POL00055196
POL00055196
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
Re: Seema Misra
5 Interim Technical expert’s report to the Court prepared by
Charles Alastair McLachlan, a Director of Amsphere Consulting
Ltd.
90 Fenchurch Street
London EC3M 4BY
England
This report contains 16 pages
POL00055196
POL00055196
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicito
Yard House, Basingstoke, RG2I 7.
Contents
I=
REVIEW OF PROGRESS AS OF 25™ FEBRUARY 2010...
In
leo
Charles McLachlan 1
POL00055196
POL00055196
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
1 Review of progress as of 25" February 2010
1.1 Introduction
This report has been prepared to describe the progress made by myself, the IT Expert
instructed by the Defence since first instructed in September 2009. This has been
offered as a simple table to provide clarity as to the development of hypotheses of
time, the work still required to conduct a proper investigation and the implications of
the witness statement of and interview with Gareth Jenkins in February 2010
Charles McLachlan 1
Amsphere
POL00055196
POL00055196
Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
Hypothesis
ist Raised
Investigation
Required
Progress to date
Expected time required to complete
investigation
Implications of most recent
information
The User interface gives
tise to incorrect data entry:
poor user experience design
can give rise to poor data
entry quality
21 September
2009
User interface design
audit
thas not been possible to arrange for
access to a branch terminal system
under conditions that would permit a
user interface design audit or the
implications of a need for screen
recalibration
Six weeks from the time that a date is
offered for access to a branch system for
the purpose of a user interface design audit
Gareth Jenkins, in a telephone
interview on 12th February 2010
confirmed the evidence in his
witness statement dated 2nd
February that use of the Fast
Cash button could result in
rejected card payment being
treated as over the counter cash.
Further, he said that there was a
possibility that when the touch
screen needed recalibrating a
user could believe they had
pressed one button while the
system recorded the pressing of a
different button (the call logs to
Fujistu identify that recalibration
was necessary on more than one
occasion).
I have now checked all cases of
Rejected Card payments and they
don't explain the discrepancies so
this hypothesis is irrelevant
The User interface gives
fise to incorrect data entry:
inadequately user
experience testing can give
rise to poor data entry
quality
21 September
2009
Review of user
experience testing
conducted for Horizon
thas not been possible to review the
adequacy of the user experience
testing in the absence of any details of
the user experience testing process
and test results from the Post Office or
Fujistsu
Two weeks from the time that a complete
set of information relating to the user
experience testing activities has been
provided
Gareth Jenkins, in a telephone
interview on 12th February 2010
confirmed the evidence in his
witness statement dated 2nd
February that use of the Fast
Cash button could result in
rejected card payment being
treated as over the counter cash.
In the absence of test information
it has not been possible to
determine whether other similar
issues were identified during user
experience testing.
I have now checked all cases of
Rejected Card payments and they
don't explain the discrepancies so
this hypothesis is irrelevant
Charles McLachlan
POL00055196
POL00055196
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
Hypothesis ist Raised investigation Progress to date Expected time required to complete implications of most recent
Required investigation information
The User Interface gives
tise to incorrect data entry:
in cases that users are
working under pressure the
problems of data entry can
be exacerbated
27 September
2009
Electronic Observation
of operational post
office where
discrepancies are
continuing to arise
A post office has been identified where
the sub post master is suffering from
continuing discrepancies, there is
currently no suggestion of theft or false
accounting and the sub postmaster is
prepared to permit electronic
observation of the use of the Horizon
system. The use of a camera or
screen capture tool was proposed in
the report dated 19th November 2009.
It has not been possible to conduct
electronic observation of the use of the
Horizon system at the identified post
office because the Post Office has not
released the sub postmaster from their
contractual obligation of confidentiality
and the Post Office has not facilitated
any arrangements to install the
necessary monitoring tool.
‘Six weeks from the time that a date is
offered for access to a branch system for
the purpose of electronic monitoring
Gareth Jenkins, in a telephone
interview on 12th February 2010
confirmed the evidence in his
witness statement dated 2nd
February that use of the Fast
Cash button could result in
rejected card payment being
treated as over the counter cash.
The Post Office in the Midlands
reports that the level of
discrepancies appears to have
increased as the level of card
based transactions has increased
I have now checked all cases of
Rejected Card payments and they
don't explain the discrepancies so
this hypothesis is irrelevant
The User Interface gives
tise to incorrect data entry:
in cases that users are
insufficiently trained the
problems of data entry can
be exacerbated
21 September
2009
Detailed review of
training both for
Seema Misra and,
more generally, the
training process and
outcomes for
individuals with a
similar profile of
experience and
English language
capability
thas not been possible to review full
and complete training records for
Seema Misra. It has not been possible
to review a complete set of training
materials. No log of the calls to the
National Business Support Centre has
been provided, the original log of calls
to the Fujitsu help line has not been
provided - such a log of calls would
provide evidence as to the extent to
which Seema Misra had been
sufficiently trained to operate the
branch system. Finally, there has been
no opportunity to observe the training
process for a sub postmaster with a
similar level of English capability as
Seema Misra
Two weeks from the time that a complete
set of information has been provided and
the training process has been observed for
an individual with a similar level of English
language capability
We have been provided with part
of a guide that explains the
process for manually dealing with
a card payment that fails to be
properly recorded due to a system
problem. It has not been possible
to establish whether the training
‘Seema Misra received ensured
that she was competent to deal
with this kind of problem.
No comment
Charles McLachlan
POL00055196
POL00055196
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
Hypothesis ist Raised investigation Progress to date Expected time required to complete implications of most recent
Required investigation information
The User Interface gives
tise to incorrect data entry:
in cases that users are
using a system presented in
a language different from
their first language the
problems of data entry can
be exacerbated
27 September
2009
Detailed review of
training both for
Seema Misra and,
more generally, the
training process and
outcomes for
individuals with a
similar profile of
experience and
English language
It has not been possible to review full
and complete training records for
Seema Misra. Nor has it been possible
to review a complete set of training
materials. Finally, to observe the
training process for a sub postmaster
with a similar level of English capability
as Seema Misra.
Two weeks from the time that a complete
set of information has been provided and
the training process has been observed for
an individual with a similar level of English
language capability
We have been provided with part
of a guide that explains the
process for manually dealing with
a card payment that fails to be
properly recorded due to a system
problem. It has not been possible
to establish whether the training
Seema Misra received ensured
that she was competent to deal
with this kind of problem.
capability No comment
The Horizon System fails to I 21 September I In order to identify A post office has been identified where I Six weeks from the time that a date is Gareth Jenkins, in a telephone
properly process 2009 whether this is a the sub post master is suffering from I offered for access to a branch system for _I interview on 12th February 2010
transactions
possible cause, it
would be necessary in
the first instance
examine the
operations in normal
Post Office conditions
where there is an
experience by the
branch manager of
what they believe to be
incorrect transaction
processing.
continuing discrepancies, there is
currently no suggestion of theft o false
accounting and the sub postmaster is
prepared to permit electronic
observation of the use of the Horizon
system, The use of a camera or
screen capture tool was proposed in
the report dated 19th November 2009.
It has not been possible to conduct
electronic observation of the use of the
Horizon system at the identified post
office because the Post Office has not
released the sub postmaster from their
contractual obligation of confidentiality
and the Post Office has not facilitated
any arrangements to install the
necessary monitoring tool.
the purpose of electronic monitoring
explained that the Horizon system
managed by Fujitsu is only part of
a much larger of integrated
systems used by the Post Office
to manage their counters
business. In particular, SAP, a
data warehouse and technology
connecting to a merchant service
provider for card payment
services is involved. The scope of
any systems audit will need to
ensure that any issue relating to
these other systems can be
excluded
I don't see the relevance of such a
statement to this observation.
What happens in the Branch is
recorded in the local branch logs
and we now have these for the 13
moth period of Dec 06 to Dec 07.
Clearly we can't prove that
nothing is missing from the logs,
but there is no evidence to
indicate any system faults that
result in missing transactions
Charles McLachlan
POL00055196
POL00055196
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
Hypothesis ist Raised investigation Progress to date Expected time required to complete implications of most recent
Required investigation information
The Horizon System falls to
properly process
transactions
27 September
2009
if there is prima facie
evidence of incorrect
transaction processing,
it would be necessary
to review the technical
documentation of the
Horizon system and
interview key
individuals responsible
for the system within
the Fujitsu team in
order to understand
the potential source of
the incorrect
transaction processing.
It has not been possible to conduct a
detailed interviews with members of
the Fujitsu team although a prelimary
conversation with Gareth Jenkins
occurred on 12th February 2010
Two weeks from the time that the interviews
are completed
Gareth Jenkins, in a telephone
interview on 12th February 2010
explained that the Horizon system
managed by Fujitsu is only part of
a much larger of integrated
systems used by the Post Office
to manage their counters
business. In particular, SAP, a
data warehouse and technology
connecting to a merchant service
provider for card payment
services is involved. The scope of
the interviews will need to engage
managers and technical experts
so that any possible issues
relating to these other systems
can be understood
I don't see the relevance of such a
statement to this observation.
What happens in the Branch is
recorded in the local branch logs
and we now have these for the 13
moth period of Dec 06 to Dec 07.
Clearly we can't prove that
nothing is missing from the logs,
but there is no evidence to
indicate any system faults that
result in missing transactions.
The back end systems are
relevant to POL’s overall
accounting, but not to what is
recorded and reported in the
Branch accounts which is what is
indicating the losses which the
defendant is being accused of
Charles McLachlan
Amsphere
POL00055196
POL00055196
Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
The Horizon System fails to
properly process
transactions
27 September
2009
Ifthe potential source
of the incorrect
transaction processing
can be identified then it
would be helpful to be
able to reproduce the
problems under
controlled test
conditions in a
consistent and
reproducible manner.
This would require the
assistance of Fujitsu in
providing access to the
test environments
maintained in support
of the Horizon system.
‘A number of hypotheses relating to
incorrect transaction processing have
been identified but it has not been
possible to conduct any testing in a
controlled environment
‘Six to twelve weeks from the time that a test
environment is made available.
Gareth Jenkins, in a telephone
interview on 12th February 2010
explained that the Horizon system
managed by Fujitsu is only part of
a much larger of integrated
systems used by the Post Office
to manage their counters
business. In particular, SAP, a
data warehouse and technology
connecting to a merchant service
provider for card payment
services is involved. The scope of
testing process will need to
ensure that end to end testing
across these other environments
is possible if the problems cannot
be reproduced in the Fujitsu
environment alone.
I don't see the relevance of such a
statement to this observation
What happens in the Branch is
recorded in the local branch logs
and we now have these for the 13
moth period of Dec 06 to Dec 07.
Clearly we can't prove that
nothing is missing from the logs,
but there is no evidence to
indicate any system faults that
result in missing transactions.
The back end systems are
relevant to POL's overall
accounting, but not to what is
recorded and reported in the
Branch accounts which is what is
indicating the losses which the
defendant is being accused of.
\'m not clear exactly what test
scenarios are proposd. Given that
the system has now moved on,
there are no longer any test
facilities for the system as it
operated in 2006 2007.
Charles McLachlan
POL00055196
POL00055196
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
Hypothesis ist Raised investigation Progress to date Expected time required to complete implications of most recent
Required investigation information
Incorrect data entryis not I 19November I System audit of branch I Ithas not been possible to conduct a__I Six to twelve weeks from the ime the Gareth Jenkins, in a telephone
resolved by sub post office I 2009 transaction logs and I systems audit - indeed no branch system audit commences interview on 12th February 2010
reconciliation and relies on the Post Office transaction logs have been provided explained that branch transaction
the consistent, accurate and
timely resolution of
discrepancies by the Post
Office and operators of the
Horizon system
reconciliation system
logs are extremely detailed
records of all branch actions as
well as any branch system
exceptions (e.g. network failure).
They are routinely archived for 7
years and a Fujitsu employee is
engaged full-time to provide
recovery of logs from the archive
in a routine batch process which,
he said, has been forensically
examined to demonstrate a full
chain of evidence necessary for
the logs to be used in court. In
addition, he explained that
software is provided by Fujitsu for
converting the logs into a readily
accessible spreadsheet format for
system and accounting audit
purposes.
The logs are now available and I
have started looking in them
NB there are 431,490 transactions
in the 13 month period!
The Horizon system does
not appear to be a single
monolithic mainframe based
system with computer
terminals with no
independent processing
capability: each of these
components could give rise
to faults that result in
discrepancies.
19 November
2009
‘System audit of branch
transaction logs and
the Post Office
reconciliation system
ithas not been possible to conduct a
systems audit - indeed no branch
transaction logs have been provided
Six to twelve weeks from the time the
system audit commences
Gareth Jenkins, in a telephone
interview on 12th February 2010
explained that the Horizon system
managed by Fujitsu is only part of
a much larger set of integrated
systems used by the Post Office
to manage their counters
business. In particular, SAP, a
data warehouse and technology
connecting to a merchant service
provider for card payment
services is involved. The scope of
systems audit process will need to
ensure that end to end audit of
transaction records is conducted if
Charles McLachlan
POL00055196
POL00055196
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
the issue cannot be identified in
the Fujitsu systems alone.
The back end systems are
imelevant for problems in the
branch accounts. The logs are
now available
Charles McLachlan 8
POL00055196
POL00055196
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
Hypothesis ist Raised investigation Progress to date Expected time required to complete Implications of most recent
Required investigation information
The end to end dialogue 79 November I System audit of branch I Ithas not been possible to conduct a _I Six to twelve weeks from the time the Gareth Jenkins, in a telephone
between the counter 2009 transaction logs and _I systems audit - indeed no branch system audit commences interview on 12th February 2010
terminal, the card the Post Office transaction logs have been provided explained that the Horizon system
authorisation terminal, the
network, the core Horizon
system, the electronic funds
transfer component, the
authorising merchant
service and the central post
office branch accounting
system is a long running
transaction with multiple
points of possible failure
reconciliation system
managed by Fujitsu is only part of
a much larger set of integrated
systems used by the Post Office
to manage their counters
business. In particular, SAP, a
data warehouse and technology
connecting to a merchant service
provider for card payment
services is involved. The scope of
systems audit process will need to.
ensure that end to end audit of
transaction records is conducted if
the issue cannot be identified in
the Fujitsu systems alone.
This is not relevant. The Branch
accounts are based purely on
whether the Branch thinks the
Debit Card was authorized or not.
Any subsequent failures are
irrelevant to the branch accounts.
Complex systems rarely
have sufficient capability
built in to deal with all
possible failure points and
discrepancies are very likely
to arise which require
manual intervention based
on the reconciliation of
paper and electronic logs at
different points in the
system.
19 November
2009
Based on the review of
the technical
documentation, it
should be possible to
identify and examine
the various electronic
log files maintained by
different components
of the systems
architecture that are
required by the
Electronic Mastercard
Visa (EMV) standard
or for Payment Card
Industry (PCI)
compliance.
thas not been possible to proceed
with this review because no technical
documentation has been provided
Six to ten weeks from the time the technical
documentation is provided
Gareth Jenkins, in a telephone
interview on 12th February 2010
explained that the Horizon system
managed by Fujitsu is only part of
a much larger set of integrated
systems used by the Post Office
to manage their counters
business. In particular, SAP, a
data warehouse and technology
connecting to a merchant service
provider for card payment
services is involved. The scope of
the technical documentation will
need to cover all of these
systems
This is not relevant. The Branch
accounts are based purely on
whether the Branch thinks the
Charles McLachlan
POL00055196
POL00055196
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
Debit Card was authorized or not.
Any subsequent failures are
irrelevant to the branch accounts.
Charles McLachlan 10
POL00055196
POL00055196
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
2 Instructions etc.
2.1 Instructions
2.1.1 1 am Charles Alastair McLachlan, a Director of Amsphere Consulting
Limited, London, England specialising in information technology consulting.
I have been instructed in this matter by Coomber Rich Solicitors, on behalf of
their client, Seema Misra, (“the Defendant”) to assist the court in this matter
of alleged fraudulent accounting in providing expert evidence on the
questions posed at 1.1.3 hereunder.
2.1.2 Ihave been instructed to review progress on my investigation to date and the
expected time required to complete a full report.
2.2 My qualifications have been itemised in the previous two interim reports.
2.3 Confidentiality
2.3.1 This report is strictly private and confidential and has been prepared at the
request of Coomber Rich Solicitors on behalf of their client, for the Court.
2.4 Legal and factual issues
2.4.1 This report should not be read as expressing any opinion on factual matters
which depend on disputed testimony of the witnesses of fact, or legal issues.
It, however, inevitably reflects my understanding of the position.
2.5 Sources of information
Charles McLachlan i
POL00055196
POL00055196
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
2.5.1 In preparing my report, I have considered the documents used for my
previous reports
2.6 The scope of my work
2.6.1 I report as an expert witness, not as a witness of fact. I have reviewed the
documentation provided to me.
2.7 Independence
2.7.1 Ihave prepared an independent and objective report addressed to the Court. I
have had no previous involvement with the Defendant. I have no previous
involvement with Coomber Rich Solicitors.
2.7.2 Amsphere’s fees in this case are not dependent on the result of the
proceedings in this matter.
Charles McLachlan 12
POL00055196
POL00055196
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
3 My duties to the Court
3.1
3.2
3.3
3.4
3.5
3.6
3.7
3.8
I understand that my overriding duty is to the Court, both in preparing reports
and in giving oral evidence. I have complied and will continue to comply with
that duty.
I have set out in my report what I understand from those instructing me to be
the questions in respect of which my opinions as an expert are required.
I have done my best, in preparing this report, to be accurate and complete. I
have mentioned all matters that I regard as relevant to the opinions I have
expressed. All of the matters on which I have expressed an opinion lie within
my field of expertise.
I have drawn to the attention of the Court to all matters, of which I am aware,
which might adversely affect my opinion.
Wherever I have no personal knowledge, I have indicated the source of factual
information.
I have not included anything in this report that has been suggested to me by
anyone, including the lawyers instructing me, without forming my own
independent view of the matter.
Where in my view, there is a range of reasonable opinion, I have indicated the
extent of that range in the report.
At the time of signing the report I consider it to be complete and accurate. I
will notify those instructing me if, for any reason, I subsequently consider that
the report requires any correction or qualification.
Charles McLachlan B
POL00055196
POL00055196
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
3.9 I understand that this report will be the evidence that I will give under oath,
subject to any correction or qualification I may make before swearing to its
veracity.
3.10 I have included in this report a statement setting out the substance of all facts
and instructions given to me, which are material to the opinions expressed in
this report or upon which those opinions are based.
3.11 I confirm that insofar as the facts stated in my report are within my own
knowledge I have made clear which they are, and I believe them to be true, and
the opinions that I have expressed represent my true and complete professional
opinion.
Charles McLachlan
Amsphere Consulting Ltd
90 Fenchurch Street
London, EC3M 4BY
England
Thursday, 25 February 2010
Charles McLachlan 14