Office Service Desk (2013)
3) Executive Team
We refer to management structure provided on 29 March 2018. As
explained at paragraph 6.3, the Group Executive Team's role was to
develop and monitor deployment of the Group's strategy and consider
overall performance of the Group. In this role, the Group Executive Team
may have been responsible for deciding whether any matters of the
nature referred to in GPOC §23, §24 or §25 would or should be
communicated to the branch network. As explained at para 2.1, the
Group Executive comprises of individuals who held certain roles (albeit
that the titles of those roles has changed over time). Numerous
individuals will have held these roles and therefore been part of the
Group Executive Team over the relevant time period.
AC_157555783_8
POL00042966
POL00042966
Claim No: HQ16X01238, HQ17X02637, HQ17X04248
4) Network wide communications
If the incident affected the entire branch network, the branch network may
have been updated by way of a Memoview. We refer to Post Office's
response to Request B7.2 which explains the teams/custodians
responsible for the matters to be communicated to the branch network.
F13: A description or list of all
categories of document produced,
held or retained by the custodians
identified pursuant to Request F12
above in which decisions of the
type referred to at F12 above were
recorded, reported or
communicated within the
Defendant company.
The information to be provided is
limited to the date ranges of July
2000 to August 2010.
It is our understanding that the following categories of documents were
produced, held or retained by the custodians identified at F12 in which
decisions of the type referred to at F12 may have been recorded,
reported or communicated within Post Office (some of which have
already been disclosed by Post Office in Stage 3 Disclosure):
1) Root Cause Analysis Report (RCA Report) created by Fujitsu;
2) simplified Post Office report based upon the RCA Report (e.g.
POL-0220693; POL-0218681; and POL-0220101);
3) Weekly technical incidents reports (e.g. POL-0217324 and
POL-0218088);
4) Business Incident Management Service reports (BIMs)
created by Fujitsu (see WBD's letter of 22 May 2019);
5) Operational Functional Reports (e.g. POL-0215620 and POL-
6) 0215637);
7) Quarterly Risk Updates (e.g. POL-0215541);
8) ET Action Logs (e.g. POL-0215618; POL-0215636; POL-
0215621; POL-0215623 and POL-0215625); and
9) Network Functional Reports
Other forms of communication: we refer you to the process set out in
POL-0217803 which states that the main methods of communication
between the Live Service Incident Management Team, Major Incident
Escalation Group; Business Protection Team and selective Service
Outage Groups were emails, telephone calls and text updates.
AC_157555783_8
10
POL00042966
POL00042966
Claim No: HQ16X01238, HQ17X02637, HQ17X04248
G14: A list of all custodians, and
teams of which they formed a part,
The following teams may have been responsible for deciding whether
any matters referred to in GPOC §23, §24, §25, §31.3, §31.4 and §31.5
engaged by the Defendant
between July 2000 to August 2010,
responsible for deciding whether
any matters referred to in GPOC.
§23, §24, §25 (matters set out
above), §31.3, §31.4 and §31.5
would or should be communicated to those identified at (a) - (c).
1.
Product and Branch Accounting Team - The key individuals of
this team are noted throughout the Responses to the Information
Requests.
would or should be communicated 2. Debt Recovery Team - Paul Dann (Current Agent Accounting
to: Team (2009)) and Jacqueline Whitham (Former Agent Accounting
Team (2009)
(a) contract advisers; and/or
3. Fraud T 2008, the team's email address was.
(b) any other personnel within the
Defendant who were
responsible for or involved in
the conduct of branch audits or
investigations; and/or
S
any other personnel within the
“} As evidenced by the email address,
the communications to persons who fall within (a) to (c) may have
been decided by Royal Mail between the agreed date range. This
email address falls outside of Post Office's control. Jason Collins;
Ged Harbinson; Dianne Matthews; Andrew Daley and Lisa Allen
were Fraud Team Managers during the relevant period.
Defendant who were 4. Security Team: Dave Posnett was the Fraud Risk Manager in
responsible for, or involved in, 2008 and 2009 and sat within the Security Team during 2010. Key
taking decisions to suspend or contacts in the Security Team during the relevant period were
terminate the contracts of Glynn Burrows and Cathy Macdonald. It is not clear whether these
postmasters following an audit individuals were employees of Royal Mail Group or Post Office
or investigation, or to whom during the relevant time as we understand that this team straddled
appeals against such a the two entities at different times.
decisions were made.
5. Network Field Support / Admin Support Teams: the key
contacts were Mike Jackson; Andrew Daley; Jane Bailey; Chris
Matters (para 31 GPOC, in addition Fayers; Dave Ogleby; Sue Richardson; Wendy Mahoney and
to those listed in RFI F12) Linda McLaughlin who were Field Support Team Leaders during
the relevant period.
In relation to investigations/ audits
in respect of incorrect Branch 6. Network Intervention Team / Performance Team: In 2010, the
Trading Statements, discrepancies General Manager of Network Support was Lynn Hobbs, the
and shortfalls, Investigators/ Network Performance Manager was Craig Tuthill and the Network
Auditors were: Field Support Manager was Adrian Wales.
(a) not instructed, notified and / or 7. Investigation Team: In 2008, Paul Whitaker was an Investigation
informed as to the experience Team Manager.
of other SPMRs or
Investigators and/ or provided 8. Outlet Intervention Team: In 2007 Julia Marwood was the Outlet
access to information about Support Manager; Gayle Laverick was the Network Co-ordination
the same; manager; and Lynn Hobbs was the Network Support General
Manager.
(b) not instructed to seek out the
true cause of the incorrect 9. Business Development Manager: Caroline Richards; Paul
Branch Trading Statements,
discrepancies and shortfalls
and in practice proceeded on
the basis that SPMRs were
liable for any shortfall, unless
the SPMR could prove
otherwise; and/ or
Hemley; Stuart Eade; John Dixon; Andy Locker; Philip Steer
The Post Office employee make-up of those teams changed over the 10
year period across a wide breadth of functions. It is not proportionate
and reasonable to identify all members of these teams. The
information provided already in this document and in Appendix B to the
EDQ provides the Claimants with a list of key individuals.
AC_157555783_8
11
POL00042966
POL00042966
Claim No: HQ16X01238, HQ17X02637, HQ17X04248
(c) instructed to disregard
possible problems with
Horizon as a possible cause
for shortfalls and/ or it was
POL's practice to do so and/
Key individuals from Senior Management who may have been
responsible for deciding whether any matters referred to in GPOC §23,
§24, §25, §31.3, §31.4 and §31.5 would or should be communicated to
those identified at (a) — (c) were:
or Investigators did in fact do
so. 1. Anthony Marsh (Head of Security and Network Audit/ Head of
Network Implementation & Security)
Martin Ferlinc (Head of Network Audit)
Julia Marwood (Outlet Field Support Manager)
Anthony Utting (Investigation Policy & Standards Manager)
Dave Pardoe (National Investigation Manager)
Manish Patel (Investigation Operations Manager/ National Internal
Crime & Investigations Ops Manager)
7. Philip Gerrish (Internal Crime & Investigations Manager)
8. Trevor Lockey (Investigation Operations Manager)
9. Susan Lowther (Senior Security Manager)
10. John Scott (Head of Security)
11. Julian Tubbs (Senior Security Manager)
12. Stephen John Clements (Security Operations Manager)
13. Rod Ismay (Head of Risk Management and Control)
14. John Breeden (National Contract Manager)
15. Lin Norbury (National Contract Manager)
PAPRWN
Royal Mail trainers may also have been responsible for deciding whether
any matters referred to in GPOC §23, §24, §25, §31.3, §31.4 and §31.5
would or should be communicated to persons falling within (a) to (c). We
refer you to paragraphs 4.2 and 11.3 of WBD's letter of 30 August 2010.
G15: A description or list of all
categories of document produced,
held or retained by the custodians
identified pursuant to Request G14
above by which decisions (of the
type referred to in G14 above) were
recorded, reported or
communicated within the
Defendant company.
We note the Claimants' request sought information in relation to “all
categories of documents". This request is therefore too broad and Post
Office has sought to provide a reasonable and proportionate response.
We understand from documents already disclosed in Stages 2 and 4 of
Disclosure (see paragraph 11 of WBD's letter of 30 August 2019) as
produced by the custodians identified under Request G14 that the
following categories of documents may record, report or communicate to
persons within RFI G14 (a) to (c) matters referred to in GPOC §23, §24,
§25, §31.3, §31.4 and §31.5:
The information to be provided is
limited to the date ranges of July a) ACCs (we refer you to class 43 of documents disclosed by Post
2000 to August 2010. Office in Stage 2 disclosure, as set out in WBD's letter of 18 May
2018);
b) auditors'/ investigators’ pro forma documents which would be
completed at an audit (such as Event Capture Forms);
c) auditors'/ investigators’ pro forma documents which would be
completed if an investigation was carried out before/ after an audit;
d) training materials.
We refer you to paragraphs 4.2 and 11.3 of WBD's letter of 30 August
2019. Prior to separation from Royal Mail in 2012, training was given to
auditors, investigators and contracts advisors by Royal Mail Trainers. If
for example a training aide-memoir needed to be updated, this would be
updated by Royal Mail Trainers. As these custodians and the class of
documents are generally outside of Post Office's control, Royal Mail has
not been referenced as a custodian in G14 above.
AC_157555783_8 12
POL00042966
POL00042966
Claim No: HQ16X01238, HQ17X02637, HQ17X04248
Information Request — handling
concerns about Horizon
G19: In so far as Requests G16, 17
and 18 relate to documents already
disclosed to the Claimants, please
identify (by reference to their
existing disclosure ID (POL-[xxx])
the documents which are relevant
to Requests G16, 17 and 18.
As explained in WBD's letter of 15 March 2019, this request required Post
Office to incur the costs of identifying documents which have already
been disclosed in the Common Issues and Horizon Trials in relation to
Requests G16 — G18.
WBD's letter of 19 August 2019 maintained this objection and requested
clarification from the Claimants on how the Claimants believed that the
identification of documents using de-duplication could be achieved. In
any event, we refer to WBD's letter of 28 June 2018 which identifies a
number of documents which may fall within Requests G16 to G18 and the
methods by which the Claimants could locate further similar documents.
which have already been disclosed.
No response has been received to this request for clarification and so this
request is considered complete.
Information Request — policies
on the provision of transaction
data
H22: A list of all custodians, and
teams of which they formed a part
with responsibility for the
formulation and communication of
any policy or guidance produced
between January 2007 and August
2010 in respect of requests made
by postmasters for:
(a) transaction, event or session
data;
(b) ARQs;
[(c) error notices — NB error
notices fall outside of the agreed
date range and so have not been
addressed in the Response];
(d) transaction corrections or error
notices issued.
In response to Request H22, parts (a) and (b):
It should be noted that transaction and event data is another name for
ARQ data.
We understand that it is / was rare in practice for a Subpostmaster to
request ARQ data.
If a request for ARQ data was made by a Subpostmaster, it would most
likely be made to a Subpostmaster's contract adviser or via the NBSC
helpline and so these form the likely group of relevant custodians.
We refer you to paragraph 18.4 of WBD's letter of 30 August 2019.
Session data was not available until the Post Office used a system called
Horice in early/ mid 2014 and therefore no information has been provided
in respect of the custodian/teams with responsibility for the formulation
and communication of any policy or guidance in respect of requests made
by postmasters for session data as this falls outside the agreed date
range.
In response to Request H22, part (d):
It is not clear what information the Claimants are seeking in relation to
Transaction Corrections.
We have therefore interpreted this request to mean "which custodians,
and teams of which they formed a part had responsibility for the
formulation and communication of any policy or guidance produced
between January 2007 and August 2010 in the issuing of Transaction
Corrections and responding to the Claimants’ queries in respect of
Transaction Corrections".
The teams involved in Transaction Corrections who may have had
responsibility for the formulation and communication of any policy or
guidance produced between January 2007 and August 2010 in the
issuing of Transaction Corrections and responding to the Claimants’
queries in respect of Transaction Corrections were:
AC_157555783_8
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POL00042966
POL00042966
Claim No: HQ16X01238, HQ17X02637, HQ17X04248
e Financial Services Centre Team (FSC). From 2005, the FSC
were responsible for the creation of Transaction Corrections (e.g
POL-0173134);
e Product and Branch Accounting team (P&BA). This team would
investigate where a discrepancy appeared between POL FS data
and client data. (e.g. POL-0173307 and POL-01730930);
e Compliance Teams - we refer you to the disclosed Event
Capture Forms (e.g. POL-0017362);
« Outlet Intervention Teams (e.g. POL-0182395 and POL-
0523155_0001 for team standards in 2007);
* Business Development Managers (e.g. POL-0323706);
e Contracts Advisors (e.g. POL-0001081); and
e Debt Recovery Team (e.g. POL-0173094).
Error notices have not been considered in the response to this RFI as
they fall outside of the date range.
We have identified the key custodians of these teams where relevant
elsewhere in this document, in particular see K30 and K31.
H23: A list of all categories of Post Office has already provided disclosure of documents relating to
document by which policies or Transaction Corrections in Stages 2 (classes 24 and 25) and 3 Disclosure
guidance of the nature referred to (classes 1 to 3, 5 to 10 and 15). These documents have been tagged with
in Request H22 above were the document tag of "transaction corrections".
recorded or given effect.
From the disclosed documents, the Claimants are able to ascertain which
The information to be provided is teams and authors who prepared the documents. We have identified an
limited to the date ranges of July example document(s) against each team above.
2007 to August 2010.
If there are any specific documents within the disclosed documents which
the Claimants would like further information about, please notify us of the
respective BeginBates references and we can look into those identified
documents, teams and authors.
AC_157555783_8 14
POL00042966
POL00042966
Claim No: HQ16X01238, HQ17X02637, HQ17X04248
Information Request — suspense
account and branch accounts
J27: The names of all Senior
Management, and their roles, who
have had responsibility since 2000
for:
(a) the processes described in
§73(2) and §73(3) of the
Generic Defence and any
similar or related processes;
and
(b)
any policy or guidance
applied by the Defendant as
to sums credited to its
accounts as described in (or
similar/related thereto) the
said paragraphs of the
Generic Defence.
The processes described in s.73(2)
and (3) cover:
(a) the process of reconciling its
figures with its clients
(b) the existence of processes
for recording and resolving
"credits" as part of Post
Office's ordinary business
practice and any similar or
related processes; and
(c) any policy or guidance
applied by Post Office as to
sums credited to its
accounts.
The information to be provided is
limited to the date ranges of July
2000 to August 2010.
The Settlements and Reconciliation Team was in operation for some
of the relevant time between 2000 to 2010. The Settlements and
Reconciliation team was responsible for making settlements or
payments to clients for the transactions completed over the counter and
accounting for receipts. There were about 10 - 15 team members.
Dawn Brooks was responsible for the Settlements and Reconciliation
Team between 2003 to 2006.
Ms Brooks recalled the following senior individuals from management
between 2000 — 2010 who may have had responsible for the processes
described in §73(2) and §73(3) of the Generic Defence and/or the
production of policy or guidance in relation to the operation of “suspense
accounts":
1) Paul Graham Uden — Client Accounting Manager, Error Resolution
Manager 2 (TP), Head of Financial Operations (TP), Support &
Supplier Manager
2) Victoria Ann Noble — BPC9 Exceptions Manager, Head of Client
Accounting & Cash Manager, Head of Operations (TP), Head of
Product & Branch Accounting, Quality Assurance & Process Imp.
Mgr (TP), Support & Supplier Manager, Training & Competence
Manager (BLK)
3) Jeanette Brown — Business Architect, Cash Policy & Reporting
Manager, Design Authority Manager, Design Manager, National
Cash Manager, Quality Assurance & Process Imp.Mgr (TP)
4) Andrew Carter — Cash Policy & Reporting Manager, Liquidity
Manager, Method of Payment Accountant, Senior Liquidity Manager
5) Mandy Bonita Jepson — BPC9 Decision Support Manager, Change
and Performance Manager, Customer/Marketing Relationship Mgr
(TP), Ops Control Change Manager, Planning Manager (TP),
Planning Manager Transaction Processing
6) Ann Clarke — Business Change Senior, FROZEN BPC9 Finance
Change Manager, Project Manager, Transformational Change
Manager (TP)
7) Susan Mary Harding — Business Partner Group, Chief Process
Architecture Mgr, Design Manager, Head of Business Architecture,
Head of Operating Process, MI Project Manager, Release &
Programme Manager
8) Linda Tracey Anne Salem — Test Domain Manager, Testing
Analyst
9) Alison Bolsover — BPC9 Exceptions Manager, Client Accountant,
Exceptions Manager, FROZEN BPC9 Head of Operations
10) Peter Michael Corbett — Finance Director
AC_157555783_8
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POL00042966
POL00042966
Claim No: HQ16X01238, HQ17X02637, HQ17X04248
J28: A list of categories of
document recording:
(a) the processes;
(b) policies or guidance; and
(c) implementation of the matters
described in Request J27 above.
The information to be provided is
limited to the date ranges of July
2000 to August 2010.
During the relevant time period, Post Office's Settlements and
Reconciliation Team used a bespoke accounting solution called Client
Ledger and Settlement System (CLASS). CLASS was used to create a
monthly trial client balance and the Settlements and Reconciliation Team
was responsible for explaining the balances on the client accounts.
Our understanding is that a series of reports would have been produced
by the Settlements and Reconciliation Team, one of which was a monthly
report called a "probity summary report".
Each appropriate product team was responsible for the balancing of the
probity within their area of control. Once balanced the probity report was
forwarded to the Probity Lead CSA. The Probity Lead CSA collated the
reports from product teams and forwarded the final probity report to
Finance and the Probity Lead STL. The Probity Lead STL compiled the
Probity Summary Report. The individuals who held these roles changed
numerous times during the 10 year relevant period and so have not been
identified.
The Settlements and Reconciliation Team would also receive a client
transaction summary from Fujitsu (CTS report) which was compared to
the client transaction balances pulled from CLASS, amongst a number of
other reports which were sent by Fujitsu to the Team daily, weekly and
monthly.
Information Request — transaction
corrections and error notice
issues
K30: A list of all custodians and
teams responsible between
January 2006 and August 2010 for
authoring policies and/or guidance
on the production of transaction
corrections where the documents
electronically verify the authors.
From a review of the tagged "Transaction Correction" documents
disclosed under Stage 2, Stage 3 and Stage 4 Disclosure we were able to
ascertain that Jo Shooter-Holt, Martin Box, Dawn Brooks, Andy Winn,
Marie Cockett, Paul I Smith, Alison Bolsover and Carol King may have
been responsible for authoring policies and/ or guidance on the
production of transaction corrections. We understand that the Claimants
are seeking the same information as set out above in H22.
These individuals worked within or with the following teams:
1) FSC;
2) Product and Branch Accounting;
3) Debt Recovery; and
4) Contracts Advisors.
Error Notices fall outside of the agreed date range and so have not been
considered in Post Office's response.
AC_157555783_8
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POL00042966
POL00042966
Claim No: HQ16X01238, HQ17X02637, HQ17X04248
K31: Post Office agreed to confirm
the teams in which Richard
Marples and Alison Bolsolver were
in at the relevant times in relation to
the below documents.
31.1 Report disclosed under doc ID
number POL- 0221544
31.2 Review of the Creation and
Management of Transaction
Corrections in POLFS (10 February
2010) (POL-0173314)
31.3 Table of transaction
corrections issued in 2013-14
(disclosure date 22 October 2014)
(POL-0221563)
In response to K31.1:
e the report titled "Period 7, P&BA Transaction Correction
Reporting Pack" was created in November 2012 and authored by
Richard Maples (TC Pack).
e Richard Marples’ role title was Grapevine Analyst working in the
Fraud and Conformance Team. Colette McAteer was Richard's
line manager at that time. Mr Marples’ recollection is that he was
asked to produce the TC Pack by Senior Manager, Marie
Cockett, of the P&BA team.
In response to K31.2:
« The document titled "Review of the Creation and Management of
Transaction Corrections in POLFS" was created in February 2010
and lists the following individuals as working on this document:
(a) Martin Box - Business Analyst, Business Efficiency 3 Team
(b) Jo Shooter-Holt - Business Analyst, Business Efficiency 3
Team
(c) Alison Bolsover - Branch Conformance and Liaison Manager
— Branch Conformance and Liaison Team
(d) Dawn Brooks — Banking Strategy and Change Manager,
Change and Financial Control Team
(e) Rod Ismay - Head of Product and Branch Accounting
e The document details the triggers that lead to the creation, types
of and the parameters around Transaction Corrections and
focuses on the work carried out by the P&BA team.
« We understand from Ms Bolsover that she was able to locate in
her One Drive a subsequent version of the original document
which was saved on 1 March 2010. The subsequent document
has been tagged as an RF! document and disclosed along with
this Response. All comments in the document saved on 1 March
2010 have been made by Managers within P&BA at that time as
you will see noted within the document.
In response to K31.3:
¢ The document titled "Table of transaction corrections issued in
2013-14" was created in October 2014.
e The document was authored by Ms Bolsolver, who was the Debt
Recovery Team Leader and Rod Ismay, the Head of Product and
Branch Accounting.
AC_157555783_8
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POL00042966
POL00042966
Claim No: HQ16X01238, HQ17X02637, HQ17X04248
e Ms Bolsover could not recall who from Post Office contributed to
this specific document and / or asked for it to be prepared.
However, she thought the following individuals may have been
involved in TC reporting work around this time:
o Andy Winn, Mark Wood (Method of Payment Manager
(FSC)),
o Joy Lennon (Systems and Master Data Manager —
Accounting and Reporting, (FSC));
o Paul! Smith (FSC Personal Banking & Camelot Team
Leader/ Branch and Product Accounting Team, Team
Leader); and
o Martin Knights (Financial Accounting Manager/
Management Reporting Manager (FSC).
K32: A list of all custodians (or, to
avoid duplication, those of the
custodians identified in answer to
Requests K30 and K31 above) with
responsibility for monitoring,
investigating or reporting to Senior
Management upon:
32.1 The accuracy and basis of
transaction corrections and error
notices; and
32.2 the extent of disputed
transaction corrections and error
notices and the Defendant's
treatment of the same; and
32.3 ‘Camelot data integrity’ - as
described in the Operations Board
Agenda dated 17 October 2017
The information to be provided is
limited to the date ranges of
January 2006 to August 2010.
In relation to K32.1 and K32.2:
Error notices fall outside of the date range and so have not been
considered in Post Office's response.
Rod Ismay was the Head of Product and Branch Accounting and the
Head of Risk and Management Control between 2003 and May 2016.
Mr Ismay no longer works for Post Office. Post Office has attempted to
contact Mr Ismay to understand who within Post Office was responsible
for monitoring, investigating or reporting to Senior Management on the
requested topics between 2006 and 2010 as he is the best placed
person to provide this information.
The Settlements and Reconciliation Team worked with PB&A to
reconcile client data against Horizon data through Probity Reports. This
team may have been responsible for monitoring, investigating or
reporting to Senior Management upon the issues set out in K32.1 and
K32.2 during the relevant period.
In relation to RFI 32.3:
The custodians who may have had responsibility for monitoring,
investigating or reporting to Senior Management upon ‘Camelot data
integrity’ - as described in the Operations Board Agenda dated 17
October 2017 are:
1) Stuart Nesbit (Finance Director)
2) Paul I Smith (Senior Manager in FSC)
3) Allison Walton (Camelot Team Leader)
4) Alison Bolsover (Senior Debt Recovery Manager)
K33: A list of repositories or
locations in which any documents
produced by the custodians
identified in answer to Request K32
above can be found.
The custodians identified in answer to Request K32 above would have
had access to a number of document repositories depending on what
team they were a part of at the relevant time, along with use of their
email account. We refer you to Appendices C, D and F of Post Office's
EDQ which set out the possible repositories and locations of
documents.
AC_157555783_8
18